- Decision
- dismissed, 23 September 2026
- Decided by
- Planning Inspector: H Nicholls
- Authority
- Reading (South East)
- Appeal reference
- 6007941
- Application reference
- PL/25/1020
- Procedure
- written representations
- Development
- Terrace of four 3-bed 2.5-storey houses with parking
- Homes
- 4
- Site context
- inside settlement, flood zone 3
- Green Belt
- No
- Housing land supply
- 3.55 years
- Framework applied
- August 2026 NPPF
- Determinative policies
- F6(1)(b), S4(1), DP3(2)
- Development plan policies
- Reading Borough Local Plan 2019 EN12, EN14, EN18, CC7, H3, H10, TR3, Affordable Housing SPD 2021
- Main issues
- flood risk; design; access; affordable housing; biodiversity
Summary
Four terraced houses on an infill plot in Caversham, in Flood Zone 3a, were dismissed. The sequential test passed on a ward-level search. The exception test failed: there was no evidence of safe escape, and underfloor voids are no longer accepted as floodplain compensation. The design was ungainly, with small gardens. Access visibility was not shown, and there was no affordable housing mechanism. The housing benefit got great weight against a 3.55-year supply. The inspector still found it "substantially outweighed" under S4 (DL ¶40).
Issues and findings
- Transition. The parties had the opportunity to comment on the August 2026 Framework (DL ¶2).
- Sequential test: PASS. For non-major housing the ward-level search area was acceptable. The council held no ranked register and identified no alternative (DL ¶6-9).
- Exception test: FAIL. "limited information is provided on flood depths or durations ... I am not satisfied that the development would be safe for its intended occupiers over its lifetime" (DL ¶13). "the use of voids is no longer an acceptable means of providing compensatory flood storage ... the development would increase flood risks elsewhere" (DL ¶16). The Environment Agency's earlier acceptance of voids pre-dated the August 2022 PPG change (DL ¶15).
- Design: FAIL. "the collective bulk and massing of the terrace would be ungainly ... exacting replicas of one another" (DL ¶20-21).
- BNG. Off-site units were an acceptable use of the hierarchy on a small infill site (DL ¶33).
Planning balance
This was the S4 balance. The harms engaged "Policy F6(1) (b) (ii) ... and (iii) and Policy DP3(2)" (DL ¶38). The benefits of a sustainable location, efficient land use and housing against a 3.55-year shortfall "collectively attract great weight" (DL ¶39). But "the benefits of approving the development would be substantially outweighed by the totality of the adverse effects" (DL ¶40).
What made the difference
The flood exception test. Passing the sequential test on a narrow search area did not help once the FRA lacked depth and duration data for escape routes and relied on voids. Several independent failures, on design, access and affordable housing, added to it.
Transferable points
- For non-major housing, a ward-level sequential search area is acceptable, and the absence of a council register helps the appellant (DL ¶6-9).
- Underfloor voids should not be relied on as floodplain compensation (PPG para 049, August 2022). The inspector treated this as settled, not negotiable (DL ¶15-16).
- The FRA must show depth and duration along the escape route to prove safety for the lifetime of the development (DL ¶13).
- F6 exception-test failures feed into the S4 "substantially outweighed" balance, even against "great weight" housing benefits (DL ¶38-40).
Policy findings
Policy codes are those of the National Planning Policy Framework (August 2026) unless a development plan is named.
| Policy | Finding | Weight | Note |
|---|---|---|---|
| F6(1)(b) | fail | sequential test passed (Caversham ward search); exception test failed - not safe for lifetime (no depth or duration data for the 5-minute escape route) and underfloor voids not acceptable floodplain compensation (PPG Aug 2022), so increases flood risk elsewhere (DL 6-17, 38) | |
| DP3(2) | fail | ungainly bulk, repetitive terrace, blank flank wall, mean gardens (DL 18-24) | |
| S4(1) | fail | great weight to housing and efficient land use against a 3.55-year supply, substantially outweighed by totality of harms (DL 37-40) | |
| HO7 | benefit | great | modest but valuable contribution with acknowledged shortfall (DL 35, 39) |
Key facts
- Supply 3.55 years, undisputed (DL 35)
- Displaces 253.8 cubic metres of floodplain storage; voids proposed as compensation; EA objected (DL 14-16)
- Visibility splays not demonstrated; no affordable housing contribution or UU despite viability negotiation (DL 26-30)
Sources
This note is one of the decisions behind the NPPF 2026 Navigator, which shows how each Framework test has been applied across all the decisions in the database. Also available as Markdown.