- Decision
- dismissed, 21 September 2026
- Decided by
- Planning Inspector: T Bennett
- Authority
- Horsham (South East)
- Appeal reference
- 6010187
- Application reference
- DC/25/1803
- Procedure
- hearing
- Development
- Siting of temporary (3-year) rural worker's dwelling (mobile home) and associated works
- Homes
- 1
- Site context
- open countryside, isolated
- Green Belt
- No
- Housing land supply
- 1 years
- Framework applied
- August 2026 NPPF
- Determinative policies
- HO11(1)(a), S5(3), S5(1)(j)
- Development plan policies
- Horsham District Planning Framework 2015 Policies 1, 3, 4, 20, 26
- Main issues
- functional need for rural worker's dwelling; isolated homes
Summary
A temporary mobile home for a worker at a small organic poultry and sheep start-up in the Horsham countryside. Dismissed after a hearing. It was agreed to be an isolated home, so S5(3) sent it to HO11(1)(a), and essential need for a permanent on-site presence was not shown. The 1-year supply created an unmet need, but S5(1)(j) failed because an isolated dwelling cannot be physically well-related to a settlement. E2's substantial weight to rural business did not help, because the business did not depend on the dwelling.
Issues and findings
- Transition. The Framework was discussed at the hearing (DL ¶2).
- S5(3) → HO11. "the parties agreed that policy HO11 … was applicable" (DL ¶8). The PPG rural-worker tests were applied (DL ¶9).
- Essential need: NOT SHOWN. Daily tasks "could likely be carried out without a rural working residing on site 24/7" (DL ¶13). Incubator failure: "the appellant stated that they had never experienced a malfunction" (DL ¶15). Monitoring alternatives: "remotely operated CCTV, alarm and/or automation systems … none of which are currently in use" (DL ¶17). Lambing: "temporary seasonal accommodation over the lambing period could meet the welfare needs" (DL ¶20). Predators: the coop that was attacked "had not been protected by electric netting" (DL ¶21). A temporary permission "does not remove the need to demonstrate an essential functional need" (DL ¶26).
- S5(1)(j): FAIL. "The Council is only able to demonstrate a 1 year housing land supply … However, this alone is insufficient to garner support from policy S5 paragraph 1.j. … As it is common ground that the dwelling would be isolated, this criterion is not met … the appeal proposal does not benefit from the presumption in favour of sustainable development as set out in policy S3" (DL ¶30).
- E2/E4. "Notwithstanding the substantial weight to be afforded, the limited scale of the proposal means any resulting economic benefits would be limited" (DL ¶34).
Planning balance
The decision was taken under s38(6), with conflict with HDPF Policy 20 and the Framework's HO11/S5(3). Housing had very limited weight because the unit was temporary and tied (DL ¶31). E2 benefits were limited (DL ¶33-34). Absence of other harm was neutral (DL ¶35).
What made the difference
The evidence on functional need. The appellant had not tried CCTV, alarms, netting or seasonal cover, so it could not be shown that only a permanent on-site presence met the risks. A 1-year supply does not rescue an agreed isolated home, because S5(1)(j)(i) needs a physical relationship to a settlement.
Transferable points
- Isolated homes route through S5(3) to HO11. The S5(1)(j) shortfall route is closed to them, however severe the shortfall (DL ¶30).
- HO11(1)(a) essential need is assessed with the PPG rural-worker considerations. Untried alternatives (CCTV, alarms, netting, seasonal presence) defeat a 24/7 case (DL ¶9, 17, 20-22).
- A temporary permission for a new enterprise still requires essential functional need to be shown (DL ¶26).
- E2's "substantial weight" attaches to the benefits, and these are small where the enterprise can prosper without the dwelling (DL ¶33-34).
Policy findings
Policy codes are those of the National Planning Policy Framework (August 2026) unless a development plan is named.
| Policy | Finding | Weight | Note |
|---|---|---|---|
| HO11(1)(a) | fail | no essential need for a rural worker to live on site 24/7; the poultry and ewes could be managed with CCTV/alarms, electric netting and seasonal lambing cover (DL 8-25) | |
| S5(3) | fail | agreed isolated home, so HO11 governs (DL 7-8, 27) | |
| S5(1)(j) | fail | 1-year supply means unmet need, but the dwelling is agreed isolated, so not physically well-related to a settlement; no presumption under S3 (DL 30) | |
| E2 | benefit | limited | substantial weight in principle, but the dwelling is not needed for the enterprise to grow, so benefits limited (DL 32-34) |
| HO7 | benefit | very-limited | temporary and tied to a rural worker (DL 31) |
Key facts
- 25-acre organic livestock start-up; by year 3, 4,000 laying hens, 1,200 broilers, 400 quail, 25 ewes; currently about 280 birds
- Council supply only 1 year
- Rudgwick and Billingshurst 10-15 minutes' drive
- No CCTV, alarms or netting in use; a predator attack occurred on an unnetted coop, and break-ins happened while the appellant lived on site
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.