- Decision
- dismissed, 28 August 2026
- Decided by
- Planning Inspector: N Bowden
- Authority
- St Albans (East of England)
- Appeal reference
- 6011520
- Application reference
- 5/2026/0202
- Procedure
- householder
- Development
- Full-width single-storey rear extension, garage conversion, front extensions, Dutch gables and rear dormers to a bungalow
- Site context
- green belt, conservation area
- Green Belt
- Yes
- Framework applied
- August 2026 NPPF
- Determinative policies
- N2, GB7(1)(b), HE9
- Development plan policies
- St Albans District Local Plan Review 1994 Policies 1, 13, 69, 72, 85, 106, Residential Extensions and Replacement Dwellings in the Green Belt SPG
- Main issues
- protected species; inappropriate development; conservation area
Summary
Extensions to a bungalow in the Metropolitan Green Belt and Old Bricket Wood conservation area. The appeal was dismissed on bats alone. The extensions were found not disproportionate under GB7(1)(b) and the conservation area was preserved, but no bat roost assessment was before the inspector.
Issues and findings
- Transition. The parties were consulted because the changes "could be considered material" (DL ¶2).
- GB7(1)(b): PASS. A later detached garage counts as an extension to the original building (Warwick DC v SSLUHC [2022] EWHC 2145 (Admin)) (DL ¶11). "I have judged the proposal, ultimately, on the visual and spatial effects of the extensions … they are not disproportionate to the original building" (DL ¶14).
- Conservation area. Preserved (DL ¶21).
- Bats: FAIL. "in the absence of any evidence to indicate that bats are not present, the proposal conflicts with policy 106 … and Framework" (DL ¶7).
Planning balance
None needed. The failure on protected species was determinative (DL ¶24).
What made the difference
The missing Preliminary Roost Assessment. The Green Belt and heritage cases were won.
Transferable points
- Detached outbuildings added after the original dwelling count as extensions in the GB7(1)(b) proportionality test (DL ¶11).
- Disproportion is judged in the end on visual and spatial effect, not only on disputed volume figures (DL ¶14).
- Missing bat surveys can defeat even a householder scheme that passes the Green Belt tests (DL ¶24).
Policy findings
Policy codes are those of the National Planning Policy Framework (August 2026) unless a development plan is named.
| Policy | Finding | Weight | Note |
|---|---|---|---|
| GB7(1)(b) | pass | rear extension at or marginally above SPG limits; roof alterations within footprint, no raised eaves/ridge; not disproportionate judged on visual and spatial effects; detached garage counted as an extension (Warwick DC v SSLUHC [2022]) (DL 8-14) | |
| GB6(2) | not-engaged | not inappropriate so openness not assessed (DL 15) | |
| HE9 | pass | Old Bricket Wood CA preserved; rear dormers/flat roof unsympathetic but rear, similar to neighbours (DL 16-21) | |
| N2 | fail | no Preliminary Roost Assessment; bats likely given semi-natural setting → cannot conclude no harm (DL 5-7, 24) |
Key facts
- A detached bungalow in a small row in woodland at Old Bricket Wood conservation area
- A PRA was commissioned but not submitted, and new evidence at appeal would not be accepted under the Procedural Guide (DL 5)
- The emerging replacement local plan's policies were not given significant weight (DL 3)
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.