Honeysuckle Bottom Sawmill, East Horsley

Decision

allowed, 21 September 2026

Decided by

Planning Inspector: C Walker

Authority

Guildford (South East)

Appeal reference

6011694

Application reference

25/P/00759

Procedure

written representations

Development

Demolition of sawmill buildings, conversion of barn to a dwelling and erection of two dwellings

Homes

3

Site context

open countryside, isolated, national landscape, ancient woodland, PDL, rural lane, green belt

Green Belt

Yes (grey belt not argued)

Framework applied

August 2026 NPPF

Determinative policies

S5(1)(c), S5(1)(d), S5(3), HO11(c), S5(4), N6

Development plan policies

Guildford Local Plan Strategy and Sites 2019 ID3, Development Management Policies 2023 P6, P7

Main issues

suitable location and accessibility; ancient woodland and SNCI

Summary

This was a non-determination appeal to replace a working sawmill in woodland near East Horsley, in the Surrey Hills National Landscape, with three homes: one barn conversion and two new builds. The appeal was allowed. The inspector accepted the site was car-dependent and conflicted with the spatial strategy. The scheme qualified under S5(1)(c) and (d), but the two new-build homes were isolated and did not meet HO11. The inspector therefore ran S5(4) and found exceptional circumstances. The main reasons were PDL redevelopment, 20% BNG, the removal of HGV traffic and disturbance, and the housing shortfall. The letter has serious drafting problems. It cites S5's sub-paragraphs as "S3(2)", "S3(3)" and "S3 Part 4", and uses the old "significantly and demonstrably outweigh" formula. It also records a Green Belt openness benefit but never applies GB6/GB7, even though S5(5) excludes Green Belt land from S5.

Issues and findings

• Transition. The parties made representations on the August 2026 Framework (DL ¶4).
• Location and TR3: FAIL. The rural roads, "none of which are lit or provided with footways" (DL ¶7), and the bridleways "would not provide safe or practical access to local services and facilities" (DL ¶8). "future occupiers would be likely to rely heavily, if not entirely, on the private car" (DL ¶9).
• Ancient woodland (N6): PASS despite a policy conflict. The worst-case buffer was 10 m against the 15 m Standing Advice (DL ¶16). But "the baseline ... is therefore not one of an undeveloped or undisturbed site, but of a functioning commercial operation" (DL ¶17). Domestic gardens would cause "a markedly lower level of activity and disturbance" (DL ¶22). Less weight went to P6 because there would be no "loss or deterioration of an irreplaceable habitat ... a key objective of Policy N6" (DL ¶24).
• S5 categories. "As the development falls into these two categories [(c) reuse and (d) PDL], the proposal meets the initial qualifying criteria of Policy S5(1)" (DL ¶25).
• Isolated homes. "Whilst one of the dwellings would meet the provisions of this exception [HO11(c)], two of the dwellings are new builds and therefore do not gain the support of policies HO11(c) nor S3(3)" (DL ¶27). The inspector then applied the S5(4) exceptional-circumstances test (DL ¶28).

Planning balance

The inspector ran S5(4) (miscited as S3 Part 4). On the benefit side: housing got significant weight (DL ¶29); economic benefits were moderate (DL ¶30); PDL reuse got considerable weight (DL ¶31). Green Belt openness improvement, National Landscape tranquillity and 20% BNG together got substantial weight (DL ¶32), and overall the benefits got substantial weight (DL ¶33). Against: the unsustainable location and spatial-strategy conflict (DL ¶34). That harm was "tempered by the fallback position and the likelihood of a reduction in overall traffic" (DL ¶35-36). "The harm from the site's unsustainable location, would not significantly and demonstrably outweigh the collective substantial benefits ... these matters constitute exceptional circumstances, where the benefits substantially outweigh the harm as required by Policy S5(4)" (DL ¶37).

What made the difference

The active sawmill fallback. It neutralised the transport harm, because residential use would cut HGV trips on narrow lanes. It also neutralised the ancient woodland harm, because the existing yard was more disturbing than gardens would be. Together with PDL and 20% BNG, that let a car-dependent, isolated site pass the demanding S5(4) test. Without an active, noisy lawful use to replace, S5(4) would almost certainly have failed. The case carries real risk as a precedent. The letter's S3/S5 citations are wrong. It also applies the superseded tilted-balance wording and omits a Green Belt assessment the Framework requires (S5(5)), even though openness is said to improve. A council could argue the decision was reached on the wrong test.

Transferable points

• A site can qualify under S5(1)(c)/(d) and still hit S5(3). The S5(1) categories do not cure isolation for new-build homes, which need HO11 (DL ¶25-27).
• Where an isolated-home element fails HO11, the inspector went to S5(4)'s reversed test (DL ¶28, 37).
• A realistic, intensive commercial fallback can temper both TR3 car-dependence and ancient-woodland buffer shortfalls (DL ¶17, 22-24, 35-36).
• An ancient woodland buffer below 15 m can be acceptable where it is a betterment over the existing use and secured by conditions, including removing PD rights (DL ¶18-24, 46).
• DM6(2)(c): Green Belt openness was not "clear justification" to remove PD rights, but ancient woodland protection was (DL ¶46).
• Caution: the letter miscites S5 as S3, uses "significantly and demonstrably outweigh" (DL ¶37), and applies S5 on a site it treats as Green Belt, contrary to S5(5).

Policy findings

Policy codes are those of the National Planning Policy Framework (August 2026) unless a development plan is named.

Key facts

• Working sawmill (PDL) in a clearing in the Surrey Hills National Landscape, surrounded by ancient woodland/SNCI; lanes unlit with no footways (DL 3, 6-7, 17)
• Letter records that the scheme "would improve the openness of the Green Belt" but applies S5, not GB6/GB7 - S5(5) says S5 does not apply in the Green Belt (DL 32, 46)
• Sawmill HGV and forklift traffic fallback used to temper both the ecology and transport harms (DL 17, 35-36)
• 20% BNG secured by condition (DL 32, 40)

Sources

• Appeal on the Planning Inspectorate appeals service
• Decision letter (Planning Inspectorate)

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.