- Decision
- dismissed, 2 October 2026
- Decided by
- Planning Inspector: P Barton
- Authority
- Dorset (South West)
- Appeal reference
- 6012115
- Application reference
- P/FUL/2025/00299
- Procedure
- written representations
- Development
- Static caravan used as rental accommodation, with a new access from Grange Road, gravel paths and driveway, and decking (part retrospective)
- Homes
- 1
- Site context
- green belt
- Green Belt
- Yes (grey belt not argued)
- Framework applied
- August 2026 NPPF
- Determinative policies
- GB7(1)(g)(iii), TR3, GB6(2)
- Development plan policies
- Christchurch and East Dorset Local Plan Part 1 Core Strategy 2014 KS3
- Main issues
- inappropriate development; openness; very special circumstances
Summary
A static caravan let as a separate home, with its own access, on garden land in the Green Belt at St Leonards and St Ives. The inspector held that stationing a caravan as a home is not a change in the use of land of the kind GB7(1)(f)(iii) covers, and that the site fails the sustainable location limb of GB7(1)(g) because the walk to the A31 bus stops is long, mostly unlit and ends at an uncontrolled crossing. The scheme was inappropriate, and one small home did not amount to very special circumstances. Dismissed.
Issues and findings
- Transition. "The main parties were given the opportunity to comment, and the comments received have been taken into account in the determination of the appeal" (DL ¶2).
- GB7(1)(f)(iii) change of use: FAIL. "It is not an open-ended category but rather, because of the words “such as”, the uses that will be within it should take their flavour or extent from the examples given" (DL ¶9). "policy GB7(1)(f)(iii) does not include development that covers the provision of a static caravan" (DL ¶9).
- GB7(1)(g)(iii) / TR3 sustainable location: FAIL. "the distance along the pavement to Boundary Lane is a noticeable one, with most of its length being unlit" (DL ¶11). "these road conditions would not be an attractive option for walkers and those with mobility … issues, particularly during hours of darkness and in adverse weather" (DL ¶11; the … marks a page break). "the proposed development is not in a sustainable location, and as all the criteria listed must be satisfied, it would not fall under the category of development specified under policy GB7(1)(g) of the Framework" (DL ¶13).
- Openness: HARM. Moderate spatial harm and "moderate harm to visual openness" (DL ¶16–17).
- Housing benefit: moderate. "due to the small scale of the proposal, and thereby the small scale of the benefits, I afford this moderate weight" (DL ¶19).
- Fallback: limited weight. "the proposal would have a more harmful impact on the openness of the Green Belt than this fallback, and I afford this limited weight" (DL ¶20).
Planning balance
GB6(2) very special circumstances. Substantial weight to Green Belt harm (inappropriateness plus moderate spatial and visual openness harm) against moderate weight to one home and limited weight to the fallback. "The other considerations in this case, as detailed above, do not have sufficient cumulative weight to clearly outweigh the harm to the Green Belt and any other harm" (DL ¶25). The letter then records: "For this reason, policy S5 of the Framework is not engaged" (DL ¶25).
What made the difference
The route to the bus stops. The inspector did not need to decide grey belt or unmet need: limb (iii) failed on a long, mostly unlit pavement and an uncontrolled crossing of the A31, and all four limbs of (g) must be met. A lit route with a controlled crossing, or evidence of nearer services, would have been needed before the other limbs mattered.
Transferable points
- GB7(1)(f)(iii) is read by its examples: "such as" outdoor sport, recreation and cemeteries gives the category its flavour, and stationing a caravan as a home is outside it (DL ¶9).
- A decision-maker can fail GB7(1)(g) on limb (iii) alone without deciding grey belt or unmet need (DL ¶13).
- A footway does not make a route acceptable where most of it is unlit and it ends at an uncontrolled crossing of a busy road; the route is judged for walkers and for people with mobility issues (DL ¶11).
- One home in the Green Belt: the Framework's substantial weight to providing homes was reduced to moderate for scale (DL ¶19).
- Once a scheme is inappropriate and very special circumstances are not shown, S5 "is not engaged" (DL ¶25).
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)(f)(iii) | fail | the limb is not open-ended: because of the words "such as", uses within it take their flavour from the examples given; it does not cover the provision of a static caravan (DL 9) | |
| GB7(1)(g)(iii) | fail | bus stops on the A31 0.6 miles (appellant) or over 1 km (Council) away along a mostly unlit pavement; uncontrolled crossing of heavy traffic to the northbound stop; occupants heavily reliant on the car (DL 10-13) | |
| TR3 | fail | applied through GB7(1)(g)(iii); "absence of genuinely sustainable travel choices" (DL 12); no TR3(1)(a) significant-movement threshold question asked for one unit | |
| GB7(1)(g)(i) | not-engaged | grey belt and unmet need limbs not decided; (g) failed on limb (iii) alone because all four criteria must be met (DL 13) | |
| GB6(2) | harm | substantial | inappropriate; moderate spatial and moderate visual openness harm from a semi-permanent caravan, independent access, comings and goings and domestic paraphernalia; VSC not shown (DL 16-18, 24-25) |
| HO7 | benefit | moderate | Framework's substantial weight to providing homes acknowledged, but "due to the small scale of the proposal, and thereby the small scale of the benefits" moderate weight to the home, efficient use of land and economic benefits together (DL 19) |
| S5(5) | not-engaged | inappropriate and no VSC, so "policy S5 of the Framework is not engaged" (DL 25) | |
| N6 | neutral | Dorset Heathlands and New Forest SAC/SPA mitigation; draft UU only; appropriate assessment not needed as dismissed on other grounds (DL 22-23) |
Key facts
- Static caravan sited since 13 November 2023 on garden land at a road junction; driveway, paths and decking already built (DL 3)
- Bus stops on the A31 0.6 miles (appellant) or over 1 km (Council) away; most of the pavement unlit; non-signal-controlled crossing where traffic flows are heavy (DL 11)
- Fallback of ancillary use of the caravan given limited weight because independent occupation would be noticeably more intensive (DL 20)
- Case law cited on openness - Turner, Samuel Smith and Mole Valley v SSCLG and Meloney [2025] EWHC 2127 (Admin) (DL 16, fn 1)
- Appellant relied on the duty to consider the needs of people residing in caravans; not a gypsy and traveller proposal, so decided as a rental home (DL 5)
- Housing land supply not stated in the letter
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.