The Golden Rules on major schemes

Appeal 6006637 · Warwick · Appeal · 23 Sept 2026 · 28 homes

• GB8(1)(b) fail (a) affordable and (c) green space met, but necessary local highway improvements for pedestrian safety not identified, substantiated or secured; Highway Authority considered mitigation inadequate (DL 12-13, 41-44)

28 affordable homes on a grey belt field next to Hatton Station, a small West Midlands Green Belt settlement, 350 m from a railway station reached along unlit Station Road with no footway. Dismissed after a hearing. The site failed GB7(1)(g)(iii): 28 homes would generate significant movement in this context, the location did not limit the need to travel, and the route to the station was unsafe for pedestrians. It also failed GB8(1)(b), because the necessary local highway improvements were not secured. The station fell short of the "well-connected station" definition, so GB7(1)(h) was not available. Very significant weight to affordable housing (1.96 years' supply) did not clearly outweigh the Green Belt harm.

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24/01047/OUT · Basildon · Council committee · 19 Aug 2026 · 11 homes

• GB7(1)(g)(iv) fail 11 dwellings = major; zero affordable vs 50% default; no viability evidence

Eleven market houses on a grey belt paddock at Billericay's edge. Grey belt, need and location limbs all passed. The scheme failed only the Golden Rules limb because it offered no affordable housing and no viability case. That made it inappropriate, and the committee unanimously held that an 11-home market benefit did not amount to VSC.

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25/2053/FUL · Cheshire East · Council committee · 19 Aug 2026 · 68 homes

• GB7(1)(g)(iv) fail care home treated as major development involving provision of housing; no affordable housing offered → Golden Rules failed → inappropriate
• GB8 fail update report — affordable contribution for care home could not meet CIL tests, so none required, yet GB8 non-compliance left scheme inappropriate

A 68-bed care home on the enclosed, previously developed site of a burnt-out nursing home on the edge of Handforth, decided two days after the new Framework was published. Officers found the site grey belt, with unmet need met and a sustainable location. They also treated the care home as "major development involving the provision of housing", so it had to meet the Golden Rules. No affordable housing was offered, so it failed GB7(1)(g)(iv) and was inappropriate. Officers then found very special circumstances, and the committee approved. The update report added a Connectivity Tool score (59–62%) and said the 2026 NPPF made no material change.

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Appeal 6010459 · Tonbridge and Malling · Appeal · 29 Sept 2026 · 7 homes

• GB7(1)(g)(iv) pass site exceeds 0.5 ha so is major development under Annex B; no evidence on the Golden Rules, but obligations cannot be secured at PIP stage, so GB8 contributions assumed capable of being met at technical details stage (DL 21)
• GB8 pass assumed, not evidenced or secured; deferred to the technical details consent stage (DL 21)

Permission in principle for 5 to 7 homes on Green Belt land at the edge of Hildenborough, partly inside the conservation area, was allowed. The access would break a protected hedgerow that defines the conservation area's edge, causing harm at the lower end of the scale. The inspector ran HE6(4) first and found the homes and economic benefits outweighed that harm. The site was grey belt, GB7(1)(g) was met (with the Golden Rules assumed to be deliverable at the next stage), and the S5(5) balance favoured approval.

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Appeal 6006497 · Tandridge · Appeal · 25 Sept 2026 · 30 homes

• GB7(1)(g)(iv) pass major housing complies with GB8 (DL 30)
• GB8 pass 50% affordable, infrastructure improvements and a significant area of publicly accessible woodland open space; compliance itself given substantial weight (DL 30, 68)

Outline scheme for up to 30 homes (half affordable) on a field on the Caterham edge, within Chaldon in the Tandridge Green Belt. Allowed after an inquiry against a non-determination. Grey belt, "fundamentally undermine" (DL ¶27) and unmet need were settled, and the Golden Rules were met. The contested limb was GB7(1)(g)(iii). The inspector found a genuine choice of modes for local trips (schools, cafe, village hall and shop within walking and cycling distance, school buses and a two-hourly bus), even though the hill to Caterham deters walking and commuting by bus would be hard. The Connectivity Tool score of 52 was read comparatively, as the top band in Tandridge. The scheme was therefore not inappropriate, and S5(5) led to approval.

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Appeal 6004144 · Tandridge · Appeal · 17 Sept 2026 · 132 homes

• GB8 pass 50% affordable, infrastructure, open space secured; GB8(2) substantial weight to compliance (DL 33-34, 52)

132 homes (50% affordable) on a contained field at the edge of Hurst Green/Oxted, decided after a two-day hearing. The inspector found the site was grey belt and passed all four GB7(1)(g) limbs, including sustainable location and the Golden Rules, so the scheme was not inappropriate. The station route GB7(1)(h) failed on walking distance. The appeal was still **dismissed**, on odour from the adjoining wastewater works, which arose late through a Southern Water objection. Odour harm "substantially outweighed" the benefits under S5(1)(j). A separate costs decision (costs PDF, 21 Sep 2026) awarded Wates full costs against Tandridge for unreasonable grey belt, sustainability and heritage reasons.

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Appeal 6007184 · Castle Point · Appeal · 14 Sept 2026 · 58 homes

• GB8 pass agreed Golden Rules met — 50% affordable, public green space, local infrastructure improvements; substantial weight under GB8(2) (DL 39, 100)

Outline scheme for up to 58 homes (50% affordable) on contained former paddocks on the Thundersley edge, previously dismissed on a larger red line in 2024. Allowed after a hearing: the site was grey belt, all four GB7(1)(g) limbs were met including the Golden Rules, so the scheme was not inappropriate. Under S5(5) the benefits (substantial weight to market and affordable housing given 0.91 years' supply and HDT 11%) were not outweighed by limited landscape and NDHA harm.

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25/00575/OUT · Basildon · Council committee · 9 Sept 2026 · 49 homes

• GB8 pass 50% affordable, infrastructure, green space; officers

49 homes (50% affordable) on an edge-of-Billericay Green Belt site in a borough with a 2.05-year supply. Officers treated it as grey belt passing all four GB7(1)(g) limbs, with VSC as a fallback, and recommended approval. Members voted 5-2 against on 19 August 2026, two days after the new Framework took effect. On 9 September they adopted a refusal reason finding that the site makes a "strong contribution to Green Belt Purpose (a)" and so is not grey belt, that openness harm is substantial, and that VSC are not shown.

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25/01052/FULMAJ · Chorley · Council committee · 8 Sept 2026 · 58 homes

• GB8 pass 100% affordable; contributions; open space

58 affordable homes on a Green Belt field at the edge of Croston, a village with a station. Officers found grey belt: a village is not a "large built-up area", so purpose (a) is weak. They passed all GB7(1)(g) limbs and recommended approval. The appeal against non-determination was already running. Members unanimously said they would have refused, but gave only the Core Strategy spatial strategy (Policy 1) and the emerging plan as the reason. They did not give a Green Belt reason.

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25/04952/EOUT · Bath and North East Somerset · Council committee · 2 Sept 2026 · 200 homes

• GB8 pass 45% affordable (30% + 15 points), highway and education contributions, accessible green space; affordable given 'very substantial' weight

Outline permission for up to 200 homes (45% affordable) on a greenfield Green Belt parcel on the edge of Keynsham, in an authority with a 2.5-year supply. Officers treated the site as grey belt even though the strategic WECA assessment rated the wider parcel "significant" on purposes (a) and (b). They assessed the site on its own: contained, not an incongruous finger, and a small part of the Keynsham–Bristol gap. They passed every GB7(1)(g) limb, with the Golden Rules uplift taking affordable housing from 30% to 45%. They then ran the S5(5) "substantially outweighed" balance and recommended approval. Members agreed 5-4.

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25/2168/OUT · Three Rivers · Council committee · 20 Aug 2026 · 70 homes

• GB8 benefit 50% affordable, infrastructure contributions, on-site green space; members gave compliance significant weight

Outline scheme for up to 70 homes (50% affordable) on a Green Belt field at Oxhey Lane, on the edge of Watford Heath/Carpenders Park, in a district with a 1.2-year supply. Officers recommended approval. Three days after the new Framework was published, their addendum said the site was grey belt and also qualified under the new station route GB7(1)(h), treating Bushey station at about 1,100 m as "around 800m". Members refused 5-4. They held the site was not grey belt and that 1,100 m is not "around 800m". So the scheme was inappropriate, and the Golden Rules benefits did not amount to very special circumstances against Green Belt harm plus harm to a Grade II listed lodge.

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25/01188/OUT · Basildon · Council committee · 19 Aug 2026 · 71 homes

• GB8 pass 50% affordable, 2.5 ha (51%) public green space, infrastructure — but GB8 compliance cannot cure failure of limb (i)

71 homes (50% affordable) on the edge of Wickford. Officers accepted that the site is not grey belt, because it makes a strong contribution to purpose (a), but recommended approval on very special circumstances: a 2.05-year supply, 36 affordable homes, and BNG well above 10%. Members disagreed 4-2 and resolved that they would have refused. The non-determination appeal will now proceed.

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TM/25/01976/PA · Tonbridge and Malling · Council committee · 19 Aug 2026 · 350 homes

• GB8 pass 50% affordable, infrastructure contributions, public open space and sports ground link

350 homes (50% affordable) on a closed commercial plant nursery on the edge of Tonbridge, in the Metropolitan Green Belt. The site is mostly PDL, but the quantum would cause substantial harm to openness, so GB7(1)(e) failed. Officers instead found it grey belt and passed all four GB7(1)(g) limbs, with the Golden Rules met. The committee approved 10-1-2 two days after the new Framework took effect, on a supplementary report whose 2024→2026 comparison table was drafted by the applicant and endorsed by officers.

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