TR6(4): unacceptable impact on highway safety

Appeal 6010033 · Hackney · Appeal · 1 Oct 2026

• TR6(4) fail narrow pavement, very limited parking and a Red Route frontage; comings and goings by cycles, motorbikes and cars would have an unacceptable impact on highway safety; letter says "paragraph 4 of Policy TR6" (DL 8-11)

A takeaway and delivery-only food use in a former barber shop in Hackney was dismissed. The premises are about 315 m from a school and outside any designated centre, contrary to the local 400 m exclusion policy and to Framework policy HC5. Activity from delivery riders and walk-in customers on a narrow pavement beside a Red Route would also have an unacceptable impact on highway safety under TR6(4).

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Appeal 6010934 · Rutland · Appeal · 30 Sept 2026 · 1 home

• TR6(4) fail northern splay needs third-party hedge removal; access width, fire appliance turning and delivery bay not shown (DL 33-39)

An isolated earth-sheltered self-build house in an open field near Great Casterton, proposed as an exceptional-design home under HO11(e). It deliberately copied Field House, allowed on appeal in 2022. The inspector held that a transplanted design is not "truly outstanding" (DL ¶25), that concealing it in an artificial mound would not significantly enhance its setting, and that the access failed on highway safety, ecology and archaeology. Under S5(4) the adverse effects substantially outweighed the benefits. Dismissed.

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Appeal 6008940 · Camden · Appeal · 29 Sept 2026

• TR6(4) fail TR6(4) not cited; the letter refers to "section 15" of the Framework and the safe use of transport and highway networks; reversing across a narrow footway and a bus lane beside a bus stop, with visibility limited by a flanking wall (DL 9-10, 13)

A proposal to use a front hardstanding at a basement flat on Finchley Road as a parking space, with a new crossover, was dismissed on the recommendation of an appeal planning officer. A car would have to reverse across a narrow footway and a bus lane beside a bus stop on a six-lane Red Route. That highway safety harm was given significant weight, and under S4 it substantially outweighed the limited benefit of one off-street space.

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Appeal 6009011 · Wychavon · Appeal · 29 Sept 2026 · 1 home

• TR6(4) fail no evidence that 60 m splays suit the 40 mph limit (60 mph nearby) or recorded speeds; condition could not mitigate (DL 8-10, 14, 48)

A live/work unit in open countryside near Inkberrow, with a new access onto the B4092. An earlier live/work permission on the site was an agreed fallback. The inspector found the visibility splays unevidenced for the road's speeds, a TR6(4) failure given very substantial weight, and that the rural-business category S5(1)(b) was not met because necessity was not shown. Under S5(4) the benefits did not outweigh the harm. Dismissed.

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Appeal 6010422 · King's Lynn and West Norfolk · Appeal · 29 Sept 2026 · 1 home

• TR6(4) fail Millers Lane too narrow for cars to pass; verge used; six trips a day increase conflict with pedestrians and cyclists; no severe capacity impact (DL 20-24, 50)

A self-build house on a field at the edge of Harpley, Norfolk, was dismissed. Self-build need was evidenced and the UU could secure it, so S5(1)(j) was in play, but the character harm and highway danger on a single-track lane made the nature of the development inappropriate there, failing (j)(i). Under S5(4), substantial weight to self-build did not substantially outweigh substantial weight to an unjustified DP3 conflict, considerable weight to TR6(4) safety harm and moderate TR3 harm.

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Appeal 6012642 · Peterborough · Appeal · 28 Sept 2026 · 23 homes

• TR6(4) fail no on-site servicing; refuse, delivery and maintenance vehicles would stop on a busy double-yellow-lined road near Boongate roundabout (DL 23-28, 47)

Replacing three houses on New Road, Peterborough, with 23 car-free flats. The inspector found significant harm to the character of the small-scale residential edge, overlooking and overbearing to a bungalow, no noise evidence against college plant, missing bat surveys, and an unacceptable highway safety impact because all servicing would be from a busy road. Substantial weight to housing was substantially outweighed under S4. Dismissed.

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Appeal 6012885 · Melton · Appeal · 28 Sept 2026

• TR6(4) fail parking demand beyond about 30 spaces; overspill field leased from a third party and unsecured; obstruction of narrow Main Street (DL 22-25, 34)

Temporary retention of a large white PVC events marquee in a pub paddock in the Branston Conservation Area. Dismissed on three grounds: harm to the conservation area not outweighed by unevidenced viability benefits; noise from events near homes; and parking overspill onto narrow village streets (TR6). The S4 balance failed.

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Appeal 6009517 · Wealden · Appeal · 25 Sept 2026 · 2 homes

• TR6(4) fail westbound visibility about 80 m against 116 m needed for 85th percentile speeds of about 43 mph on an A-road carrying over 21,000 vehicles a day; improvement on existing is not enough; no speed data for Herring Lane; no collisions does not show safety (DL 7-16, 29)

Two self-build homes in a side garden between Cross-in-Hand and Heathfield, using an existing lane access onto the busy A267. The site met S5(1)(j), with a 3.44-year supply, and was in a reasonably sustainable location, with no flood objection. But westbound visibility of about 80 m, against the 116 m needed for measured 43 mph speeds on a road carrying over 21,000 vehicles a day, meant an unacceptable highway safety impact under TR6(4). That harm substantially outweighed the housing benefits. Dismissed.

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Appeal 6006305 · Calderdale · Appeal · 23 Sept 2026

• TR6(4) fail overspill onto estate circulation areas harms highway safety and free flow (DL 12, 18)

Storage building for a joinery business on an industrial estate in Halifax, dismissed. It would take up the business's existing parking and yard, and the appellant could not show that the remaining parking, or land outside the red line, would meet the combined demand. This conflicted with TR4(1)(e) and brought in TR6(4).

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Appeal 6009997 · Buckinghamshire · Appeal · 23 Sept 2026 · 4 homes

• TR6(4) fail north-west visibility splay needs third-party hedge land; unsafe access on a curving 30 mph road (DL 11-16, 36)

Four houses on a narrow former builder's yard and garden site in the middle of Lacey Green, in the Green Belt and Chilterns National Landscape. Once the 2026 Framework was published, the council conceded the site was grey belt and met GB7(1)(g), and dropped its Green Belt refusal reason. The appeal still failed on highway safety: the access visibility splay depends on a neighbour's hedge. TR6(4) says such proposals should be refused, and the benefits (substantial weight to 4 homes against a 1.98-year supply) were "substantially outweighed".

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Appeal 6011100 · Buckinghamshire · Appeal · 23 Sept 2026

• TR6(4) fail "the Framework ... sets out that development should be refused on highways grounds if there would be an unacceptable impact on highway safety" — frontage too shallow, car would overhang narrow pavement (DL 7, 10)

A dropped kerb for a shallow frontage parking space. Dismissed because a parked car would overhang a narrow pavement. The TR6(4) "should be refused … unacceptable impact on highway safety" wording was invoked (DL ¶10). The benefit of home EV charging did not outweigh this.

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Appeal 6009228 · Kingston upon Hull · Appeal · 22 Sept 2026

• TR6(4) fail retained dropped kerb, small forecourt parking and supports near pavement edge beside a cycle lane on a busy road - unacceptable highway safety impact (DL 20-24)

Retrospective shop canopies, a free-standing canopy and proposed storage racking on the forecourt of a three-unit shop in the Beverley Road Conservation Area, Hull. The appeal was dismissed on conservation-area harm (HE6) and highway safety (TR6(4)). The S4 presumption was displaced through S4(2)(c) because DP3 and TR6 were treated as policies saying development "should be refused".

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Appeal 6006761 · Epping Forest · Appeal · 21 Sept 2026

• TR6(4) fail 2.4 x 78 m visibility splay depends on a ditch and verge the highway authority says is private; not securable by condition or Grampian condition (DL 14-21, 35)

B8 storage conversion of farm buildings in the Epping Forest Green Belt. Not inappropriate under GB7(1)(b). The location conflicted with TR3 and E3 but was on balance acceptable given E2 and E4 support. Dismissed because the required visibility splay could not be secured on land the highway authority accepts as highway. That breach of TR6(4), a "refuse" policy, meant the S5(2) presumption was defeated.

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Appeal 6010702 · Harrow · Appeal · 21 Sept 2026 · 1 home

• TR6(4) fail PTAL 2, head of cul-de-sac, no parking survey; overspill parking harms safety (DL 9-14)

Extending a house in Canons Park to form a second 3-bed dwelling. Dismissed on the recommendation of an Appeal Planning Officer, with no re-consultation on the new Framework (DL ¶4). Sub-standard ceiling heights (P3), overspill parking at PTAL 2 (TR6), and bin storage reachable only via a barriered footpath (DP3) were each given substantial weight. One net unit had moderate weight and was substantially outweighed under S4 (DL ¶23-24).

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Appeal 6006846 · South Tyneside · Appeal · 18 Sept 2026 · 1 home

• TR6(4) fail unacceptable impact on highway safety; new private access on a 30 mph local distributor road beside a junction, zebra crossing, bus stops and hatching (DL 7-16, 25)

One detached house in the garden of a corner property in Boldon Colliery, with a new direct access onto Cotswold Lane, a 30 mph local distributor road. It was a resubmission that added on-site turning. The appeal was dismissed on highway safety grounds alone. The access would add another conflict point where a junction, a zebra crossing, bus stops and hatched markings were already close together. That failed TR6(4), and because TR6(4) is a refusal policy, S4(2)(c) applied and outweighed substantial HO7 weight for one home in an area with a 4.1-year supply and 53% HDT.

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Appeal 6010090 · Somerset · Appeal · 18 Sept 2026 · 1 home

• TR6(4) fail not in reasons for refusal; substandard visibility at the existing access; unacceptable highway safety impact (DL 13-15)

Retention of a static caravan in open countryside near Stogursey as temporary accommodation for a Hinkley Point C worker. Dismissed. The site is outside any defined settlement and is an isolated home, so it is outside S5(1)(j) (not well-related to a settlement) and fails S5(3)/HO11. The small benefits came nowhere near the S5(4) "exceptional circumstances" test. The inspector also found a TR6(4) highway safety conflict that was not in the council's reasons.

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Appeal 6010288 · Dartford · Appeal · 18 Sept 2026

• TR6(4) fail tracking used cars shorter than the 4.8 m highway-authority standard; reversing across the footway near a junction, crossing and bus stop (DL 16-21, 25)

A driveway and crossover on a prominent corner front garden onto the A226 in Dartford. Dismissed. The inspector applied the 2026 Framework without re-consulting, because it did not "fundamentally alter the relevant policy position" (DL ¶5). Both DP3(3) (design) and TR6(4)/TR4(1)(c)(i) (highway safety) were treated as weighing "substantially" against, so the modest parking and EV benefits were "substantially outweighed" under S4 (DL ¶23-26).

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Appeal 6011375 · Waltham Forest · Appeal · 18 Sept 2026 · 1 home

• TR6(4) fail no mechanism to stop parking in the private alley turning head, or to secure car-free status; reversing onto a parked-up street "unacceptable impact on highway safety" (DL 12-19)

This was a resubmitted backland bungalow behind Walthamstow maisonettes. It was acceptable on character, following the 2025 appeal, but dismissed on highway safety and BNG. Nothing could stop occupiers parking in the private alley turning head. That would force cars to reverse onto a congested street, conflicting with TR6's "unacceptable impact on highway safety" test (DL ¶19). The statutory biodiversity metric was never submitted either (DL ¶25). Under S4, one home's limited benefit was "substantially outweighed" (DL ¶44).

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Appeal 6011522 · Coventry · Appeal · 18 Sept 2026

• TR6(4) fail 29 spaces against 56 required; existing footway and yellow-line parking at peaks already causes "severe adverse" safety impacts; staggered Friday sessions and unenforceable overflow letter insufficient (DL 10-13)

A replacement mosque, education and community building on Red Lane, Coventry, was dismissed on parking and highway safety. The site already runs over capacity. Friday worshippers park on footways and double yellow lines. The proposal would cut on-site spaces to 29 against a standard of 56, so the "severe adverse impacts" would continue (DL ¶11-13). The Framework was not consulted on because the relevant wording was "largely unchanged" (DL ¶3).

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Appeal 6005051 · Westminster · Appeal · 17 Sept 2026

• TR6(4) fail Framework not cited on highways; customers would wait in narrow mews carriageway with no footway (DL 30-38)

A retrospective cake-shop serving hatch on the mews flank of a Grade II listed Bayswater terrace. It harmed the listed building and the conservation area, partly by bringing commercial activity into a quiet mews, and customers would wait in a carriageway with no footway. Both appeals were dismissed. The parties had been consulted on the 2026 Framework, but the heritage reasoning uses the 2024 vocabulary throughout.

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Appeal 6009618 · Torridge · Appeal · 16 Sept 2026 · 3 homes

• TR6(4) fail steep narrow access, visibility splay needs third-party land; highway authority objected (DL 12-22, 41)

Three market homes on a field adjoining Petrockstowe on three sides, in Torridge. The inspector applied S5 because the site is outside the settlement despite adjoining it. S5(1)(e) infill failed. S5(1)(j) was engaged by the 4.61-year supply, but the housing benefit got only little weight. Against that were an unsafe access (TR6(4), a "should be refused" policy, substantial weight) and a Connectivity Tool score of 6/100. The benefits were "substantially outweighed".

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Appeal 6008848 · Wyre · Appeal · 15 Sept 2026 · 1 home

• TR6(4) fail 2.4 x 58 m splay to the NE not achievable in appellant's control; no legal agreement over third-party land (DL 7-11)

A barn-to-live/work conversion in rural Lancashire won on the principle and lost on access visibility. The inspector made an important finding under Annex A ¶2. The local plan's sequential hierarchy of uses for rural conversions (employment first, residential last) is more restrictive than S5(1)(c), which supports re-use "irrespective of their intended use", so conflict with it carries very limited weight. TR3(1)(a) was held not principally aimed at small-scale proposals. But TR6(4) non-compliance triggered S5(2), and the appeal failed.

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Appeal 6010379 · Redbridge · Appeal · 15 Sept 2026

• TR6(4) fail two spaces (over London Plan maximum), no tracking in a constrained yard; safe access not shown (DL 11-15, 32)

Intensifying a small HMO in Ilford to an 11-person large HMO. Dismissed. The location passed TR3 (walkable shops and services, buses, Goodmayes station). But the undersized communal space (significant weight) and an unproven parking and turning layout (TR6(4), moderate weight) substantially outweighed the moderate benefits under S4. This was so even though the HDT results were very low: 24% (2024) and 30% (2025).

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Appeal 6008646 · Coventry · Appeal · 14 Sept 2026

• TR6(4) fail on-street parking already at capacity; no parking survey or care-visitor management evidence (DL 12-15, 21)

A C3-to-C4 supported-housing HMO in a Coventry terrace was dismissed. The appellant had not shown the HMO would avoid a harmful concentration, or that parking and visitor demand could be absorbed on a full street. Under S4, the P3 and TR6(4) conflicts were described as "very substantial harm". That outweighed a supported-housing benefit whose need was not evidenced (DL ¶20-22).

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Appeal 6008160 · Ashfield · Appeal · 8 Sept 2026 · 42 homes

• TR6(4) fail visibility splays not based on speed survey; no turning heads on private drives; unassessed crossroads (DL 21-27)

An outline scheme for 42 homes, with layout fixed, on an infill wedge in Selston that includes part of a Local Wildlife Site. It was dismissed on almost every issue: cramped, parking-dominated layout, LWS loss with ecology evidence written for an 18-home scheme, unproven access visibility, no SuDS strategy, and no archaeological assessment. The site was within the settlement, so S4 applied. The inspector found that design, highway and biodiversity failures each meant "the proposal should be refused" (DL ¶49). Supply was 4.39 years, a shortfall the inspector called "not considerable".

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Appeal 6011059 · Sheffield · Appeal · 7 Sept 2026

• TR6(4) fail "significantly adverse effect upon highway safety" — no off-street parking; drop-off parking on congested Springfield Road with pavement parking; area-wide parking surplus not decisive; national 60-70% car mode share preferred to small parent survey (26%) (DL 11-20)

Conversion of a house into a 55-child nursery with no off-street parking. Dismissed under TR6 and the local plan because drop-off parking on a congested road would worsen pavement parking. The inspector preferred national car-mode-share data (60-70%) to a small parent survey (26%) (DL ¶14-15). On transition: the Framework is "of 'critical importance'" but "has not materially changed the national planning policy position" on this issue, so there was no consultation (DL ¶2).

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Appeal 6009886 · Croydon · Appeal · 4 Sept 2026 · 6 homes

• TR6(4) fail 1.5 x 1.5 m pedestrian splays need third-party land with no evidence of control; 34 two-way movements a day; shared surface overrun by vans with no pedestrian segregation (inclusive design) (DL 20-33, 42)

Flats and two backland houses (net +6) in South Croydon were dismissed. The design and density were acceptable. But the shared-surface layout gave no pedestrian segregation, and the access splays depended on unsecured third-party land. That was an unacceptable highway safety impact under TR6, a "should be refused" policy. Under S4(2)(c), the substantial housing benefit was "substantially outweighed" (DL ¶42).

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Appeal 6011471 · Croydon · Appeal · 3 Sept 2026 · 2 homes

• TR6(4) fail no signed car-free s106 in PTAL 5 area with saturated parking — congestion and highway harm (DL 11-13)

Upward and rear extension to create two flats above a pharmacy in the South Norwood CA. Dismissed on three grounds: CA appearance, the neighbour's light and outlook, and parking in the absence of a signed car-free obligation. The letter treats the 2026 Framework as materially the same as 2024 and uses 2024 language throughout: "less than substantial" and "significantly and demonstrably outweigh".

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W/26/01322/OUT · Wychavon · Council (delegated) · 2 Sept 2026 · 50 homes

• TR6(4) fail insufficient access information (closure of the existing access, fire appliances, visibility), so a severe impact is not ruled out

An outline for 50 homes (40% affordable) on fields next to Drakes Broughton, outside the development boundary. With a new local plan and a five-year supply, the officer held that S5(1)(j) was simply unavailable, treated the scheme under S5(4) "exceptional circumstances", and refused under delegated powers. The location was found "relatively sustainable" under TR3. The decisive harms were the S5 principle, countryside encroachment under DP3 and a string of technical gaps.

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041303 · Nuneaton and Bedworth · Council committee · 1 Sept 2026 · 621 homes

• TR6(4) fail members found that occupying 75 more homes before the Golf Drive/B4112/B4114 junction works were built "is likely to cause a severe adverse impact on the highway network"; officers and the County Highway Authority had found no severe impact

This was an application to vary a condition on a 621-home greenfield permission at Golf Drive, Nuneaton, so that 225 homes, not 150, could be occupied before the Lutterworth Road / Golf Drive junction was signalised. Officers relied on the County Highway Authority's acceptance of 225 and on TR6(4) to recommend approval. The committee refused against that recommendation, finding the extra 75 occupations "likely to cause a severe adverse impact on the highway network". Members made this TR6(4) finding against the technical advice, after asking for and hearing a presentation from County Highways at the meeting.

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Appeal 6002168 · Lancashire County Council · Appeal · 26 Aug 2026

• TR6(4) fail required 2.4 x 52 m visibility splays cross hedges on third-party land (owner objects); no Grampian prospect; narrow B-road with no footways means HGV passing and reversing conflicts, a "severe impact from a safety perspective" (DL ¶72-79, ¶85-105)

A 20.7 ha sand and gravel quarry near Preesall (Wyre), refused by Lancashire County Council and appealed to an 8-day inquiry. The inspector accepted a "critical" county landbank shortfall and found noise, dust and air quality acceptable with conditions. But the required access visibility splay depended on a hedge owned by an objector, and the narrow B-road could not take two-way HGV traffic safely. That was an unacceptable highway-safety impact, and TR6(4) says such proposals "should be refused". Appeal dismissed.

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Appeal 6007680 · Sandwell · Appeal · 21 Aug 2026

• TR6(4) fail parking under-provision and tight drop-off leading to indiscriminate on-street parking near a bend (DL 17-22)

A 10-child home nursery with a side extension was dismissed on three grounds: design (a terracing effect), noise to close neighbours, and drop-off parking on a busy road. The new Framework was "broadly consistent", so the parties were not consulted (DL ¶4). It is cited generically, without codes.

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Appeal 6010430 · Leicester · Appeal · 21 Aug 2026

• TR6(4) fail 4 spaces for repair, storage, collection and 5 staff; cars displaced onto narrow street with no turning head; decided under plan T07 (DL 13-21)

Retrospective change of use of a factory to an MOT and repair garage on a narrow residential-commercial street. Dismissed for "significant harm to highway safety through the parking and manoeuvring of cars on the public highway" (DL ¶21). The only Framework input was the conditions tests, which a vehicle management plan could not meet (DL ¶16). The parties were not consulted on the new Framework as the changes were "not material" (DL ¶5).

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Appeal 6003947 · Maidstone · Appeal · 20 Aug 2026 · 1 home

• TR6(4) fail intensified use of access onto 60 mph A274 with poor visibility in one direction (215 m the other); County Highways objection; previous donkey-sanctuary trip claims unevidenced. Letter relies on LPR policies only — TR6 code mapped by harvester (DL 8-11, 24)

One-family Gypsy pitch on a former donkey-sanctuary paddock beside the 60 mph A274 near Headcorn. The appeal was dismissed on highway safety alone. The access has poor visibility in one direction, and the appellant could not show that the previous use generated as much traffic. The council accepted every other LPRHOU8 criterion. The unmet need (considerable weight), the children's best interests (considerable), personal circumstances (moderate) and the PSED did not outweigh a "risk to life and limb", and temporary permission was also refused. No Framework policy is cited by code.

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Appeal 6010542 · Peterborough · Appeal · 20 Aug 2026

• TR6(4) fail sharp bend in access track means two vehicles (especially large) cannot pass near the junction; widening land outside red line and control not shown; Grampian condition not appropriate (DL 8-17)

An early (20 August 2026) decision under the new Framework, dismissing a farm-barn-to-B2/B8 conversion on highway safety at the access. The principle was accepted under S5(1)(c), but vehicles could not pass on the bend near the junction. The land needed to fix this was outside the red line, and not shown to be in the appellant's control. The concluding paragraph states the S5 test backwards.

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