Failing the location limb makes it inappropriate

Appeal 6012115 · Dorset · Appeal · 2 Oct 2026 · 1 home

• 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)
• 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 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)

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.

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Appeal 6007668 · Newcastle-under-Lyme · Appeal · 29 Sept 2026 · 1 home

• GB7(1)(g)(iii) fail not in a sustainable location, so (g) fails whatever the position on (i) and (ii) (DL 24, 26)
• GB7(1)(g)(ii) not-engaged self-build shortfall evidence incomplete and no evidence of a five-year supply shortfall; not decided because (iii) fails (DL 25-26)
• GB6(2) fail inappropriate; footprint about three times the ruined brick building; significant loss of spatial and visual openness; encroachment (DL 28-30, 45-48)

One self-build plot in an open Green Belt field beyond the end of a rural lane near Newcastle-under-Lyme. The inspector tested the route in detail: the quiet no-through lane itself was walkable, but it ends at the A53 with no footway, and the only bus runs six times a day with no evenings or Sundays. That failed TR3 and GB7(1)(g)(iii), so the dwelling was inappropriate. With openness and character harm and modest benefits, VSC did not exist. Dismissed.

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Appeal 6006224 · East Hertfordshire · Appeal · 28 Sept 2026 · 4 homes

• AnnexB:grey-belt pass accepted by the Council; no contribution to purposes (a), (b) or (d) (DL 9)
• GB7(1)(g)(i) pass would not fundamentally undermine the purposes of the remaining Green Belt (DL 9)
• GB7(1)(g)(ii) pass no five-year supply, so evidenced unmet need (DL 9)
• GB7(1)(g)(iii) fail not a sustainable location, so the (g) exception fails and the scheme is inappropriate (DL 18)
• GB6(2) fail inappropriate development plus spatial and visual loss of openness; VSC not shown (DL 21, 33)

Permission in principle for up to four homes on open land in the Green Belt between Hertford and Ware. Grey belt and unmet need (3.4 to 3.7 years' supply) were accepted, but limb (iii) failed. The site is 0.72 km and 1.15 km from the edges of the two towns, with services further on, reached along a mostly single-track, unlit lane with no pavement. A Connectivity Tool score of 49, in the 90th percentile for its rural class, did not rescue it. As inappropriate development causing openness harm, substantial weight to housing did not clearly outweigh. Dismissed.

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Appeal 6010253 · Cheshire East · Appeal · 28 Sept 2026 · 1 home

• AnnexB:grey-belt pass undisputed; would not undermine the purposes of the remaining Green Belt (DL 10)
• GB7(1)(g)(i) pass undisputed (DL 10)
• GB7(1)(g)(ii) pass no five-year supply (3.3 years Council, 3.8 appellant) (DL 11, 32)
• GB7(1)(g)(iii) fail bus stop about 550 m in the village; route beyond the village edge unlit, no footways, national speed limit, incline, little refuge; supermarkets, GP and station (about 4.5 km) in Macclesfield; heavy car reliance notwithstanding small scale (DL 12-23)
• GB6(2) fail inappropriate; significant openness harm from building on an open field; benefits significant but VSC not shown (DL 25-26, 29, 35)

Permission in principle for one dwelling on a field beyond the edge of Langley, near Macclesfield, in the Green Belt. Grey belt and unmet need (3.3-year supply) were undisputed, but GB7(1)(g)(iii) failed: the walk to the village bus stop is on an unlit, footway-free lane at the national speed limit, and a Connectivity Tool score of 25 came with no useful detail. Small scale did not help. As inappropriate development with significant openness harm, significant housing weight did not clearly outweigh. Dismissed.

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

• AnnexB:grey-belt pass common ground (DL 10)
• GB7(1)(g)(i) pass common ground (DL 10)
• GB7(1)(g)(ii) pass common ground; 1.96 yrs supply, 3,466 shortfall (DL 10, 56)
• GB7(1)(g)(iii) fail Hatton Station has very few facilities; unlit Station Road without footways, narrow bridge; bus 1.1 km with twice-weekly service; station 350 m but not "well-connected" and only partly step-free; 28 homes are "significant movement" in context (DL 14-39)
• GB6(2) harm inappropriate; distinct spatial loss of openness on an undeveloped 1.17 ha site (DL 55)

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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Appeal 6008688 · Tandridge · Appeal · 23 Sept 2026 · 1 home

• AnnexB:grey-belt pass does not strongly contribute to (a), (b) or (d); limited encroachment does not preclude grey belt (DL 10)
• GB7(1)(g)(i) pass one dwelling would not fundamentally undermine purposes of remaining GB across plan area (DL 10)
• GB7(1)(g)(ii) pass 1.92-year supply = undisputed significant unmet need; no need to resolve self-build-specific need (DL 11)
• GB7(1)(g)(iii) fail 2 km to East Grinstead centre and station; lit continuous but narrow footway beside busy road; two infrequent bus routes, none on Sundays; "finely balanced" (DL 14-17)
• GB6(2) harm inappropriate development plus "significant" harm to spatial and visual openness (DL 19-26)

A single self-build house on grassed land beside Frith Manor, outside any settlement and about 2 km from East Grinstead. The Inspector accepted the land as grey belt and found unmet need established by the 1.92-year supply. However, the site failed GB7(1)(g)(iii)/TR3 even though a lit, continuous footway and bus stops were close by. The route and the service quality were not "genuinely attractive". Inappropriate development, significant openness harm and an unmitigated SPA effect were not clearly outweighed. The costs decision (separate PDF, `PINS-6008688-costs.pdf`) partly allowed costs against the Council for keeping a highway reason after the Highway Authority withdrew its objection.

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Appeal 6007428 · West Lancashire · Appeal · 22 Sept 2026 · 3 homes

• AnnexB:grey-belt pass confined parcel well beyond any large built-up area; purpose (c) irrelevant to grey belt; relevant question on (a) is a "strong" contribution to restricting sprawl of a large built-up area; Annex E guidance applied (DL 7-10)
• GB7(1)(g)(i) pass 1-3 dwellings would not fundamentally undermine purposes across the plan area (DL 20)
• GB7(1)(g)(ii) pass no five-year supply = unmet need (figure not stated) (DL 20)
• GB7(1)(g)(iii) fail 60 mph narrow hedged lane used by agricultural traffic, no footway between site and pedestrian network; some street lighting does not overcome this (DL 12-16, 19)
• GB7(1)(g)(iv) not-engaged not major (DL 20)
• GB6(2) harm inappropriate development plus localised spatial and visual openness harm (DL 21-24)

A PIP for up to three dwellings on a gap along a rural 60 mph lane in the West Lancashire Green Belt. The site was accepted as grey belt and unmet need was established. However, the lack of any footway between the site and the pedestrian network at Southport Road meant it failed GB7(1)(g)(iii)/TR3, even though the distance was short and some street lighting existed. As inappropriate development with openness harm, it was dismissed on the VSC balance. The S5(5) balance was expressly held not to be engaged.

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Appeal 6011736 · Tandridge · Appeal · 22 Sept 2026 · 7 homes

• GB7(1)(g)(i) pass undisputed (DL 11)
• GB7(1)(g)(ii) pass undisputed; 2.17-year supply (DL 11, 16)
• GB7(1)(g)(iii) fail 1 km / 15-minute walk to shop, school, village hall along mainly unlit 30-40 mph road with a section walking in the carriageway; hourly bus; Connectivity Tool score 52/100; no genuine choice of modes (DL 4-7, 11)
• GB6(2) harm inappropriate plus clear openness harm (DL 13-14, 17)

Seven houses on an open site off Copthorne Bank, about 1 km from Copthorne's shop, school and village hall. Grey belt, unmet need and the Golden Rules limb were undisputed. The appeal was **dismissed on GB7(1)(g)(iii)**. The walk is along a mainly unlit road with a stretch in the carriageway, so it is unattractive, and an hourly bus did not provide a "genuine choice" of modes. This was so despite a Connectivity Tool score of 52/100 and £250 travel vouchers. The scheme was therefore inappropriate, and moderate housing benefits did not clearly outweigh the harm.

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Appeal 6012481 · Sevenoaks · Appeal · 22 Sept 2026 · 6 homes

• AnnexB:grey-belt pass agreed between parties (DL 11)
• GB7(1)(g)(i) pass agreed (DL 12)
• GB7(1)(g)(ii) pass agreed; 2.96 yrs supply (DL 12, 42)
• GB7(1)(g)(iii) fail undisputed poor Connectivity Tool score; nearest settlement (Well Hill) has few services; no accessible public transport; no lighting, footways or cycle lanes (DL 13-17)
• GB6(2) harm substantial harm to spatial and visual openness from up to six dwellings (1,600 m3) on an open field; VSC not shown (DL 19-21, 51-52)

Outline proposal for up to six dwellings on an open field next to the M25, offset by removing nearby commercial buildings. Dismissed. Grey belt and unmet need were agreed, but the site failed GB7(1)(g)(iii): it scored poorly on the Connectivity Tool, had no public transport, and was reached by unlit rural roads without footways. The scheme was therefore inappropriate development, and no very special circumstances were shown. Missing protected-species surveys, M25 noise and poor access visibility added to the harm.

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Appeal 6003001 · Reigate and Banstead · Appeal · 21 Sept 2026 · 1 home

• AnnexB:grey-belt pass field beyond farmhouse curtilage is not PDL but does not perform strongly on (a), (b), (d); grey belt raised by the inspector, not the parties (DL 2, 5)
• GB7(1)(g)(ii) fail no details given of an evidenced unmet need for housing in the area (DL 7-8)
• GB7(1)(g)(iii) fail "not in a sustainable location", though one dwelling would not generate significant movement (DL 7)
• GB6(2) fail inappropriate; materially greater effect on openness, visual and spatial (DL 10, 21, 41)

Demolition of a curtilage-listed stables building (used as a dwelling) and a new single-storey dwelling in an adjoining open field in the Metropolitan Green Belt. The land was grey belt, but GB7(1)(g) failed for want of evidenced unmet need and a sustainable location. It was not a "replacement" under GB7(1)(b) because it moved to a different site. Openness, character and heritage harms were unjustified, and no VSC was shown. Dismissed.

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Appeal 6009966 · Tandridge · Appeal · 18 Sept 2026 · 5 homes

• AnnexB:grey-belt pass common ground, inspector agrees (DL 15)
• GB7(1)(g)(i) pass common ground, would not fundamentally undermine purposes of remaining GB (DL 16)
• GB7(1)(g)(ii) pass no 5YHLS, so unmet need (DL 17)
• GB7(1)(g)(iii) fail 800 m to settlement edge, services a similar distance beyond; 40/30 mph lanes, no continuous footways or lighting; hail-and-ride bus unevidenced (DL 21-23, 28)
• GB6(2) fail inappropriate; significant/substantial openness harm and encroachment (purpose c); VSC not shown (DL 33, 44-46)

Permission in principle for up to 5 dwellings on a paddock in the Green Belt, about 800 m outside South Nutfield. Grey belt, GB7(1)(g)(i) and (ii) were all common ground. The appeal failed on limb (iii) sustainable location, because the walking and cycling routes are unlit lanes with no continuous footway and the bus evidence was thin. As inappropriate development, substantial weight to the housing benefit did not clearly outweigh the Green Belt, openness, character and travel harms.

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W/26/01639/PIP · Wychavon · Council (delegated) · 18 Sept 2026 · 5 homes

• GB7(1)(g)(i) pass grey belt accepted, following the Inspector's finding on the larger site
• GB7(1)(g)(ii) fail five-year supply now demonstrated after SWDPR adoption (the appeal had found 1.1 years); HDT 133%
• GB7(1)(g)(iii) fail Connectivity Tool score 23; limited bus service; narrow, mostly unlit pedestrian routes; residents would rely on the car
• GB6(2) fail inappropriate development; material harm to openness; very special circumstances not shown

A permission-in-principle bid for up to five homes on paddock land at New End, Astwood Bank, in the Green Belt. It followed an appeal refusal of nine homes on a larger site that included this land. The officer accepted the Inspector's grey belt finding but refused on two grounds. GB7(1)(g)(ii) now fails because adopting the SWDPR restored a five-year supply. GB7(1)(g)(iii) fails because the location is car-dependent, with a Connectivity Tool score of 23 and narrow, unlit walking routes. This is one of the clearest early examples of the grey belt route failing on the need and location limbs even though grey belt status is accepted.

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Appeal 6008528 · Mole Valley · Appeal · 16 Sept 2026 · 1 home

• GB7(1)(g)(i) pass established residential curtilage outside any built-up area could be PDL; site does not strongly contribute to purposes (DL 9)
• GB7(1)(g)(ii) pass Council now has a 5YHLS but HDT is below 75%, so footnote 41 unmet need is established (DL 10)
• GB7(1)(g)(iii) fail no footways or lighting on Beare Green Road; bus not shown to stop nearby; well separated from village and Holmwood station; Connectivity Tool score 25/100 (DL 11-13)
• GB6(2) harm inappropriate development; openness harm given considerable weight; some encroachment (DL 17-19, 31)

The appellant sought to keep an original house, which was due to be demolished under a 2017 replacement-dwelling permission, as an extra dwelling in the Mole Valley Green Belt. Dismissed. Grey belt and unmet need were accepted: the Council has a five-year supply, but its HDT is below 75%. Limb (iii) sustainable location failed on an unlit lane with no footways, remote from the village and station, with a Connectivity Tool score of 25/100. A new driveway through ancient woodland separately failed N6.

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Appeal 6005433 · Mole Valley · Appeal · 9 Sept 2026

• AnnexB:grey-belt pass Council accepted grey belt; GB7(1)(g)(i) met and (iv) n/a (DL 9-10)
• GB7(1)(g)(ii) fail no substantive evidence of an unmet need for storage containers (DL 11)
• GB7(1)(g)(iii) fail rural, relatively isolated, no nearby regular public transport, so users heavily car-reliant (DL 12-13)
• GB6(2) fail inappropriate; moderate openness harm, spatial and visual; VSC not shown (DL 16-18, 35-37)

Retention of two storage containers on grey belt land at Headley. This is a non-housing grey belt case: it failed GB7(1)(g)(ii) because there was no evidenced need for this type of development, and (iii) because the location is car-dependent. As inappropriate development causing moderate openness harm, AGLV character harm and low-level harm to a Grade II setting, it was dismissed with no VSC.

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Appeal 6010313 · Tandridge · Appeal · 4 Sept 2026 · 5 homes

• AnnexB:grey-belt pass undisputed; does not strongly contribute to (a), (b), (d) (DL 10)
• GB7(1)(g)(ii) pass 1.97-year supply, shortfall over 3,000 homes = evidenced unmet need (DL 11)
• GB7(1)(g)(iii) fail five dwellings in an area with very few homes = significant movement "in this context"; rural, away from settlements, facilities and buses; 40 mph lane without footways or lighting (DL 12-14)
• GB6(2) fail inappropriate; demonstrable loss of openness from curtilages and paraphernalia; VSC not shown (DL 17-18, 37-38)

Conversion of a barn complex to five dwellings in the Tandridge Green Belt, where supply is 1.97 years. Grey belt and unmet need were accepted, but GB7(1)(g)(iii) failed: the site is on a 40 mph lane with no footways or lighting, away from settlements and buses. As inappropriate development causing openness, heritage (Grade II setting), character and amenity harm, it did not show VSC even with an acute shortfall. Dismissed.

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25/01429/FUL · Bromsgrove · Council (delegated) · 21 Aug 2026 · 1 home

• GB7(1)(g)(iii) fail rural site; first school 180 m away but no other facilities; bus one each way on Tuesdays and Fridays only
• GB6(2) pass very special circumstances shown by the Class Q fallback plus a reduction of 125.4 m³ in volume and 19.1 m² in footprint compared with the existing buildings

A new dwelling in place of a barn (with Class Q consent) and stables in the Green Belt at Dodford. It fails GB7(1)(b), because a replacement must be for the same use. It fails GB7(1)(e), because agricultural land is not PDL. It fails GB7(1)(g)(iii): with a bus on two days a week, the site is not in a sustainable location. It was therefore inappropriate development. Very special circumstances were found in the Class Q fallback combined with a net reduction in built volume, and the application was approved four days into the new Framework.

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