Very special circumstances for small schemes

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

• 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)
• HO7 benefit 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)

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

• 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)
• HO7 benefit benefits of one dwelling modest; self-build unsecured - UU undated, unsigned and referring to two dwellings (DL 44, 47)

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 6010411 · Wirral · Appeal · 29 Sept 2026 · 3 homes

• GB6(2) fail modest visual and spatial openness harm; substantial weight at DL 15 but "significant weight" at DL 21; VSC not shown (DL 13-15, 21)
• HO7 benefit no evidence of a supply shortfall; dwelling types unknown at PIP stage (DL 16)

Permission in principle for up to three houses on paddocks in the Wirral Green Belt, beside a ribbon of houses on Telegraph Road near Caldy. Both parties accepted Caldy as a village and the scheme as limited, but the inspector found the ribbon visually separate from the village and the site bounded by houses on one side only, so it was not limited infilling in a village under GB7(1)(c). Inappropriate development with modest openness harm; limited housing weight; no VSC. Dismissed.

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

• GB6(2) fail inappropriate development plus spatial and visual loss of openness; VSC not shown (DL 21, 33)
• HO7 benefit up to four homes, "modest but meaningful" contribution; with economic, social and BNG benefits, substantial weight collectively (DL 30, 32)

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

• GB6(2) fail inappropriate; significant openness harm from building on an open field; benefits significant but VSC not shown (DL 25-26, 29, 35)
• HO7 benefit one dwelling against a significant shortfall (DL 32)

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 6011889 · Buckinghamshire · Appeal · 25 Sept 2026 · 1 home

• GB6(2) harm inappropriate development; domestic paraphernalia and parking would fail to preserve openness in spatial and visual terms; a 2024 inspector had called the effect of a similar curtilage limited but harmful (DL 8-12, 22-23)
• GB6(2) fail very special circumstances do not exist; one dwelling and biodiversity gain do not clearly outweigh the harm (DL 23)
• HO7 benefit one dwelling; contribution described as limited, but given substantial weight in light of the supply position and HO7 (DL 20, 23)

Conversion and extension of a stable to a one-bedroom dwelling in the Green Belt and the Chilterns National Landscape was dismissed, for the third time on this site. The building works fell within GB7(1)(b). The new garden and driveway did not: they were a change of use of open grassland to residential use, which no GB7 exception covers. That made the proposal inappropriate development, and one dwelling with a modest biodiversity gain did not amount to very special circumstances.

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

• GB6(2) harm inappropriate development plus "significant" harm to spatial and visual openness (DL 19-26)
• HO7 benefit one dwelling against 1.92-year supply (DL 34)

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 6008723 · Sefton · Appeal · 23 Sept 2026 · 4 homes

• GB6(2) fail inappropriate; visual and spatial openness harm; VSC not shown (DL 21-25, 30-31)
• HO7 benefit up to 4 homes, no 5YHLS, small site, good access to services and buses on Southport Road - moderate weight together (DL 26, 31)

Permission in principle for up to four bungalows on open former farmland at the edge of Lydiate was refused on appeal. The key finding was that Lydiate and Maghull form a single large built-up area, so the site strongly contributes to Green Belt purpose (a) and is not grey belt. The scheme was inappropriate development, harmed openness, and its moderate benefits did not clearly outweigh the harm.

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Appeal 6009281 · Buckinghamshire · Appeal · 23 Sept 2026 · 4 homes

• GB6(2) harm inappropriate development plus moderate spatial/visual openness harm (DL 10, 23, 25)
• HO7 benefit substantial in principle given 1.98-year supply but "only of moderate significance being for only 4 dwellings" (DL 24)

Outline scheme for up to four houses on a manège and garden land on the open side of Denham Lane, at the edge of Chalfont St Peter. It was dismissed. The site was not PDL as a whole under GB7(1)(e) and was held not to be grey belt, because it makes a strong contribution to purpose (a) on the council's draft 2026 Green Belt Assessment. So the development was inappropriate. Four homes against an acute shortfall, in an accessible location, did not clearly outweigh the Green Belt harm.

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

• GB6(2) harm inappropriate development plus localised spatial and visual openness harm (DL 21-24)
• HO7 benefit 1-3 dwellings, no certainty of 3 (DL 25)

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

• GB6(2) harm inappropriate plus clear openness harm (DL 13-14, 17)
• HO7 benefit substantial weight to homes in principle, moderate overall given scale; 2.17 yrs, HDT 38% (DL 16)

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

• 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)
• HO7 benefit small contribution; benefit moderated by lack of realistic alternatives to the car (DL 42); self-build not secured, so assessed as market housing (DL 49-50)

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

• 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

• GB6(2) fail inappropriate; significant/substantial openness harm and encroachment (purpose c); VSC not shown (DL 33, 44-46)
• HO7 benefit up to 5 homes against a significant shortfall, "small but meaningful" (DL 39)

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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Appeal 6011972 · Tandridge · Appeal · 18 Sept 2026 · 8 homes

• GB6(2) harm inappropriate plus spatial and visual openness harm; VSC not shown (DL 17-18)
• HO7 benefit substantial weight to homes given 1.92 yrs and HDT 38%, tempered by scale → moderate overall (DL 16)

Eight detached houses replacing equestrian buildings at Newchapel, the same area as Branford Wells (PINS-6010313). Dismissed. The site was agreed PDL, but eight two-storey houses would be taller, bulkier and more conspicuous than the low stables, so they would cause substantial harm to openness and fail GB7(1)(e). The site was also car-dependent under TR3. Moderate overall benefits against 1.92 years' supply did not clearly outweigh the harm. Grey belt (GB7(1)(g)) was not argued or considered.

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

• 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

• 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 6011330 · North East Derbyshire · Appeal · 15 Sept 2026 · 1 home

• GB6(2) harm harm to openness but below "substantial harm" threshold; minor encroachment (purpose c), potentially offset if polytunnel/hay store/glasshouse removed (DL 10, 13, 23)
• HO7 benefit self-build secured by UU, but little evidence on self-build supply; boost to housing; moderate not substantial weight (DL 19)

An outline scheme to replace stables with one self-build house in the North East Derbyshire Green Belt. The appeal was dismissed. The house sat on previously developed land, but its necessary garden took in paddock outside the stables' curtilage. So the site was not wholly PDL and the GB7(1)(e) exception failed. A garden is not a "material change in the use of land" under GB7(1)(f)(iii). Moderate self-build and ecology benefits did not clearly outweigh the Green Belt harm.

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Appeal 6010260 · Shropshire · Appeal · 11 Sept 2026 · 2 homes

• GB6(2) harm inappropriate; limited spatial loss of openness, very limited visual (DL 15-16)
• HO7 benefit 3.81-year supply; 1-2 dwellings "important but limited contribution"; self-build unsecured so no weight (DL 26-27)

PIP for one or two houses in the garden of a rural cottage near Albrighton, on land that once held four earlier cottages. It was dismissed. The former buildings had "blended into the landscape", so the site was not PDL under GB7(1)(e). No other exception was argued, so the scheme was inappropriate. Location on a narrow, unlit, national-speed-limit lane added spatial-strategy and car-dependence harm.

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Appeal 6005495 · Cheshire West and Chester · Appeal · 10 Sept 2026 · 6 homes

• GB6(2) harm inappropriate; net volume reduction limits spatial harm, but visual openness harm from a new house on rising, open land (DL 29-32, 35)
• HO7 benefit six dwellings with no five-year supply (shortfall unquantified) (DL 33, 36)

Conversion of a Grade II* farmstead's traditional buildings, plus one new detached house presented as a "replacement dwelling". The conversions were acceptable and a heritage benefit. The new house was inappropriate in the Green Belt: it was not a replacement, grey belt was not shown, and it was in any event unsustainably located under TR3. It harmed visual openness and the setting of the farmhouse, and it failed S5(1)(j) because it was not well-related to a settlement. Dismissed. The joint LBC appeal (PINS-6005497) was dismissed on the same heritage reasoning.

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Appeal 6007030 · Epping Forest · Appeal · 10 Sept 2026 · 1 home

• GB6(2) harm improved accommodation and short-term economic benefit not VSC; neutral on housing stock (DL 16-18)

Replacement of a single-storey 1960s bungalow with a two-storey self-build house that more than doubles floor area and volume. It was dismissed. The new building was "materially larger" under GB7(1)(b). Prior-approval and CLD fallbacks covered the ground-floor extensions, but not the added height. The first-floor bulk would cause substantial local harm to openness, so GB7(1)(e) also failed.

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

• GB6(2) fail inappropriate; demonstrable loss of openness from curtilages and paraphernalia; VSC not shown (DL 17-18, 37-38)
• HO7 benefit moderate weight at DL 33, "modest" weight in the VSC balance at DL 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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Appeal 6008062 · Calderdale · Appeal · 3 Sept 2026 · 1 home

• GB6(2) harm new building where none exists reduces spatial openness, and to lesser degree visual openness, despite screening (DL 7)

A temporary rural worker's dwelling on a smallholding in the Calderdale Green Belt. The appeal was dismissed. The dwelling fell within no GB7 exception. No essential need under HO11(1)(a) was shown. The site was isolated and car-dependent, and the access and drainage were unsatisfactory. Limited-weight benefits did not clearly outweigh the harm.

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