Three agricultural barn appeals at Thrale Farm in Harrow have been dismissed after an Inspector found insufficient evidence of an agricultural trade or business and of a genuine need for the proposed buildings. The combined decision and three refusals of costs were issued on 6 November 2026.
Inspector M Cryan considered three separate applications for barns of 1,000, 1,500 and 1,475 square metres on a 5.5-hectare field near Oxhey Lane. Each proposal relied on Schedule 2, Part 6, Class A of the General Permitted Development Order. The Inspector accepted important points about size and associated works, yet found that the core qualifying tests were not met.
These agricultural barn appeals concern different application references from an earlier dismissal at the same farm on 27 October 2026. Together they expose an important distinction: reaching the five-hectare threshold and staying within a building-area limit do not, by themselves, establish a permitted development right.
Why the agricultural barn appeals failed
The land at Thrale Farm comprised a grassland field enclosed by hedgerows, with sports pitches and other similar fields nearby. The applicant reported an agricultural unit of 55,000 square metres, meeting the Class A minimum of five hectares. The disputed questions were whether the land was used for agriculture as a trade or business, and whether the proposed barns were reasonably necessary for that agriculture within the unit.
A Department for Environment, Food and Rural Affairs letter confirmed that the field was included in a Countryside Stewardship arrangement and recognised agricultural management. But Inspector Cryan considered that the letter did not establish commercial trade on the field for Part 6 purposes. The Inspector also examined photographs submitted during the appeal showing recent harvesting, which were admitted after the normal deadline with the council given a chance to respond.
The appellant supplied an invoice for 200 bales of hay of 20 kilograms each. The Inspector said this recorded a transaction but did not connect the sale to production on Thrale Farm, and it showed only one sale. A personal statement about hay production and sales did not provide the missing underlying commercial evidence. The Inspector concluded that it has not been substantively demonstrated that the appeal site is in agricultural use
in the specific Part 6 sense.
Our Class A agricultural buildings guidance explains why agricultural land must already be in use for agriculture for a trade or business. A countryside stewardship arrangement, visible harvesting or a business invoice can be relevant evidence, but its significance depends on whether it establishes the statutory requirements for the actual unit.
These agricultural barn appeals therefore do not establish that grass harvesting is incapable of qualifying as agriculture. They show why the evidence must connect agricultural activity, commercial trade and the particular land for which development is proposed.
Why the three proposed barns were considered too large
The smallest barn would have covered 1,000 square metres with seven-metre eaves. The other two would have covered 1,475 and 1,500 square metres with eight-metre eaves. The applicant said the buildings were needed for hay and straw storage, ventilation, machinery shelter and safe circulation, with space for tractors, balers and a telehandler.
Inspector Cryan accepted that those functions can be associated with agriculture. Nevertheless, the Inspector found no sufficiently detailed estimate of the hay output from this relatively small field or explanation showing why any of the three buildings was proportionate to its agricultural activity. The decision noted that the buildings and hardstanding themselves would reduce the area from which a crop could be produced.
The harvesting photographs showed several tractors and balers among other equipment, but the evidence did not identify what would be stored permanently on the site and why. The holding was also described in the stewardship correspondence as being managed at low intensity. The Inspector considered that the proposed capacity went well beyond equipment and hay storage needed to manage this field.
The appellant carried on an agricultural contracting business, which might require storage of equipment used on other farms. That was not enough to establish a permitted development right for this land. The Inspector drew a distinction between an operating base for work elsewhere and a building reasonably necessary for agriculture within the identified unit.
The Alkham Part 6 appeal provides a useful contrast. There, evidence of an emerging sheep enterprise and its realistic requirements supported a different outcome. These agricultural barn appeals are about the shortcomings of the specific justification before the Inspector, not an absolute ban on ambitious farm buildings.
Where the applicant succeeded on other Part 6 points
Harrow Council had suggested that development at nearby Oli Farm should be taken into account when assessing the cumulative ground-area limit. The appellant described Thrale Farm as a separate unit, though some earlier planning statements also referred to a wider agricultural holding. Inspector Cryan assessed the appeals on the unit actually put forward and did not find a breach of the relevant 1,500-square-metre limitation.
The calculation in Part 6 is not simply the area of the proposed barn. It can include other specified development within the same unit during the preceding two years and within 90 metres of the proposal. On the evidence in these appeals, none of the proposed barns was disqualified by that restriction.
Questions were also raised about excavations for the first two schemes. The land had a gentle slope, and the Inspector considered the shallow foundations described in the evidence to fall within the scope of the right. For the third proposal, the council pointed to a track and bridge affected by separate enforcement action. Since no new access works formed part of the application, the Inspector did not treat access as a Part 6 failure in this decision.
Those favourable findings did not rescue the proposals. The agricultural barn appeals were dismissed because the applicant had not proved the qualifying trade-or-business use or the necessity of the three buildings. The Inspector therefore did not proceed to a separate decision about the acceptability of the siting, design and appearance through prior approval.
This distinction matters for agricultural agents: a positive finding on dimensions, excavation or access cannot overcome a failure to establish that the proposed development falls within the permitted development class in the first place.
Three costs applications fail as well
The appellant sought costs against Harrow in all three appeals, alleging factual errors, incorrect interpretation of the GPDO, insufficient engagement and a failure to substantiate parts of the council’s reasoning. The separate costs decision examined the claims individually and refused each one.
Inspector Cryan acknowledged that the council’s approach to excavation and one of its separation arguments might arguably have been unreasonable. But an award of costs also requires the conduct to have caused unnecessary or wasted expense. The Inspector considered that the core refusals remained justified and that the applicant was likely to have appealed in any event.
The three applications followed other attempts at the same site. An earlier Class A appeal, reference 6006380, had been dismissed on 27 October. Planning Geek reported that earlier decision, which is distinct from the three applications decided on 6 November.
These agricultural barn appeals also demonstrate why winning an individual point in a planning dispute does not establish entitlement to costs. The alleged unreasonable behaviour must actually have caused expense that would otherwise have been avoided.
Practical lessons for agricultural applicants
Anyone pursuing agricultural permitted development should start by defining the relevant unit, its existing agricultural activity and the evidence of trade or business conducted there. Crop and sales records, invoices linked to production, machinery schedules and farm management plans may help, but a business operating across several sites must distinguish the activities at each one.
Justification for the building should follow the evidence rather than precede it. Expected crop yields, storage volumes, machinery size, seasonal operations and internal circulation should explain why the particular footprint and height are needed. The agricultural unit guidance helps identify the land against which that need must be assessed.
Taken together, the agricultural barn appeals show that a large farm building cannot be justified only by staying within the maximum permitted size. The scale must be reasonably necessary for agriculture within the qualifying unit, and the evidence must demonstrate that fact.
The three dismissed appeals were 6003732, 6004775 and 6008452, all determined by Inspector M Cryan on 6 November 2026. The combined appeal decision and separate costs decision are also available on AppealBase.
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