An Alfold PIP appeal has secured permission in principle for four to five homes after Inspector C Walker gave substantial weight to Waverley’s acute housing land shortfall. The appeal was allowed on 6th October 2026.
The site lies outside Alfold’s settlement boundary and the Inspector accepted that the development would cause some harm to the character and appearance of the countryside. But Waverley could demonstrate only 1.28 years of deliverable housing land, which the decision described as a chronic undersupply.
I would keep the two stages clear: permission in principle settles whether the location, use and number of homes are acceptable, while technical details still need approval before building can begin. The housing shortage brought the proposal within the August 2026 National Planning Policy Framework route for development outside settlements that addresses an evidenced unmet need. The Inspector found the limited localised harm did not substantially outweigh the housing and wider benefits.
Why the Alfold PIP appeal was allowed
Appeal 6011178 concerned land at Alfold Farm, Loxwood Road, where Rowe Property Investments sought permission in principle for between four and five dwellings.
At the PIP stage the considerations are limited to location, land use and amount of development. Detailed design, landscaping, drainage, access detail and other technical matters fall to a later technical details consent application.
There was no dispute over the proposed residential land use or the broad location. The main issue was whether the amount of development was appropriate, particularly in terms of character and appearance.
The appeal decision is hosted locally by Planning Geek. The case can also be checked on the Planning Inspectorate appeal service.
A mixed edge-of-settlement context
The site at the centre of the Alfold PIP appeal is outside the defined settlement boundary and outside the Green Belt. It was last used as a builder’s storage yard and is reached from a shared drive serving the Alfold Business Centre and nearby homes.
Much of the wider area is low-density and loose-knit, but the immediate surroundings are more mixed. The business centre, its car park and other substantial buildings create a more urbanised character along the access.
The appeal land itself is enclosed by high fencing and was found to make only a limited contribution to the wider countryside. In the Alfold PIP appeal, the Inspector considered that it related more closely to the existing built form than to the open countryside beyond.
Five homes were still capable of being ‘small scale’
The neighbourhood plan supports small-scale housing subject to criteria, but does not impose a fixed numerical definition of small scale.
In the Alfold PIP appeal, the Inspector noted that major development is defined as 10 or more dwellings. On that basis, a proposal for up to five homes could still fall within a small-scale category.
There is also an extant PIP on adjoining land for up to four dwellings. Taken together, the two permissions could create a cluster of up to nine homes.
That cumulative figure was important to the character assessment, but it did not automatically make the amount unacceptable.
Density left room for a workable technical scheme
Because this was a permission in principle appeal, there was no final layout to assess. Even at the maximum five dwellings, however, the density would remain below 10 homes per hectare.
In the Alfold PIP appeal, the Inspector considered that low enough to leave meaningful scope at technical details consent stage for a suitable layout, landscaping and design response.
The combined cluster with the adjoining PIP would be more intensive than the prevailing loose-knit pattern, but the Inspector in the Alfold PIP appeal described the overall quantum as relatively modest.
The resulting character harm was therefore real but limited.
Development plan conflict remained
The appeal was not allowed because the proposal suddenly became fully compliant with local policy.
The Inspector found conflict with policies intended to protect countryside character, and was not satisfied that the site could clearly be treated as previously developed land for the purposes of the neighbourhood plan.
That was enough to bring the scheme into conflict with the development plan when read as a whole.
The question then became whether material considerations justified a different outcome.
A 1.28-year supply carried substantial weight
The decisive material consideration was Waverley’s housing land supply.
The council could demonstrate only 1.28 years of deliverable housing land. The Inspector described that as a chronic undersupply in a borough where the need for additional housing was urgent and pressing.
Under Policy S5 of the August 2026 Framework, development outside settlements can be approved where it addresses an evidenced unmet need, provided it is physically well related to an existing settlement and can be accommodated at an appropriate scale with available infrastructure.
The site directly adjoins existing development and the Inspector found that four to five homes could be satisfactorily accommodated.
The housing contribution itself was modest in numerical terms, but national policy required substantial weight to be given to meeting unmet housing needs.
The planning balance favoured permission
In addition to the housing supply contribution, the Inspector gave moderate weight to other social, environmental and economic benefits, including support for a rural community, use of a small site and construction employment.
Against that stood the limited countryside character harm.
The Framework test was not whether there was any adverse effect. It was whether the benefits would be substantially outweighed by the adverse effects when assessed against the national decision-making policies.
The Inspector found they would not be.
Permission in principle was therefore granted despite development plan conflict.
What remains for the technical details stage
A PIP is not a full planning permission on its own. The developer still needs technical details consent before the development can proceed.
Issues such as final layout, design, landscaping, access details and infrastructure will be tested at that later stage.
The Inspector also noted that concerns raised by residents about traffic, wildlife, infrastructure and living conditions were largely matters for technical details consent rather than the first-stage PIP decision.
Planning Geek’s permission in principle guide explains the two-stage process and the deliberately limited scope of the first decision.
Why the new NPPF matters
The appeal is another practical example of how the August 2026 Framework is changing housing decisions outside settlement boundaries.
Rather than treating countryside location as an automatic endpoint, Policy S5 directs decision-makers to consider whether the proposal falls within one of the identified forms of development and then apply the benefits-versus-adverse-effects test.
That does not remove local character policies. The Inspector still found conflict with them and attached weight to the harm.
But where housing supply is exceptionally weak, the national policy balance can become decisive.
Planning Geek view
The striking figure is 1.28 years. At that level of supply, even a small site can attract substantial policy weight because the national framework is asking decision-makers to respond to the unmet need, not simply count the number of units in isolation.
The decision is also a reminder not to overload a PIP application with matters that properly belong at technical details stage. The first-stage question remains location, land use and amount.
For landowners, that can make PIP a useful route where the principle is the real battleground and the site is capable of accommodating a detailed scheme later.
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