Undeveloped land at Heald Green has won permission in principle for between one and six homes after an Inspector found that it qualified as grey belt.
Appeal 6005877, concerning land off Bolshaw Farm Lane, was allowed on 11th September 2026. Inspector Laura Bartle gave very limited weight to the conflict with Cheshire East’s older Green Belt policy because it did not reflect the current national policy exceptions.
There are two important qualifications. This is permission in principle, not permission to start building, and the decision covers only the part of the application site within Cheshire East.
Undeveloped land can still be grey belt
The site lies within the Green Belt, between the built-up edge of Heald Green and farm redevelopment off Bolshaw Farm Lane. Larger agricultural structures lie beyond the field immediately to the west.
The Inspector found that development and infrastructure physically enclosed most of the site’s boundaries. Up to six homes would not materially alter that visual and functional containment.
Substantial separation would remain between Heald Green and Handforth. Intervening open land and the Manchester Airport Relief Road would continue to provide a clear physical break between them.
Those findings addressed Green Belt purposes concerning unrestricted sprawl and neighbouring towns merging. There was also no evidence of a contribution to the setting or special character of a historic town.
The Inspector therefore found that the land did not strongly contribute to purposes (a), (b) or (d) and met the grey-belt definition. The fact that the site was undeveloped did not prevent that conclusion.
Our Green Belt and grey belt guide explains why grey belt is not simply another name for brownfield land. The current definition can cover previously developed land or other land, but in either case the relevant Green Belt-purpose test must be met.
Why the older local policy carried less weight
Policy PG3 of the Cheshire East Local Plan Strategy restricts development in the Green Belt. Its listed exceptions did not cover this proposal.
However, the Inspector found that PG3 predated the revised national Green Belt provisions and did not reflect grey belt or the exceptions now contained in NPPF policy GB7. She therefore gave very limited weight to the policy conflict under Annex A of the Framework.
That does not mean PG3 ceased to be part of the development plan, or that every older Green Belt policy can be ignored.
The August 2026 NPPF makes the distinction expressly. Annex A addresses policies, or parts of policies, materially inconsistent with national decision-making policy, subject to its stated exception. Other development plan policies should not receive reduced weight simply because they were adopted before the Framework was published.
The practitioner lesson is to identify the actual inconsistency. Age alone is not the argument. This appeal concerned a policy conflict which did not reflect the current national route available to this particular proposal.
Grey belt was only the first part of the assessment
Policy GB7(1)(g) also required consideration of the remaining Green Belt across the plan area, evidenced unmet need and whether the location was sustainable. Applicable major housing proposals must also satisfy the relevant GB8 requirements.
Both main parties agreed that developing this limited, well-contained site would not fundamentally undermine the purposes of the remaining Green Belt across the plan area.
The council’s most recent evidence showed a shortfall in deliverable housing sites. The Inspector accepted that this established an evidenced unmet need for housing, with the proposal making a modest contribution towards meeting it.
That is consistent with the current national policy treatment of a lack of a five-year housing land supply, including the relevant buffer. The decision does not give a numerical supply figure for Cheshire East, and the 3.81-year figure in the Albrighton appeal is not a figure for this council.
The Inspector expressly found that the major-development provisions of GB8 did not apply in this case. Having found the relevant requirements satisfied, she concluded that the development was not inappropriate and did not require very special circumstances.
The connection to Heald Green mattered
The site adjoins the built-up area and benefits from good pedestrian infrastructure connecting it to some everyday services and facilities.
Not every facility was within the distances mentioned in the supporting text to local policy SD2. Nevertheless, the Inspector found that residents would have reasonable access to shops, education, public transport and other services.
Taking the evidence together, and particularly the sustainable-location requirements referenced in national policy TR3, she found the location sustainable.
This was a judgment about the actual connections and facilities available. It was not a conclusion that all land beside a settlement is automatically a sustainable location.
One red line, but two council areas
A very small part of the red-line site extended into Stockport. However, the application had been submitted only to Cheshire East, and there was no corresponding application to Stockport Metropolitan Borough Council.
The Inspector explained that the appeal could only determine the land within Cheshire East, being the land to which that council’s decision related. Her permission in principle was therefore expressly limited to that administrative area.
The practical lesson is to check administrative boundaries when preparing an application. Including land inside a red line does not extend a council’s decision-making jurisdiction into its neighbour’s area.
Permission in principle is not the final building approval
Mr Aiman Salama’s application, 25/0958/PIP, sought up to six dwellings. The Inspector expressed the permitted amount as a minimum of one and a maximum of six.
The permission in principle route deals first with location, land use and amount. The submitted layout was treated as illustrative, not as an approved detailed design.
Technical details consent is still required. The decision does not remove the need to address the detailed proposals and relevant matters such as drainage, trees, ecology, construction arrangements and access at the appropriate stage.
Planning Geek analysis: a different question from Albrighton
Compare this with the same-day Albrighton appeal concerning former cottages. There, historic buildings were accepted, but their remains had blended into the landscape and the PDL exception was unavailable.
Heald Green was undeveloped but qualified as grey belt. Albrighton had a history of development but failed the PDL test. The different outcomes underline why previously developed land and grey belt must be assessed separately.
For advisers, the other useful point is the weight given to an identified policy conflict. The decision applies the 2026 NPPF to the site’s particular circumstances; it is not a general licence to disregard adopted Green Belt policy.
Read the decision
Official appeal decision 6005877, issued on 11th September 2026. Paragraphs 7–8 explain the cross-boundary issue, 11–22 address Green Belt policy, and 26–28 set out the planning balance.
Our planning appeals guide explains the wider process.
Report prepared: 13th September 2026
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