A permission in principle appeal for up to two self-build homes at Nash in Buckinghamshire has succeeded after the revised National Planning Policy Framework changed the planning balance. Inspector Richard Snow allowed the appeal on 21st October 2026, even though the site lies outside the village settlement boundary and near a conservation area.
Buckinghamshire Council had refused the application, but subsequently told the appeal Inspector that it would no longer defend its refusal reasons in light of the Framework issued on 17 August. The council acknowledged it could demonstrate only 3.73 years of deliverable housing land supply, well below the usual five-year requirement.
What stands out to me is not simply that two homes were allowed. The decision shows how the new national rules can alter the weight given to settlement boundaries and neighbourhood plans, while still requiring proper consideration of heritage, access and the next stage of an application.
Why permission in principle succeeded at Nash
The appeal concerns land known as The Green, beside Nichollswood Farm on Winslow Road. The application, PL/26/01162/PIP, proposed phased development of one or two self-build homes. Permission in principle is a two-stage process. The first establishes whether the location, land use and amount of development are acceptable. Detailed design and access follow through a separate technical details consent application.
That distinction matters. This permission in principle decision does not settle the positioning of individual buildings, access design, drainage, architectural treatment or other technical matters. Nor does it allow construction to begin without the next approval.
The Nash Neighbourhood Plan places the site beyond its settlement boundary. The Vale of Aylesbury Local Plan also takes a restrictive approach to growth outside established settlements, particularly in smaller villages. Previously those boundaries would have presented a substantial obstacle.
How the August 2026 NPPF changed the outcome
Inspector Snow applied the revised National Planning Policy Framework, including Policy S5, which identifies categories of development capable of being supported outside settlements. One route covers proposals meeting evidenced unmet needs that are physically well-related to an existing settlement and are of a scale local infrastructure can accommodate.
The inspector found the Nash site immediately adjoined existing development. Homes were present to the north and across Winslow Road, and a former stable building to the south was being converted. He considered that this setting made the land physically well-related to the village, notwithstanding its position beyond the mapped boundary.
Buckinghamshire’s 3.73-year housing land supply was decisive in establishing unmet need. The inspector also noted unmet demand for self-build plots. He considered that one or two additional homes would make a modest contribution, but one which attracted meaningful weight in the particular housing supply circumstances.
For this permission in principle appeal, Annex A of the revised Framework also mattered. It says materially inconsistent development plan policies should receive very limited weight, subject to defined exceptions. The inspector considered the restrictive local policies materially inconsistent with the new national decision-making provisions and reduced their weight accordingly.
This is not a general abolition of settlement boundaries. A proposal must meet the actual wording of Policy S5, including the nature of the need, physical relationship with the settlement and its scale. The judgment depends on the evidence for that site, rather than the mere fact that a boundary has been crossed.
Why the neighbourhood plan did not prevent approval
The Nash Neighbourhood Plan was made in 2022, bringing it within the five-year period relevant to Policy S6. However, the inspector explained that the plan contained no housing allocations. The particular protection in Policy S6 did not therefore defeat the favourable starting point arising from Policy S5.
A further issue was travel. Nash has few services, while its volunteer bus operates only on a limited basis. Residents will be likely to rely on cars for many journeys. Even so, the inspector accepted that the very small number of homes would not create significant additional movement and that the highway authority had no objection in principle.
That is another important limitation on the permission in principle result. The assessment was of the scale and location of this specific proposal. It does not establish that a much larger car-dependent scheme in the same village would pass the same transport tests.
Conservation area harm was weighed, not ignored
The site lies close to the Nash Conservation Area and Grade II listed Weir Cottage. Its openness contributes to the area’s rural setting. Inspector Snow accepted that development would cause some harm to the conservation area’s significance, even before the detailed appearance of the proposed houses had been decided.
He characterised that harm as low, partly because the site makes a limited contribution to views of the conservation area’s wider setting. He distinguished an unsuccessful 2023 appeal for three homes, which concerned a different site arrangement and greater proximity to the protected area.
The inspector also concluded that the intervening distance from Weir Cottage would preserve the setting of that listed building. He attached the required importance to the conservation area’s harm but found that the public benefits of the additional self-build homes outweighed it in the final planning balance.
Anyone reading the permission in principle outcome as a way to sidestep heritage protection would miss that distinction. The inspector recognised harm, weighed it against the identified benefits and reached a conclusion based on the scale and setting of the actual site.
What happens after permission in principle?
The applicant must still seek technical details consent before the development can proceed. Design, access, drainage, landscaping and any necessary mitigation will have to be properly addressed at that stage. The inspector also noted a proposed unilateral undertaking intended to secure delivery as self-build homes, which could be dealt with through the later stage.
Another procedural point is easy to miss. Standard planning conditions cannot simply be added to a grant of permission in principle. The decision resolves only the location, use and amount within the two-stage process. It should not be mistaken for a fully detailed planning permission.
For applicants, this permission in principle decision suggests a disciplined way of approaching small rural housing sites: establish the current housing supply position, show how the land relates physically to the settlement, explain the unmet need and confront heritage and transport concerns at the correct stage.
For planning authorities, it underlines the need to revisit refusal reasons when national policy changes during an appeal. That happened expressly here. A restriction in an adopted plan is still part of the statutory starting point, but its practical weight can change where it materially conflicts with the national decision-making policies now in force.
Decision and further reading
The decision relates to Planning Inspectorate appeal 6014063 and Buckinghamshire Council application PL/26/01162/PIP. Richard Snow allowed the appeal on 21st October 2026. The permission in principle relates to up to two self-build homes at The Green, Nash, not an unconditional right to construct completed houses.
Read the Planning Inspectorate appeal record, the national policy rules in S3 to S6, our guide to the revised NPPF and our earlier permission in principle appeal coverage.
The appeal decision is also available on AppealBase.
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