A traveller site appeal near North Heath in West Sussex has succeeded, with a Planning Inspector granting permission for two residential static caravans at Staalcot Farm despite countryside impacts and earlier unauthorised development. Inspector D Szymanski allowed appeal 6008830 against Horsham District Council on 29 October 2026 after a hearing and site visit on 12 August.
The scheme includes two pitches, hardstanding, landscaping and utility buildings. It followed earlier attempts to develop the site, including a larger scheme and enforcement action. The Inspector accepted that the proposal would harm the rural landscape and that development had intentionally gone ahead without permission. Neither finding was dismissed as unimportant.
The traveller site appeal is particularly relevant under England’s August 2026 National Planning Policy Framework. The Inspector gave substantial weight to an unmet need for Traveller pitches, the children’s welfare and the families’ circumstances, ultimately finding that the scheme’s benefits were not substantially outweighed by its adverse effects. The permission comes with detailed restrictions, including a family-specific occupation condition.
Why the traveller site appeal succeeded
The traveller site appeal concerned Horsham application DC/25/1364, which had been refused by the council. The proposal was to use land at Staalcot Farm, Stall House Lane, for the stationing of caravans for residential purposes, with associated surfacing, landscaping and utility buildings. The Inspector granted permission for two static caravans, subject to 16 conditions.
The starting point was not that any rural caravan site should automatically receive approval. Inspector Szymanski found conflict with the development plan considered as a whole, including the countryside strategy. The decision instead turned on whether more recent national policy and the particular evidence amounted to material considerations sufficient to justify permission despite that conflict.
Planning Geek’s guide to Gypsy and Traveller site planning permission explains how pitch need, location, national policy and site-specific circumstances are assessed. In this case, the decision expressly applied policies HO7, HO12, S3 and S5 in the August 2026 Framework, rather than treating the former stand-alone Traveller Sites policy as current.
Horsham’s pitch shortfall mattered
At the hearing the council confirmed that its five-year supply assessment required 61 deliverable pitches for 2023 to 2028. Although the emerging local plan identified sites and allocations, the Inspector was not persuaded that everything relied upon could safely be treated as deliverable. Even counting those proposals, he identified a remaining shortfall of around 14 pitches.
The traveller site appeal therefore involved more than a general assertion that Traveller accommodation was desirable. The Inspector found a significant unmet need. Policy HO7 gave substantial weight to supplying homes that addressed evidenced accommodation needs, while policy HO12 required him to consider the suitability of locations together with the need and personal circumstances.
Under policy S5, certain development meeting an evidenced unmet Traveller accommodation need may be approved outside settlements where it satisfies HO12, unless its benefits are substantially outweighed by adverse effects under the relevant national decision-making policies. That is a qualified planning balance, not a blanket exemption from countryside, environmental or enforcement controls.
Unauthorised work carried substantial weight against permission
The land was not a clean, undeveloped site awaiting a first application. The Inspector referred to previous refusals, a Temporary Stop Notice and an enforcement notice. Some unauthorised work had been removed, and the earlier appeal concerned a larger proposal. The new scheme was smaller, but the planning history remained a serious consideration.
Policy DM8 of the 2026 Framework requires substantial weight to be given where unauthorised development was intentional. The Inspector concluded that this was intentional unauthorised development, noting that the works had begun despite the planning history. He also recorded allegations from interested parties, which the appellant did not dispute, concerning damage, trespass, tree works and obstruction.
The traveller site appeal should not be read as suggesting that retrospective permission erases the breach. The Inspector gave the intentional development substantial adverse weight and considered its possible ecological consequences. Our guide to retrospective planning permission explains why an after-the-event application is still judged against planning policy and evidence.
The countryside harm was real but limited
The site sits outside any defined settlement, beside a narrow rural lane near North Heath. The Inspector found that hardstanding, caravans, vehicles and the associated works would urbanise part of a pastoral landscape. Views from some nearby fields and a public right of way would be affected. He nevertheless considered the two-pitch arrangement modest in scale, with landscaping capable of partly reducing its visibility.
Horsham’s local policy specifically addressing Traveller pitches used an unacceptable-harm threshold. The Inspector did not find that threshold met, although he identified conflict with other countryside and design policies. He also found that walking, cycling and public transport access to services would be poor, while road journeys would be relatively short and the highway authority had not raised a significant safety objection.
Those distinctions matter. The traveller site appeal is an example of a fact-specific planning balance, not a general precedent that development in the countryside can be allowed because another site nearby received permission. The Inspector expressly addressed differences from the nearby Peacocks Paddock approval and treated the smaller scale of this scheme as material.
Children, healthcare and family life
One pitch was intended for parents and their four children, the other for a family member. Evidence before the hearing described the occupiers’ need for a stable base, continuity in schooling, access to healthcare and mutual family support. The council and appellant agreed that no alternative authorised pitches were available locally.
The Inspector considered Article 8 rights, the children’s best interests and the public sector equality duty, alongside the planning harms. He found that a move, potentially back to roadside living, could damage access to education and healthcare. These were not automatic grounds for permission, but in this traveller site appeal they received substantial weight because they were supported by the particular evidence.
The conclusion also reflected the difference between the present two-pitch proposal and a larger scheme considered previously. The Inspector did not treat neighbour concerns as irrelevant. Rather, he concluded that an authorised, landscaped site could support integration with the local community and that its relatively modest effects should be weighed against the families’ circumstances.
Biodiversity harm was not ignored
The Inspector examined the site’s previous habitat loss and the possibility of effects on protected species, including great crested newts and reptiles. He was not satisfied that past unauthorised works had been shown to avoid significant biodiversity harm. Remaining works would be controlled through precautionary methods and conditions, with external lighting and ecological compensation also addressed.
An important distinction in the traveller site appeal is that, because the application was retrospective under section 73A of the Town and Country Planning Act 1990, the Inspector considered the statutory 10% biodiversity net gain requirement did not apply. The appellant nevertheless proposed measures it suggested could deliver a gain of around 20%. That figure was a possibility put forward in evidence, not an already verified outcome.
The decision also considered water neutrality and designated habitats. Conditions require controls on water consumption and detailed drainage, ecological and landscaping schemes. The fact that harms might be compensated for in future did not mean they disappeared from the Inspector’s assessment of the earlier unauthorised works.
Permission is permanent but tightly conditioned
Inspector Szymanski imposed 16 conditions. The site is limited to two static caravans or mobile homes and no more than two touring caravans, with touring caravans not permitted to be occupied while stationed there. Industrial, commercial and business activity is prohibited, and vehicles over 3.5 tonnes may not be stationed, parked or stored on the site. Some otherwise permitted boundary works require express consent.
Crucially, the occupation condition names the particular families and their resident dependants. If their occupation ends, the permitted use must cease and the site must be cleared and restored within 12 months. The Inspector rejected a temporary permission, but the personal occupancy restriction means this is not an unrestricted general-purpose caravan site consent.
The traveller site appeal demonstrates why the actual decision and conditions must be read together. The Inspector’s overall conclusion was that the benefits of the proposal are not substantially outweighed by its adverse effects.
That wording is from his decision, published by the Planning Inspectorate under the Open Government Licence v3.0.
What applicants and councils can learn
For applicants, the stronger evidence was not the simple presence of caravans or a promise of landscaping. It was the demonstrated need for pitches, the absence of available alternatives, specific family circumstances and a smaller, more controlled scheme than before. Previous unauthorised development was a substantial obstacle and could have led to a different result had the balance been less compelling.
For councils and neighbours, this traveller site appeal shows the importance of identifying the actual conflict under national and local policies rather than relying on a general objection to countryside sites. Documented landscape and ecological harms were weighed seriously. The updated Framework’s approach to need outside settlements, together with deliverability evidence and enforceable conditions, ultimately proved decisive.
The official Planning Inspectorate appeal record is reference 6008830, decided on 29 October 2026 following the August hearing. The appeal decision is also available on AppealBase. The full decision should be read before seeking to apply its reasoning to another site.
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