Vale housing supply has been assessed at approximately 4.9 years after an Inspector removed 474 dwellings from the council’s claimed pipeline. But the same decision rejected the appellant’s additional blanket allowance for permissions that might lapse or fail to be implemented.
The inquiry concerned up to 31 homes on land west of Little Smiths Farm, Drayton. Inspector Stephen Wilkinson allowed the appeal on 11th September 2026.
The lesson cuts both ways: a council needs evidence for its delivery forecasts, but an appellant cannot assume that a general percentage deduction is justified simply because some permissions may never be built.
How the Vale housing supply figures compared
Vale of White Horse District Council claimed 5.34 years. The appellant’s primary position was 3.63 years, with a secondary calculation of 3.27 years. Neither headline was accepted.
The assessment covered 1st April 2025 to 31st March 2030. The requirement was 4,982 dwellings, including a 5% buffer. Because of the age of the development-plan housing requirements, the calculation used local housing need derived from the standard method.
After testing the disputed sites, the Inspector identified approximately 4,850 deliverable dwellings, rounded in the decision to 4.9 years. This is an assessment for that period and evidence base, not a permanent declaration about every future Vale application.
Our five-year housing land supply guide explains the distinction between the requirement, the buffer and the deliverable supply.
Where the 474-dwelling reduction came from
The decision separates its assessment into Category A and Category B sites. It removes 44 dwellings from Category A and 430 from Category B. These are reductions from the homes expected within the five-year period. In most cases they reflect delayed or slower delivery, not a finding that the entire site can never be developed.
| Site or phase | Homes removed | Inspector’s principal reason |
|---|---|---|
| Greensands | 29 | A fresh application was anticipated but had not been received; the contamination issue and likely lead-in made the trajectory unrealistic. |
| Land at Kiln Lane | 7 | The permission had expired. |
| Land at Fernham Road | 8 | The permission expired on 12th May 2026 without evidence of commencement. |
| Land west of Great Western Parkway, phase 3P | 90 | The council’s uplift to the developer’s build-out forecast was speculative. |
| Land west of Great Western Parkway, phase 6T | 175 | The developer’s local delivery forecast was preferred to the council’s uplift. |
| North of Abingdon-on-Thames | 70 | Progress on reserved matters did not support the assumed timetable. |
| Rogers Concrete | 30 | Outstanding reserved matters and lead-in times supported 55 completions rather than 85. |
| Land at Crab Hill | 65 | The remaining delivery period for the disputed phase was too short for the claimed output. |
| Total | 474 | Site-specific reductions; no additional blanket discount. |
The detailed findings are in paragraphs 25–53 of the decision. The distinction between reduced build-out and complete removal matters when preparing a competing trajectory.
What evidence established deliverability?
The Inspector considered the planning status of each site, whether permissions remained alive, progress on reserved matters and conditions, infrastructure constraints, evidence of construction, developer programmes and realistic lead-in and build-out periods.
The August 2026 NPPF distinguishes sites with the benefit of the deliverability presumption from major outline permissions, allocations and other sites requiring clear evidence that completions will begin within five years. The existence of a planning permission is not the answer to every trajectory dispute.
However, a slow start did not automatically justify deletion. Westview and Long Reach remained in the supply because delay alone did not provide the necessary clear evidence against delivery. On other sites, building-control records, surveys, imagery and evidence of works supported retention.
Monks Farm also survived the challenge: developer evidence, resolved infrastructure matters and reserved-matters applications submitted ahead of expectations supported its forecast. The Inspector was testing the evidence, not applying an assumption that disputed sites should always be excluded.
Nor did strong past Housing Delivery Test results prove future supply. The decision expressly distinguishes historic performance from the current prospects of individual sites.
Why the blanket non-delivery discount failed
The appellant sought a further percentage allowance for non-implementation or lapse. The Inspector found no supporting evidence for that approach in this appeal.
He also found that neither the NPPF deliverability definition nor the Planning Practice Guidance on housing supply and delivery advocated an automatic allowance of that kind. The site-by-site exercise had already identified actual expired permissions and unjustified delivery assumptions.
An additional deduction would therefore unnecessarily and unjustly reduce the council’s supply. Importantly, the Inspector acknowledged that other Inspectors had accepted percentage discounts on different evidence.
This is not a ruling that a percentage allowance can never be justified. It is a clear warning against presenting one as an automatic national-policy requirement or applying it without explaining what evidenced risk remains after individual sites have been assessed.
Why Oxford’s unmet need was not simply added
The appellant also argued that Oxford’s unmet housing need should form part of Vale’s requirement for this decision. The Inspector rejected that approach in the circumstances of these older development plans.
Both authorities were using standard-method local housing need. He found no policy basis for adding Oxford’s unmet need to Vale’s development-management requirement. Strategic redistribution, the large allocations and the infrastructure needed to support them were matters for the emerging Joint Local Plan.
This does not mean neighbouring unmet need is irrelevant to planning. It distinguishes the strategic plan-making exercise from the particular calculation used in this Section 78 appeal. Our local housing need guidance explains why need and an adopted plan requirement are not interchangeable.
There was a further supply-side qualification. The Inspector considered removing all 173 dwellings from three Oxford-fringe sites excessive, because those homes could also serve people moving within Vale. He accepted that a proportionate reduction could be considered, but did not calculate or apply one: it would not alter the conclusion that supply was below five years.
Why the Drayton appeal was allowed
The housing shortfall was important, but it did not settle the whole planning balance. The site lay outside the built-up area and conflicted with parts of the development plan’s spatial strategy.
Its relationship to Drayton mattered. Existing housing lay nearby, village facilities were accessible on foot or by bicycle, and bus services connected the village with surrounding centres. The Inspector considered the new NPPF Policy S5, including its route for development addressing evidenced unmet need outside settlements.
The provision of market and affordable housing attracted substantial weight. The Section 106 agreement secured a 35% affordable contribution, described in the decision as ten homes on site plus a £137,937 payment for the remaining fraction.
There were harms, including the loss of Grade 2 agricultural land and heritage harm at the lower end of the less-than-substantial range, associated with access works affecting the conservation area and a listed building’s setting. The heritage harm still attracted great weight; it was not dismissed because it was described as low level.
The Inspector found that the public benefits outweighed the heritage harm and that the overall balance justified permission despite development-plan conflict. Outline permission was granted, with access determined and the other matters reserved.
Minimum statutory BNG received neutral weight
The decision contains a useful, narrower point about biodiversity net gain. At paragraph 128, the Inspector gave the scheme’s statutory 10% BNG neutral weight, because it met the legal minimum. That is how the minimum requirement was treated in this appeal. It should not be turned into a universal statement that biodiversity improvements never carry positive weight, or that every scheme offering 10% is in the same statutory and policy position.
Planning Geek analysis: challenge the assumptions, not just the headline
For councils, this decision underlines the need to explain why a trajectory departs from the developer’s own programme. For appellants, it demonstrates the value of identifying the specific permission, condition, infrastructure or programme evidence which undermines delivery.
A robust challenge should show which homes are likely to slip beyond the assessment period and why. It should also identify any remaining risk relied on for an additional allowance, rather than counting the same uncertainty twice.
The result is a particularly useful example for planning appeals: a detailed challenge succeeded in reducing supply below five years, even though the appellant’s broader percentage-discount argument failed.
Read the decision
Appeal 6005108; application P25/V0180/O; land west of Little Smiths Farm, Drayton, OX14 4JP; decision dated 11th September 2026. Download the Little Smiths Farm appeal decision, conditions and appendices: 6005108 (PDF). The key sections are paragraphs 10–59 on housing supply, 78 on affordable housing, 128 on BNG and the concluding planning balance. Report prepared: 12th September 2026
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