A temporary rural-worker dwelling at Wagtails Farm near Billingshurst has been refused on appeal after an Inspector accepted the need for intensive supervision during lambing but found no essential need for somebody to live on the holding throughout the year.
The Wagtails Farm rural-worker home was sought for three years while an expanding poultry, quail and sheep enterprise became established. The appeal failed because the functional need relied upon was largely seasonal and other ways of managing risks had not been convincingly ruled out.
An expanding mixed livestock enterprise
The 25-acre holding was being developed around laying hens, rare-breed poultry, quail, broilers and sheep. By year three, the business plan projected 4,000 laying hens, 1,200 broilers, 400 quail, 300 rare-breed hens and 25 breeding ewes.
The appellant argued that animal welfare, security and the practical demands of the enterprise made a 24-hour presence necessary. The proposed mobile home would allow that need to be tested while the business grew.
Inspector T Bennett accepted that there was agricultural work on the holding and that the question was not simply whether the business employed a full-time worker. The policy test was whether there was an essential need for a rural worker to live permanently at or near the place of work.
Lambing created a real need, but only for part of the year
The strongest part of the case was lambing. The parties agreed that close, round-the-clock supervision was needed during that period.
But with a relatively small flock, the Inspector considered the intensive lambing requirement to be short and seasonal. Temporary or seasonal accommodation could potentially meet that need without establishing that somebody had to live on the farm throughout the year.
The other claimed welfare risks did not bridge that gap. Routine feeding, watering, egg collection and animal checks could generally be organised without permanent residence. The evidence did not show that failures involving incubators, brooder equipment or other systems were so frequent that a year-round on-site presence was essential.
Technology and other measures had not been exhausted
The Inspector also looked at alternatives. CCTV, alarms and automated monitoring had not been fully deployed. Predator attacks had affected rare-breed hens where electric netting was not used, while other birds protected by electric netting had not experienced the same problem.
Security concerns were treated similarly. Two recent incidents had occurred while the appellant was already living on site, including an attempted break-in at the caravan. That weakened the argument that the mere presence of a resident worker was an effective answer to crime risk.
Why the Wagtails Farm rural-worker home was refused
Horsham had also raised concerns about financial viability. The Inspector did not treat that as the decisive issue at this stage. A temporary permission can allow an emerging enterprise to establish whether it will become financially sound.
But a temporary dwelling still needs an essential functional reason for somebody to live on site. On the evidence, that had not been demonstrated for the whole year.
The council could demonstrate only about a one-year housing land supply, but the Inspector gave the housing benefit of this isolated and occupation-restricted dwelling very limited weight. The appeal was dismissed on 21st September 2026.
Planning Geek’s guide to rural workers’ dwellings explains the wider policy tests.
Appeal reference: 6010187. Planning Inspectorate appeal page.
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