Isolated homes and the NPPF – A definition?

At Plainview Planning we are regularly instructed to help landowners secure planning permission for new homes outside defined settlement boundaries. The projects can be challenging but the fact that a site falls outside of the defined boundary need not be fatal to your chances of success.
Councils generally take the view that settlement boundaries are sacrosanct, but it depends very much on the status of their Local Plan and whether they can demonstrate a 5 year housing land supply. Councils are also keen to cite national guidance which seeks to resist isolated homes in the countryside. But what does an “isolated home” mean in practice? Unfortunately the National Planning Policy Framework (NPPF) does not provide a clear definition.
A recent high court case brought by Braintree District Council brings a very useful interpretation of what the phrase “isolated home” really means. Mrs Justice Lang made the following observations:

• “Isolated” should be given its ordinary objective meaning of “far away from other places, buildings or people; remote”;

• Housing can be supported where it will “enhance or maintain the vitality of rural communities” and “by providing the supply of housing required to meet the needs of present and future generations”. Such provision is therefore not limited to just economic benefits. A rural home can contribute to social sustainability because of its proximity to other homes.

• The NPPF cannot be read as a policy against development in settlements without facilities and services since it expressly recognises that development in a small village may enhance and maintain services in a neighbouring village, as people travel to use them.

• In rural areas, where public transport is limited, people may have to travel by car to a village or town to access services. Policy is clear that sustainable transport should be sufficiently flexible to take account of the differences between urban and rural areas.

The village that the case related to had very limited facilities and amenities, comprising a village hall, public house and playing field. There was a village 2 miles away which had a post office, village store, public house, a nursery and pre-school. It was agreed that those occupying the proposed dwellings would rely heavily on the private car to access everyday services, community facilities and employment BUT this was consistent with national policy as sustainable transport opportunities are likely to be more limited in rural areas.
This latest case, in conjunction with the Dartford case that we reported on in March 2017, sets out a very clear and logical approach to interpreting what is an isolated dwelling.  
Plainview Planning have been making these arguments since the adoption of the NPPF in 2012, and it is encouraging to see the high court endorse the approach. Hopefully Local Planning Authorities will take note.