‘Limited Infilling’ is increasingly used by planning officers as a justification when approving applications in Normandy/Flexford, even where the site is outside the settlement area identified in the Local Plan and is therefore in the Green Belt. (It is worth recalling in this context that the Local Plan removed Normandy and Flexford, along with several other settlements, from the Green Belt, making then ‘inset’, rather than ‘washed over’; this meant that development within the settlement area would not need to accord with Green Belt policy.) We therefore thought it would be helpful to take a closer look at this concept of ‘limited infilling’ in the Green Belt.

 The Policy Framework

National planning policy is clear that “Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.” (National Planning Policy Framework (NPPF) – revised December 2023 – section 152. However, there are exceptions, and ‘limited infilling’ in villages is one of them (section 154 e).

The Guildford Local Plan (adopted in 2019) reiterates this protection. Policy P2 states: “The Metropolitan Green Belt… will continue to be protected against inappropriate development in accordance with the NPPF. Inappropriate development will not be permitted unless very special circumstances can be demonstrated. Very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”

The Plan also specifies that certain forms of development are not considered inappropriate, including “Limited infilling within the identified settlement boundaries” of settlements including Normandy and Flexford (which, NB, are treated separately for these purposes). It goes on to state that “Limited infilling may also be appropriate outside the identified settlement boundaries where it can be demonstrated that the site should be considered to be within the village” (emphasis added). This is the area that we examine more closely here.

In November 2023, following a consultation earlier in the year (see our Planning Alert of 24 Feb 23) Guildford Borough Council (GBC) published a ‘Green Belt Supplementary Planning Document’ (SPD) that attempted to be more precise about two tests: when could a proposed development be considered to be ‘in a village’ and what exactly is meant by ‘limited infilling’? It is a short document as these things go, and well worth a read.

Regarding whether a location can be considered to be within a village, the SPD makes clear that this need not be confined to the settlement area identified in the Local Plan: “it is important to note that this area is not definitive and there may be parts of the village outside of this boundary which could also be considered to be ‘in the village”.

Regarding limited infilling, it reiterates that “[The Local Plan] paragraph 4.3.23 states: ‘Limited infilling is considered to be the development of a small gap in an otherwise continuous built-up frontage, or the small-scale redevelopment of existing properties within such a frontage. It also includes infilling of small gaps within built development. It should be appropriate to the scale of the locality and not have an adverse impact on the character of the countryside or the local environment.”

However, the SPD is also clear that “Case law has established that what constitutes ‘limited infilling’ is essentially a question of fact and planning judgment.” (Section 6.27). In other words, each case will be taken on its merits.  

Note also that passing the test of ‘limited infilling in a village’ is not the end of the story: any application must still satisfy other planning requirements, e.g. regarding design.

Application of the Policy in Normandy and Flexford

Approvals for infilling in Normandy and Flexford predate the Local Plan: for example 16/P/01719 (approved despite being deemed not ‘in the village’), but since its adoption there have been a growing number of planning approvals for developments outside the identified settlement area, i.e. in the Green Belt, which have drawn on the concept of ‘limited infilling’ outlined above. This does not claim to be a definitive list, but some examples are:

19/P/00330 for two new houses adjacent to Northrepps Cottage in Green Lane East, Normandy; 22/P/00174 for 5 detached houses at the rear of Vaglefield Farm in Glaziers Lane; 23/P/00361 for the construction of two detached houses and garages at Wyke Lodge, Guildford Road (opposite St Mark’s Church). All of these were deemed to have passed the tests (a) of being ‘in the village’ and (b) of amounting to ‘limited infilling’.

However another application not far from the Wyke Lodge site, 20/P/01678, was refused on the grounds that it would not constitute ‘limited infilling’, as although there was a building to the west of it, there was nothing for 450 yards to the east. We recommend reading the Planning Officers’ Reports in the ‘Documents’ section of the relevant page in the Planning Portal to get a better sense of how the arguments are framed in all these cases.

What does the future hold?

Other applications in the pipeline also use the concept of ‘limited infilling’ as a justification, for example 23/P/01653 for three detached dwellings at Syndal, 61 Glaziers Lane (to the left of the lane leading to Backhursts), and there may be more to come. Whatever one thinks about the merits of the individual developments listed above, the prospect of every single gap in the Green Belt between Normandy and Flexford’s being ‘infilled’ is alarming. As one of our followers has said, filling in all the gaps in our lanes would be like removing all the punctuation marks from a paragraph.

One would hope that where a gap is sufficiently large, for example to the left of Glaziers Lane heading north and approaching the stream or, heading south, to the left approaching the railway bridge, or the various gaps to the left of Westwood Lane north of the railway bridge, no-one would seek to make a case for ‘limited infilling’. However, there is an application outstanding, 22/P/01207, (34 objections) for eight 2-storey dwellings on the second of those three plots, i.e. to the east of Glaziers Lane just north of the railway bridge, which argues “The proposal could be considered to be infill development due to its siting between and proximity to Normandy & Flexford”. *

This last case illustrates graphically the danger that the openness of the Green Belt land between the two distinct settlements of Normandy and Flexford will be eroded by creeping ‘limited infilling’. Once this happens the distinct, semi-rural, nature of our community will be lost and the way will be open to much larger-scale development. Local residents will need to remain vigilant and make their objections known in order to prevent this from happening. And let’s keep relentlessly focused on that test of ‘very special circumstances’, which in most cases will still be the most important criterion for development in the Green Belt.

* [This application was 'withdrawn' on 21 December, the day we published this article.]