when is a site isolated?
Policy S5: Principle of Development Outside Settlements of the National Planning Policy Framework (NPPF) published in August 2026 sets out the types of development that should be approved outside settlements, which includes development proposals comprising isolated homes that accord with Policy HO11.
Policy HO11: Isolated Homes in the Countryside of the NPPF is permissive of “isolated” new dwellings in the countryside in certain circumstances, including criterion (e) where the design is of exceptional quality, in that it is truly outstanding, reflecting the highest standards in architecture, and where it would help to raise standards of design more generally in rural areas (limb 1); and would significantly enhance its immediate setting, and be sensitive to the defining characteristics of the local area (limb 2).
The policy replaced the former Paragraph 84 (‘Para 84’) of the previous version of the NPPF, published December 2024.
The policy provision within the NPPF (August 2026) that provides the justification and support for new country houses uses the term ‘isolated’ homes in the countryside. A common question therefore is, when is a site isolated?
Until August 2026, the term ‘isolated’ was not defined in national planning policy guidance. Its meaning had however been the subject of two court judgements handed down in 2017 and 2018 at the time when the policy relating to isolated dwellings in the countryside was contained in paragraph 55 of the then NPPF (published 2012), and more recently a third judgement which was made in 2021 at the time when the policy was contained in paragraph 79 of the then NPPF (published 2019).
Refer to ‘The 2017, 2018 & 2021 Judgements’ section below for more information.
However, with the publication of the latest NPPF (August 2026), the Government has now provided a definition of the term ‘isolated’ for the purposes of Policy HO11.
Isolated homes are defined as “those lying outside settlements or groups of houses” (NPPF, Policy S5(3)).
Having regard to the new definition, it is important to point out that: -
a) the new NPPF distinguishes between development “within settlements” which are covered by Policy S4 of the NPPF, and development “outside settlements” which are covered by Policy S5 of the NPPF; and
b) the new NPPF also provides a definition of ‘settlement’ which excludes hamlets and scattered groups of houses located outside predominantly built-up areas, unless specifically defined as a settlement in the development plan.
The reference within the definition of isolated to ‘groups of houses’ must be read in its true context which is to say that one of the development types that is appropriate “outside settlements” is - limited infilling within groups of houses (Policy S5(e)). Thus, if a site is within a group of houses outside a settlement, then this is an appropriate form of development. In such circumstances, it would not be necessary to accord with Policy HO11.
The NPPF also, for the first time, provides a definition of “settlement”, as follows: -
“Includes cities, towns, villages and other predominantly built-up areas, including land which is allocated or has permission for development which will form part of the built-up area once the development is complete. This includes areas defined as a settlement in the development plan (whether using defined settlement boundaries or equivalent terms, or criteria for identifying settlement extents where boundaries have yet to be defined).
Importantly, the definition of “settlement” does not include: -
“…hamlets and scattered groups of houses located outside predominantly built-up areas, unless specifically defined as a settlement in the development plan. For the purpose of this Framework they also exclude villages which lie within and are defined as part of the Green Belt in the development plan.”
The new definition now only requires the decision-taker to determine whether a site is within a settlement, in which case Policy S4 applies, or outside a settlement, in which case Policy S5 applies. If a site is outside of a settlement (as defined above) and does not comprise limited infilling within groups of houses, then Policy HO11 will apply. This will be the case no matter whether a site is very close to, or adjacent to, a settlement, or located further away.
The clear objective of the new definition is to remove the subjectivity regarding how far away a site needs to be from a settlement to become isolated, which had plagued so many application and appeal decisions. In essence, it is now a more binary decision.
POLICY DP3(5): Key principles for well-designed places
There are instances where permission has been granted for new homes in the countryside in locations that are not deemed to be isolated, including some of our own approvals listed on this website.
Previously known as ‘Para 139’, Policy DP3(5) of the NPPF gives “substantial weight” to outstanding or innovative designs which promote high levels of sustainability, or which help raise the standard of design more generally in an area, so long as they are consistent with the overall form and layout of their surroundings.
There is a growing body of Appeal Decisions in which Inspectors have attributed “significant weight”, “considerable weight” and “great weight” respectively to independent and expert assessment by design review panels regarding the design quality of proposals. Examples include Appeal References - 3357959 (May 2025), 330948 (July 2024), 3302832 (November 2022), 3241508 (March 2020) and 3213784 (March 2019).
It is important to be aware that whilst Policy DP3(5) may provide an alternative policy approach to justifying a new dwelling in the countryside on the basis of the substantial weight to be applied to outstanding or innovative designs which may outweigh other policy conflicts, the policy relates to all forms of development, in all locations. Unlike Policy HO11, it does not explicitly relate to new dwellings in the countryside.
The important takeaway from all of this is that the NPPF continues to promote and support design of outstanding quality, and the weight to be applied to such outcomes can outweigh conflict with other development plan policies.
the 2017, 2018 & 2021 judgements
In Braintree District Council v SSCLG & Ors [2017] EWHC 2743 (Admin) (2017) the Judge found “isolated” should be given its ordinary objective meaning of “far away from other places, buildings or people; remote” (Oxford Concise English Dictionary). The Judge also found “The immediate context is the distinction in NPPF 55 between “rural communities”, “settlements” and “villages” on the one hand, and “the countryside” on the other. This suggests that “isolated homes in the countryside” are not in communities and settlements and so the distinction between the two is primarily spatial/physical. At the Court of Appeal, Lord Justice Lindblom held that: -
““31…in its particular context in paragraph 55 of the NPPF, the word ‘isolated’ in the phrase ‘isolated homes in the countryside’ simply connotes a dwelling that is physically separate or remote from a settlement…”
“32. What constitutes a settlement for these purposes is also left undefined in the NPPF. The NPPF contains no definitions of a “community”, a “settlement”, or a “village”. There is no specified minimum number of dwellings, or population. It is not said that a settlement or development boundary must have been fixed in an adopted or emerging local plan, or that only the land and buildings within that settlement or development boundary will constitute the settlement. In my view a settlement would not necessarily exclude a hamlet or a cluster of dwellings, without, for example, a shop or post office of its own, or a school or community hall or a public house nearby, or public transport within easy reach. Whether, in a particular case, a group of dwellings constitutes a settlement, or a “village”, for the purposes of the policy will again be a matter of fact and planning judgment for the decision-maker. In the second sentence of paragraph 55 the policy acknowledges that development in one village may “support services” in another. It does not stipulate that to be a “village”, a settlement must have any “services” of its own, let alone “services” of any specified kind.””
In the subsequent Court of Appeal judgement handed down in March 2021 between City & Country Bramshill Limited v Secretary of State for Communities and Local Government & Others, Sir Keith Lindblom (Senior President of Tribunals) held that: -
“33…To adopt remoteness from other dwellings, instead of remoteness from a settlement, as the test for “isolated homes in the countryside” would seem inconsistent with the Government’s evident intention in producing the policy in paragraph 79. It would mean, presumably, that the policy would not apply to a development of housing in the countryside – large or small – on land next to an individual dwelling remote from the nearest settlement, because although the new homes might be “isolated” from the settlement, they would not be “isolated” from existing development. It would prevent the policy from applying to the development of additional dwellings, one or two at a time, on sites next to other sporadic rural housing, again on the basis that they would not then be “isolated”. It might even prevent the policy from applying to a proposal for two or more dwellings on a single, undeveloped site in the countryside, because none of them would itself be “isolated” from another dwelling, and the development as a whole would therefore not be “isolated”. If this were so, only the development of a single dwelling, on its own, separate from any other dwelling already built or proposed nearby, would engage the policy. This would be hard to reconcile with the Government’s aim, as policy-maker, to “promote sustainable development in rural areas”.”