HGVs on a rural lane: the Great Eccleston appeal.

What the inspector decided

The two units were in use when the inspector visited: one for the maintenance and repair of vehicles including HGVs, the other for agricultural machinery repair and other work (paragraphs 4 and 5). The appellant's evidence was that they generate up to about 10 and 4 HGV movements a day respectively, generally routing to the A586 via White House Lane (paragraphs 23 and 24).

The inspector identified three issues: the development strategy, highway safety, and character and appearance. The scheme was found acceptable on character, but in conflict with the local plan's rural economy policies, because there was limited evidence that it involved diversifying or expanding an existing rural business (paragraphs 16 to 18 and 32 to 36). On highway safety, the inspector found a significant adverse risk, contrary to local plan policy CDMP6 (paragraphs 30 and 31).

The route, not the access

The local highway authority's view was that concerns about visibility at the site access could be overcome, and the inspector accepted that a condition could deal with the gate (paragraph 25). The finding of harm related to the route beyond the access.

1. The junction with the A586. The A586 is a principal route with fast-moving traffic and a sweeping curve near the White House Lane junction. Two collisions had been recorded at or close to the junction in five years, one of them serious (paragraphs 20 and 21). Even with the proposed widening, an HGV turning west out of White House Lane would partly overhang the eastbound lane of the A586 (paragraph 26).
2. Passing on the lane. There was a realistic possibility of HGVs meeting on White House Lane, or meeting other large vehicles from businesses in the area (paragraph 24). The inspector described 5.5 metres, the width given in Manual for Streets for two HGVs to pass, as a bare minimum that could not be consistently achieved along the relevant stretch. Manual for Streets also makes clear that bends need greater width (paragraph 27).
3. The consequence. Vehicles unable to pass could stop on the A586 or be forced into awkward manoeuvres, potentially including avoiding action on the A road itself (paragraph 27). On the site visit, even smaller vehicles had difficulty passing one another (paragraph 29).
4. Other road users. White House Lane is likely to be used on foot by residents of nearby properties walking to bus stops on the A586, including for school and college services (paragraph 22).

Widening and conditions

The appellant proposed widening on White House Lane near the junction and on Moss Side Lane, and suggested more could be done. The inspector was not persuaded that further widening was realistic. The lane is tightly bounded by established hedgerows, parts of its verges are likely to act as drainage ditches, and the area has a flood risk. Further works could be technically difficult and excessively expensive, so a condition requiring them could be unreasonable and fail the tests for conditions. Nothing indicated that a site management plan or other condition would address the concern (paragraph 28).

That reasoning is worth noting. Mitigation that is only possible in principle, or only at disproportionate cost, is unlikely to carry weight if it cannot be secured by a condition that meets the tests.

The fallback argument

Two fallback arguments were put forward. The first was a 2022 permission for three industrial workspace units in a building since replaced. The evidence on whether it had been implemented was inconsistent, the inspector saw no real prospect of it being carried out, and in any event it appeared to involve smaller units and smaller vehicles. It was given limited weight (paragraphs 37 to 39).

The second was a return to intensive agricultural use, with its own large vehicle movements. The inspector accepted that agricultural activity would generate some large vehicle traffic, but found nothing compelling to show that its type or frequency would be comparable to the appeal scheme. That too was given limited weight. The inspector also noted that the appellant had operated from the site as an HGV operator for over ten years, but the decision does not treat that as establishing any lawful baseline (paragraphs 41 and 42).

Points of interest and doubt

The movements involved are modest: around 14 HGV movements a day across both units. A reasonable argument could be made that a rural lane already serving farms and other businesses should be able to accommodate that level of traffic, and that the junction's collision record, two incidents in five years, is not in itself exceptional. The inspector's response rests on the specific geometry: the overhang into the eastbound lane on a bend in a fast road, and the inability to provide even the minimum passing width. It is a finding about this route rather than about HGV numbers in general.

The decision also gives an early indication of how inspectors are applying the 2026 Framework. The inspector described policy TR6.4 as stating that development proposals should be refused if they would have an unacceptable impact on highway safety, and concluded that, even if the presumption in policy S5 applied, TR6 indicated that the proposal should be refused (paragraphs 46 and 47). Readers relying on TR6 should check its full text rather than the inspector's summary.

Practical points

• Assess the whole route to the main road. For HGV-generating uses, the route can be the decisive issue even where the site access is acceptable.
• Test the conflicts that matter. Swept paths for two HGVs meeting on the lane, and for HGVs turning at the junction, should show the actual carriageway, including bends.
• Check that widening is deliverable. Establish highway extent, hedgerows, ditches and drainage before relying on widening, and be ready to show that it can be secured by a reasonable condition or agreement.
• Evidence any fallback properly. The type and frequency of vehicle movements under the fallback, and its lawful status, need to be demonstrated, not assumed.
• Include collision data and other users. The collision record and pedestrian use of the lane both featured in the inspector's reasoning.