Houses could be built on open farmland in Fleet, opposite the sports centre, if a developer's appeal is successful.
The developer has launched an appeal because Hart has failed to make a decision on its plans for building homes on land west of Hitches Lane.
Hart says it has been unable to consider the plans while it waits for a crucial report on land development in the area.
Last March Hart published a document outlining possible land available in the district for both recreational and residential use. Planning applications relating to these modified plans and including Hitches Lane have not yet been considered because members were awaiting the "Urban Capacity Study" report.
In the report, land suitable for development would be identified and preference given to available, suitable, urban or previously developed land. After that, greenfield sites needed to fulfil district housing requirements up to 2006 would be looked at followed by a revised Hart District Local Plan identifying land earmarked for development.
Coun. Colin Hazell said it was disappointing that Berkeley Strategic Land was placing extra work and cost on Hart when the delay in processing its planning application was due to Government requirements.