118. A number of parties opposed to the allocations in the Green Belt highlight the advice in the PPG (which repeats a Ministerial Statement in 2013, CD9/H11)
that unmet housing need is unlikely to outweigh the harm to the Green Belt and other harm to constitute the very special circumstances justifying inappropriate development on a site within the Green Belt. However, the strategic allocations would be on land that is removed from the Green Belt, so would not be inappropriate development when a planning application is considered. The above guidance is not applicable. The relevant test for changing Green Belt boundaries (to remove land from the Green Belt) is that of exceptional circumstances (Framework, paragraph 83).
119. Parties also refer to the exchange of correspondence between the Planning Minister and the Planning Inspectorate in March 2014 concerning Green Belt reviews. I note that the Minister’s comments are not intended to be a change of policy. Furthermore, within the context of the need to provide around 13,000 homes, the allocation of five sites in the Green Belt has been the Council’s choice, which it consistently defended at the hearings in March/April 2014. That correspondence is not relevant to assessing the soundness of these proposals.