18. If the Inspector agrees with the Council on the application of Green Belt policy, there can also be no justification for allowing a breach of policy HI and the SPG on "Restricting the Supply of New Housing". The SPG should be accorded significant weight given that it is referred to in the reasoned justification to H1, it has been subject to public consultation and has been adopted by the Council. It clearly applies to the proposal under consideration in this appeal. By resulting in an additional new dwelling in the Borough, the proposal is in breach of the SPG and will cumulatively add to the over supply of housing in the Borough. In this regard, it is important to note that other Inspectors (including the Inspector on this appeal) have applied the policy strictly. It is submitted that the policy should similarly be applied here. This proposal does not fall within any of the stated exceptions to the SPG.

19. If, however, the Inspector is minded to allow the proposal because he finds that there are special circumstances to justify the development in the Green Belt and to justify a departure from the SPG, he is respectfully requested to make clear in his decision that the proposal is nevertheless contrary to the development plan and the SPG in this regard.

20. It is of course the Council's case, however, that the special circumstances put forward by the Appellant are not sufficient to justify either a departure from the SPG or inappropriate development in the Green Belt and for all the above reasons the Inspector is urged to dismiss the appeal.

Jenny Wigley
No 5 Chambers
27th October 2004

[Original typescript transcribed by Mike Chitty of The Wavertree Society, November 2004. E. & O. E.]