Monday, 31 October 2011

Planning – the way forward?

Following the end of the consultation period on the draft National Planning Policy Framework earlier this month, it is becoming clear that numerous local planning authorities all round the country, and of all political hues, have sent a range of robust responses to the document to De-CLoG. The points they make are varied, but one message comes through loud and clear - they don’t like it.

Up to now the Secretary of State has seemed intent on impersonating Jabba the Hut in the way he has responded to any criticism or counter-argument to his stated intentions, not only about the NPPF but about almost anything and everything, including dustbin collections. However, it is going to be difficult for the government entirely to ignore the weight of opinion which has been brought to bear on this subject.

Although there are some LPAs whose views are indistinguishable from those of the Daily Torygraph, the National Trust and the CPRE, one theme which has emerged on all sides is the concern expressed about the loss of much very useful, even essential, policy guidance which is contained in the existing suite of Planning Policy Guidance Notes (and Statements) which the NPPF is intended to replace. The fear is that the NPPF will leave numerous lacunae in policy guidance which will lead to considerable uncertainty and the possibility of endless disputes as to the proper approach to those issues which were covered in the previous policy advice but about which the NPPF is silent.

This is precisely the objection I identified right at the outset of this exercise, when the government first announced their intention to produce a substantially abridged version of ministerial policy advice in the form of the NPPF, in place of all the PPGs and PPSs we have now. I predicted in this blog the difficulties and uncertainties which this would cause, and I made the point (as others have more recently) that the length of the existing policy advice, in terms of the number of pages it covers, is not an objection in itself to that policy guidance.

One option which the government might be well advised to consider (although it would involve considerable loss of face for ‘Jabba the Hut’ himself) would be to withdraw the proposed NPPF altogether. This is not so say that the government should abandon its determination to achieve economic growth through development, simply that they should go about it in a different way. If the government is prepared to admit that they made a huge mistake in seeking to scrap all the existing ministerial advice on planning policy, they could nevertheless publish a circular (very much on the lines of the pro-development circulars published by Michel Heseltine in the early 1980s, starting with Circular 9/80 and ending with 14/85) which makes the government’s more liberal approach towards development abundantly clear. Any necessary adjustment can then be made to individual PPGs and PPSs, although comparatively few changes to those documents are likely to be needed.

Such a revised approach would have the advantage that there is no legal or political obligation on the government to consult on a circular before it is published, and such consultation as might be required on amendments to PPGs and PPSs would relate solely to any minor changes that might be needed to bring a particular document into line with the over-arching policy set out in the new circular. Such an exercise would be much less likely to stir up controversy than the consultation exercise over the draft NPPF has done.

The question is – has the government got the guts to do this? It would involve what will almost certainly be seen as yet another U-turn, but that in itself could have its advantages. It would wrong-foot much of the rather over-heated and misguided opposition to the draft NPPF, while not in fact representing any retreat from the government’s intention to promote growth through development.

In practice, I rather expect that we shall still get a revised version of the NPPF, but perhaps fleshed out with some of the material which was inadvisably omitted from the original draft, and with some anodyne reference to the use of brownfield land as a sop to the critics. That would be a pity but politics, as they say, is the art of the possible, and David Cameron would never do anything to dent the pride and self-regard of ‘Jabba the Hut’, now would he?


Tuesday, 25 October 2011

Change at the Planning Inspectorate

Planning professionals will already be aware of the news that Peter Burley, who has been in charge of PINS’ Welsh branch in Cardiff, has been appointed Chief Planning Inspector.

My colleague David Brock has very recently commented on this in his own blog, and rather than my repeating what he has already written, I would refer you to the link to David’s blog on the left-hand side bar of this page. I agree with everything David has written about this.

It is encouraging that we have a professional head of the Inspectorate at an operational level (replacing the position which was formerly held, without the title but with great distinction by Leonora Rozee), although the chief honcho (Sir Michel Pitt) is purely a management man with no previous professional experience in PINS.

On the other hand, I share David’s concern at the removal of the PINS website. The Inspectorate should be and should be seen to be at arm’s-length from government. I am not paranoid by nature, but I strongly suspect machinations within De-CLoG to bring what had occasionally been an independent voice under central control, and to silence any potentially dissentient views.


Sunday, 23 October 2011

NPPF - a balanced view

On Thursday 13 October the House of Lords took a short break from the Report Stage of the Localism Bill to have a free-standing debate on planning generally. This debate was specifically concerned with the draft NPPF, and in initiating the debate, the Labour peer Lord (Jeff) Rooker said that in principle, and in general, he is actually with the Government on the issue of proposed changes to the planning system.

Ministers, he said, had had a torrid time from their friends at the Daily Telegraph, the owners of which are not really entitled to a view on this issue from their offshore island. There has been much misleading hype from the National Trust and the Campaign to Protect Rural England. He did not think they believed everything they put out. As Planning Minister, he had had disagreements with them, but they did not feel they had to resort to hype on the current scale.

Lord Rooker pointed out that the draft NPPF deals solely with England. Over 90 per cent of the land of England is not built on. National parks account for 9 per cent; designated areas of outstanding natural beauty account for 15 per cent; the green belt accounts for 13 per cent; urban developments (including the roads and other infrastructure) are 9 per cent. That is a total of 46 per cent. From memory, he said, when he was at the relevant department, the land that was thought to be needed for development, i.e. for housing and other infrastructure, was about 1 per cent. So, what on earth is the problem? That is all we are talking about in terms of the scope of the land of England for proper development. The last Government managed to leave behind more green belt than they inherited, two new national parks and sustainable development.

The draft planning policy nowhere near seeks to destroy our countryside, areas of outstanding natural beauty, the green belt or our vast open countryside. The NPPF simply does not do that given the very limited amount of land that is required. In Lord Rooker’s view, we need to get real on this matter.

However, he suggested that the final policy has to include encouraging the use of brownfield. It will remove a major plank from the sometimes misleading opposition to the draft policy. The NPPF is a draft and any draft can be improved. But the central thrust should remain a presumption in favour of sustainable development. It is not a plan to concrete over our manmade countryside or destroy the quality designated areas. Those who claim this were plain wrong, in his view.


Localism Bill - Lords Report Stage completed

The House of Lords completed the report stage of the Localism Bill on 17 October.

Disappointingly, there has been no further amendment of the clause relating to allegedly ‘concealed’ development, but the Law Society did at least secure a partial amendment of the offending clause at the committee stage, which will make its effect slightly less draconian than the original draft. These provisions are now set out in Clauses 124 to 126. I will take a look at these provisions in more detail in a separate post later.

The government tabled amendments to what was then Clause 111 (now Clause 123), dealing with applications for retrospective planning permission, so as to make it clear that a retrospective planning application would only be precluded where there is a pre-existing enforcement notice in place. For the purposes of the operation of this section, a "pre-existing enforcement notice" is defined as an enforcement notice issued before the retrospective application is received by the local planning authority. This amendment is designed to meet a point which had been raised in committee by Lord Avebury, who thought that the drafting of what is now Clause 123 was ambiguous, so that it might be possible for a local planning authority to negate the purpose of this clause by both declining to determine a retrospective planning application and arguing that an enforcement appeal on Gound (a) was also inadmissible. These amendments, according to ministers, should solve the problem. The government’s policy is that those people seeking planning permission after the event should have one, but only one, bite at the cherry.

The government has also attempted to a limited extent to allay fears as to the effect of what was then Clause 130 (now Clause 142), which provides for ‘local financial considerations’ (i.e. the New Homes Bonus) to be taken into account as a material consideration in the determination of planning applications in accordance with section 70(2) of the 1990 Act. The amendment makes it clear that this clause in the Bill does not alter whether regard is to be had to any particular consideration, or the weight to be given to any consideration under that subsection. Members of the House nevertheless expressed misgivings about the continued presence of this clause in the Bill, and its actual and intended effect on the development control process.

The government has also moved to meet criticisms of the clause relating to unauthorised display of advertisements by adding to the Bill a right of appeal to the Magistrates’ Court where a removal notice has been served in accordance with section 225A(3) or (5)(b) of the 1990 Act (as amended) – in what is now Clause 127.

There was a also a discussion on opposition amendments relating to appeals, which were not in fact pressed to a vote. This revealed that the government is still thinking in terms of limiting the right of appeal at some stage in the future. On behalf of the government, Lord Shutt said “The purpose of our planning reforms is to put the local plan at the heart of the system. In fact, the draft national planning policy framework explicitly says so. It is the plan where councils and communities weigh up and integrate different goals and long-term needs so that it sets the framework within which individual planning applications are assessed and decisions taken. We want planning decisions to be taken by local communities, not more appeals undertaken by unelected inspectors in Bristol.”

He added “We are committed to a system of fewer appeals and want development proposals to be determined locally. However, in the few cases where appeals are made, the Secretary of State, as decision-maker, must be entitled to take other material considerations into account, as can councils, on finely balanced matters of judgment-for example, where a local policy is out of date because it does not reflect the changing circumstances of the local area or more recent national policy. In such instances the law allows councils to consider other material considerations in making the right decisions for their communities. ........We shall take the measures that I outlined earlier so that councils and communities feel confident, if challenged at appeal, in defending planning decisions made in accordance with an up-to-date plan and where there is no conflict with national policy.”

I don’t like the sound of that, and we shall have to be vigilant to avoid any future attempt to abrogate or limit the right of appeal or the basis on which appeals will be considered and determined.


Wednesday, 19 October 2011

Non-planning issues creeping in

I received an interesting note last month from Robert O’Leary of O'Leary Goss Architects Ltd. As he observes, there appears to be a definite shift in the extent to which planning applications are now being evaluated against technical matters that have traditionally been quite separate, and were previously dealt with through the Building Regulations process. This seems particularly invasive where addressing the technical issues would not affect the design or appearance of the proposed building insofar as this is presented for planning permission.

An example of the introduction of detailed and highly technical issues into the development management process under the guise of "sustainability" is provided by the September 2011 edition of Bristol City Council's Development Services e-bulletin produced by their Development Management and Building Regulations & Standards services, referring to “Sustainability Statements and changes to validation requirements”: Here are a couple of examples of the information which the planning department is now asking applicants to provide when submitting a planning application:-

For residential developments comprising 10 or more dwellings there is a requirement for a Code for Sustainable Homes assessment. The quoted policy also requires a Revised Report/Ratings to be submitted with the planning application, with the design stage assessment/interim certification submitted wherever possible. This is at variance with the Technical Guidance (Nov. 2010) for the Code which advises that for the design stage assessment…"The DS assessment is carried out on the detailed design of each dwelling in the period up to the issue of tender documents, sometimes referred to as RIBA Stages A–G. A Code assessment requires a more detailed specification than Building Regulations compliance because the Code covers many more aspects of the performance of the dwelling." It follows from this that it is entirely inappropriate for the LPA to require this information at the planning application stage.

Another paragraph requires the modelling of the proposed building(s) using a specific code, the purpose of which (according to its authors) “is to produce consistent and reliable evaluations of energy use in non-domestic buildings for Building Regulations Compliance and for Building Energy Performance Certification purposes". Again, it is entirely inappropriate for the LPA to require this information at the planning application stage.

As Robert O’Leary observes, these points raise a number of very important questions:

1. In formulating these very specific policies has there been any consideration of the practicality of preparing the considerable level of detail to a fixed and final form at the time of submission of a planning application?

2. There are no specific guidelines on what Code Level is desirable. The saving of "at least 20%” in CO2 emissions in the Council’s document does not indicate the baseline from which this saving is to be achieved.

3. How do these policies, and the desire to implement compliance with energy strategies by planning condition tie in with the Building Regulations? In the event of conflict between what is approved by Planning and what is required by, say, an amendment to the Building Regulations or a rethink of the energy strategy during design development, which takes precedence? What mechanisms have been set up to allow for dialogue between planning officers and either Building Control officers or Approved Inspectors?

4. How would a revised energy strategy (which has no effect on the siting, scale, massing, access or detail of the approved building) to comply with the Building Regulations be dealt with? Would this require a full planning application, a minor amendments application, or would it be dealt with as a discharge of conditions?

5. How will the content of the highly technical issues associated with the energy strategy be assessed at the time of the planning application? Also, by whom, and with what technical qualifications?

6. Is it correct to assume that the discharge of the condition covering the energy strategy/CSH/BREEAM assessment can only be discharged on completion of the dwelling? This raises significant practical difficulties with regard to the discharge of the relevant condition, which (in Bristol at least, and no doubt in a number of other authorities) may take 8 weeks or even longer. This could result in a delay at the end of any project of a minimum of 8 weeks, and probably more, whilst the LPA discharges the condition requiring CSH certification. The absence of a discharged condition to a planning permission will not allow any sale to complete or occupation to take place, with an ensuing potential financial nightmare for all involved. Given that all other conditions would have been discharged, I assume that this final submission would require a further fee payment (currently £85).

I entirely agree with Robert O’Leary, when he says that all of this raises some significant concerns. These include :

1. The attempt to set aside the process for compliance with the Building Regulations by the planning system.

2. The difficulty in enforcing this, particularly where the Regulations may change and differ from the detail forced into the planning permission. In short - which takes precedence?

3. The competence of anyone in the planning system to properly discharge compliance with these issues (which would usually be dealt with by experienced building control staff).

4. The confusion amongst officers associated with the planning process between the Building Regulations, and the approved documents (which are only one way of complying).

5. The increasing drive to require ever more detailed designs and expensive reports at the planning application stage.

All of this very clearly demonstrates the impossible position in which developers, their architects and other professional advisers are placed when the planning system is distorted by importing concepts and standards which should be confined to other regulatory regimes, in this case building control under the Building Regulations. There used to be clear ministerial policy guidance to the effect that non-planning issues which are dealt with under other regulatory regimes should not be dragged into the planning process and should not be treated as material considerations in the determination of planning applications. I cannot put my finger on this in the current guidance, although it may still be inferred from paragraphs 11 and 12 of “The Planning System: General Principles” annexed to PPS1. Ministers should ensure that this principle is clearly re-stated in the published version of the NPPF next year. Technical issues which need to be addressed in order to tackle climate change should be confined to the building control process under the Building Regulations, where they properly belong.

© MARTIN H GOODALL (with due acknowledgement to Robert O’Leary)

Thursday, 13 October 2011

Dale Farm judgment

Perhaps not surprisingly, the last ditch attempt by residents of the Dale Farm travellers’ site in Essex to prevent their eviction from the site failed in the High Court yesterday. The challenge on human rights grounds was rejected by Mr Justice Ouseley, who held that the Council’s action in seeking to evict the residents from the illegal site was not disproportionate.

I have not yet seen a transcript of the judgment, but I understand that a further reason for refusing this latest application for judicial review was that there had been undue delay in bringing these proceedings against the Council’s decision to take direct action to evict the residents of the site.

It seems clear that the judge felt that this last-minute attempt to prevent or delay the physical execution of enforcement notices which had previously been upheld by planning inspectors and by the courts was totally lacking in merit, and that preventing the effective enforcement of planning law would bring the whole planning system into disrepute.

It seems that the claimants have not ruled out the possibility of an appeal against this judgment, but it is very unlikely that the Court of Appeal could be persuaded to give permission for an appeal to be pursued. These claimants have, however, shown remarkable determination in their attempts to use every possible means to prevent their eviction from the site, so it may be premature to predict that this is necessarily the end of the legal road for them.

Although reports which I have seen do not say so in terms, the injunction preventing the Council from proceeding with evictions has no doubt been lifted, so that there is no longer any legal impediment to the Council’s taking the necessary steps to clear the site. I would think it very unlikely that the claimants could persuade any court to order any further delay of evictions pending an appeal.

There has been a certain amount of hot-headed comment out of court on both sides of the case during the course of these proceedings, but the latest hearing does demonstrate that the Courts will bend over backwards to do justice and to ensure that it is manifestly seen to be done. It is right that the claimants’ latest legal challenge should not have been dismissed out of hand but that it was given a fair hearing. On the other hand, the judge was undoubtedly right, after careful consideration of the matter, to dismiss the claim and to insist that the law must now take its course.


Tuesday, 11 October 2011

The planning debate continues

I was interested to see a piece entitled “The Great NPPF Consensus?” which Chris Brown posted on his blog at the weekend, following the Tory party conference. I don’t necessarily agree with everything he said, nor with all of the comments the piece has attracted, but it is nevertheless an interesting summary of the current state of the planning debate, and gives a useful indication of the direction which the debate over the NPPF and ‘localism’ might take, following the end of the consultation period on the draft NPPF next week. The article can be found at:

[We don’t do links on this blog (sorry about that), but you can avoid having to retype the full web address by blocking and copying it (CTRL + C), then clear the address line at the top of your web browser and paste in the copied address (CTRL + V) and click on the ‘Go’ arrow. You should be able to get back to this blog afterwards by clicking on the return button at the top left of the screen.]


Friday, 7 October 2011

Brownfield first?

If one ignores all the hot air and pointless posturing in the National Trust’s recent 10 ‘asks’ to the government, the one point with any real substance is the request that the government should restore the preference for developing brown land (or “brownfield sites” as they are usually called nowadays) before greenfield sites are developed.

The form in which this policy was applied by the last government had a disastrous effect on housebuilding. The requirement that 70% of housing development should be on brownfield sites seriously reduced the overall level of house building and contributed to the ever-growing housing shortage.

I have expressed the hope in previous posts that the government will resist this particular demand on the part of the NT and others, but if they are minded to make some concession in that direction, as indications suggest they might, it should certainly not include any percentage target. To do so would be wholly unrealistic, and would simply prolong the current housing shortage.

The plain fact is that in order to build the sort of family homes that are needed, with generous gardens in which children can play safely, a lower density of development is required. The previous government’s policy led to too many little boxes being built on cramped sites, which were totally unsuitable for families. We do not need yet more one-bed and two-bed flats; we need decent family homes.

If ministers are persuaded that there does need to be some reference in the NPPF to the desirability of developing brownfield sites in preference to greenfield, any such statement should be qualified by the proviso that this would apply only where it can be demonstrated by the LPA that there are brownfield sites in the same district which are currently available and are physically capable of being developed with the same number and type of homes that are proposed by the developer, and that it would be commercially viable to do so taking account of the location of the alternative site or sites, the physical state of the land and any contamination and other problems requiring remediation.

In practice, it is likely that a substantial number of brownfield sites will prove on investigation not to be currently available or to be incapable of commercially viable development. It is undesirable and would be damaging to the government’s wider objectives to place too high a hurdle in the way of the development of greenfield sites. The development of such sites is essential and unavoidable if housing need is to be met. Only where a currently available brownfield site is a realistically viable alternative should the development of a greenfield site be resisted by the LPA.

So if the government makes any move to accommodate the views of the National Trust and others on this point, they should be very careful in doing so not to inhibit or delay much-needed housing development.


Saturday, 1 October 2011

And it came to pass..........

One of the early posts in this blog after it was re-launched in April 2010 took the form of an imagined speech by a Secretary of State (“in a galaxy far, far away”) who was intent on adopting a pro-development agenda, and was prepared to change the planning system to make it happen.

This was written and published a month before the General Election, when it did not appear that any of the major parties had any intention of pursuing such an agenda, and certainly not the Tories whose “Open Source Planning” ‘green paper’ seemed set to become a NIMBYs’ charter. How things have changed!

The readership of this blog back in April 2010 could probably be counted on the fingers of one hand; whereas we are now getting 8,000 page views a month (and still rising), so I thought it might be worth revisiting that earlier piece, to see how certain passages in the imagined speech compare with what the government is now proposing.

The first topic touched on was the presumption in favour of development. These are the words I put in the mouth of my fictional minister:

As you know, if you want to carry out development in this country you need planning permission, but I want to re-establish the principle which once applied to all cases where the citizen is required by statute to apply for a licence or permission to do something, namely that that licence or permission should always be given unless there are sound and clear-cut reasons for refusal. In other, words, there is always a presumption, indeed a strong presumption, in favour of the requisite permission being granted.

The reasoning behind this is very simple - without the legislative restriction imposed by parliament the citizen would be perfectly entitled to do with his property as he pleased. He should not therefore be deprived of his property rights without good reason, and so planning permission should always be granted unless to do so would cause demonstrable harm to interests of acknowledged importance. That was a principle which was recognised for many years, and it is not so very long ago since government policy guidance said precisely that

My colleague, David Brock, has pointed out that the presumption in favour of development dates back in fact to 1923. It applied, more or less without qualification, until at least 1987, if not later, and then continued as a presumption in favour of development which was ‘in accordance with development plan’, but the presumption remained in place nonetheless. It is hardly a revolutionary concept.

After a discussion of changes to the development plan system (not currently on the ministerial agenda), my putative Secretary of State went on to consider changes to the Use Classes Order and to the General Permitted Development Order:

I want to turn now to some of the main policy changes I propose in order to make the planning system fairer and less burdensome. First, I intend to widen considerably the scope of Permitted Development under the General Permitted Development Order, especially for householder developments. The previous government has already had one go at householder development (under Part 1 of the Second Schedule to the GPDO) and quite frankly they made a total mess of it. Far from being more liberal, the new provisions have simply replaced one set of restrictive and ambiguous rules with another. I don’t propose to go into the detail here, but what I have in mind is a much more liberal regime for householder developments and a set of rules which iron out the ambiguities and anomalies and which are easily understandable. I propose to take the same approach to the rest of the GPDO and to rewrite every part of the Second Schedule in a similar fashion.

I also propose to revisit the Use Classes Order so as to produce rather broader classes, especially for commercial uses in town centres. For example, I propose to amalgamate the Category ‘A’ Use Classes in a single class, so that there would no longer be any restriction in changes of use to and from retail, office and catering uses in town centres. We really must leave it up to the market to decide what uses will be commercially viable in particular locations. I do not accept that we have to intervene in a misguided effort to protect primary retail frontages from other town centre uses. Nor should the planning system be used to restrict or control the development of food and drink or leisure uses in town centres. So far as the sale of alcohol is concerned, and the problems sometimes associated with it, that is a matter for licensing authorities; it is not the business of the planning system

Proposed changes to the UCO and GPDO may not go as far as this, but ministers certainly seem to be prepared to contemplate some significant liberalisation in this area.

One suggestion which was put forward in this imaginary speech which ministers do not currently appear to be pursuing was to ensure that it should no longer be open to local planning authorities to restrict the scope of the UCO by conditions attached to planning permissions which seek to restrict changes of use within a particular Use Class. The intentions of parliament in passing Section 55(2)(f) of the 1990 Act should not be over-ridden in this way.

I (or, rather, my fictitious minister) also proposed that the power of local planning authorities to remove permitted development rights by means of conditions attached to planning permissions should be ended, so that in future, if there were genuine and compelling reasons for restricting permitted development in particular areas or on particular sites, planning authorities would have to use the procedures available under Article 4 of the GPDO, which should be subject to ministerial review and confirmation if there were objections. (The requirement for ministerial confirmation of Article 4 directions was removed by the last government.)

The next main topic dealt with in this theoretical speech was the need to find considerably more housing land.

There will still be a need for a very large number of houses to be built in the private sector, and it is frankly unrealistic to expect that the numbers required can be built without resort to a significant number of ‘green field’ sites, especially in the south-east of England. All that has been achieved by restricting new build to ‘brown’ land is an overall reduction in house building, and the over-provision of small flats when there is an overwhelming need for family houses, with a decent amount of garden space where children can play. I shall use my supervisory powers over Development Plans to ensure that sufficient housing land is released to provide the homes we need, and I shall reinforce ministerial policy requiring local planning authorities to identify a 5-year land supply for housing (with a 2-year supply of sites ready for immediate development), failing which undesignated ‘wind-fall’ sites will have to be given planning permission (on appeal, if necessary) in order to ensure that house-building targets are met. We do need to predict future housing needs, and we do need to provide the land to meet those predictions. The so-called alternative of “plan, monitor and manage” simply did not deliver the housing the country so badly needs.”

The government has set its face firmly against the imposition of top-down housing targets, but it is clear that by one means or another they intend that there should be substantially more houses built in the future, most of which cannot realistically be built on brown land.

My phantom Secretary of State next proposed to overhaul the Green Belt, but despite the fears expressed by the National Trust and others, the draft NPPF does not depart from the principles currently set out in PPG2. I have set out elsewhere in this blog my own views on the need for Green Belt reform, and so I do not need to repeat them here.

I (or my alter ego) also proposed similar changes to the legislation and practice relating to Listed Buildings and Conservation Areas, but there does not seem to be any appetite on the part of ministers to intervene in that area. Again, concerns which have been expressed about the NPPF appear to have been prompted by the omission of some detail which had previously been set out in PPS5. I do not believe this betokens any change of policy on the part of the government.

My imaginary Secretary of State ended his speech with this peroration:

Bearing in mind the disappointing results following previous promises of planning reform, those involved in planning and development might be forgiven for being a little cynical about the proposals I have announced, but I assure you, ladies and gentlemen, that this is no cosmetic exercise. This time we are going right back to first principles. It may involve the slaughtering a few sacred cows, and I can already hear the screams of agony from certain special interest groups, who have become accustomed to regard the planning system as a useful tool for resisting change. But such protests will not deter us from our intent to carry through these reforms, so as to produce a planning system that is truly responsive to the needs of society, and which will produce the development that we need, in the right place and at the right time, in order both to sustain our economic position and to provide decent homes for our citizens.”

We have recently heard loud and prolonged “screams of agony from certain special interest groups, who have become accustomed to regard the planning system as a useful tool for resisting change” Some of the details of the NPPF may benefit from some modest textual amendments, mainly to restore to the text certain passages from previous ministerial policy statements which seem to have got ‘lost in translation’, but I do hope that the government will stick to its guns “so as to produce a planning system that is truly responsive to the needs of society, and which will produce the development that we need, in the right place and at the right time, in order both to sustain our economic position and to provide decent homes for our citizens”.

Perhaps I should offer my services as a political speech-writer!