The Falling Rate of Profit Redux Part One – The Bias towards Capital Deepening – Wonkish

The tendency of the rate of profit to fall (TRPF)[1]. Would I ever have imagined writing that some aspect of this classical theory was correct. 20+ years ago I was studying in Edinburgh and as a diversion from my own course and the tiny Edinburgh College of Art exhausted library I used to dust off their huge collection of heterodox economic books (well huge collection of everything) and became fascinated by the Sraffan/Neo-Ricardian writings then fashionable. Then I would have been totally convinced that the concept of the falling rate of profits had been completely and totally disproved – look at the maths – look at Okishio’s theorem[2] – its been totally disproved. I would, and did, argue it till the cows come home. It was to me an obvious fallacy.

Indeed most were convinced and indeed it seemed only the tankiest of tendencies still believed it (especially at my neighbours the University of Greenwich). Now coming back to an interest in the history of economics after a 20 year break I can see things from a new perspective. Just as heterodox economists apply ever more arguments about the root assumptions of neoclassical economics, those same assumptions can be applied to the criticisms and arguments over value theory, especially long run equilibrium as a basis for excluding study of disequilibrium price movements and investment decisions.

These doubts has promoted me to start this series to prompt argument and discussion about a number of puzzles over profit rates that an easily dismissal of TRPF leaves unexplored. I should stress i’m not here arguing that there is an inevitability of capitalist ‘breakdown’, rather there are structural aspects of capitalism, that unless corrected by political action lead to crisis and depression, and these need to be corrected to address our current condition. Nor am I arguing for a labour theory of value (LTV) at least in its pure pysicalist form of value been hammered into goods – though I will argue that there are interesting puzzles there too which mean that until they are addressed the theory won’t go away.

A Bias Towards Capital Deepening

This first part is about a core assumption in TRPF that there is a bias towards labour saving technology. The theory, at least in Marx’s form, requires there to be a bias that capital deepening techniques are chosen over capital shallowing techniques. Capital deepening being more intensive of fixed capital – mechanisation etc. Capital swallowing being choosing techniques more intensive of ‘variable capital’ in Marx’s term – expenditure on labour.

A very frequent argument made in too many books and articles to mention is that Marx did not prove that Capitalism has an inbuilt bias towards capital deepening. He did not, very little about this in his writings, again numerous Marxian authors claim that there is a bias and Marx’s approach proves it. Hence

Argument I

If a capitalist introduces a capital deepening technique which is more productive and hence more profitable then other capitalists will be forced to adopt it, if not then capital will flow from that sector.

However that immediately begs a retort

Argument II

If a capitalist introduces a capital shallowing[3] technique which is more productive and hence more profitable then other capitalists will be forced to adopt it, if not then capital will flow from that sector.

Indeed argument II might also seem to have Marx on its side. After all if labour is immiserated wont it then become cheaper forcing a switch from capital intensive production, won’t some form of dynamic equilibrium be reached below which the rate of profit will not fall?

Before getting too deeply into the maths of this in future instalments I want to try to show in simple non mathematical terms why in most areas in most circumstances there is a clear bias under capitalism for capital deepening.

The Stick Houses

A couple of years ago I was working in the Middle East. Though the construction boom had ended there was still a lot going on. ‘Stick houses’ as they are known were being built everywhere. That is housing made from encasing concrete around steel ‘sticks’ that stick up until the roof is formed at the end of construction. What was interesting was just how labour intensive it was (and also how appalling labour conditions were with labour camps in the desert with no water of electricity- astonishing). You often saw several poor guys mixing concrete by hand in a big tub rather than using a mixer for example. I used to discuss this with the chief economist of the country. His explanation for it – Dutch Disease – that oil/resource rich countries get lazy and stop innovating. This seemed only a partial explanation to me, after all hadn’t the concrete mixer been invented, and would not richness sometimes express itself in overly expensive capital toys (which it sometimes did in State or State guaranteed monopoly projects)? After all it was rational for construction countries to substitute labour for capital because it was more profitable.

Only yesterday I thought about this when contemplating this series of articles. The answer was obvious. In most countries you tend to get capital widening because very cheap labour is not available and is not allowed to be imported, in some countries it is available and is allowed to be imported. It is the exception that proves the general rule.

Lets take our hypothetical concrete mixer example and a potential investment decision by a capitalist. Ok this mixer is five (say) times more productive than a single builder – but requires one man to load. So in a single year it will produce 5-1=4 man years worth of concrete. If I spent $1000 dollars on purchasing it I need to decide whether or not at the current rate of interest it will produce more in terms of profit than the wages of the 4 workers – the opportunity cost – over the period of the loan. If the payback period on the loan (assuming interest and all other costs remain equal) is less than the period of the loan then every day past the payback period you are in profit.

But consider the inverse calculation replacing the mixer by hiring additional workers?

The calculation is exactly the same, apart from asset resale value, which if labour is cheaper and export of the asset expensive would be zero (or even have a negative price – scrappage cost), the only other difference being that you are purchasing workers for the investment period rather than capital.

Investment as units of Labour

This was an easy case because capital and labour were perfects substitutes. Where they are though you can see from the above example that investment decisions are made in terms of units of wages, or rather bundles of wages goods needed to support the labourer. This is very Keynesian (though Keynes theories on wages have been sadly neglected) but actually the idea goes way back to the foundation of classical economics – Petty and Cantillon[4] and the formulation of this concept by Cantilon has never been bettered.

I.III.1    To whatever cultivation Land is put… the Farmers or Labourers who carry on the work must live near at hand; otherwise the time taken in going to their Fields and returning to their Houses would take up too much of the day. Hence the necessity for Villages established in all the country and cultivated Land…The size of a Village is naturally proportioned in number of inhabitants to what the Land dependent on it requires for daily work

I.XII.6… if we examine the Means by which an Inhabitant is supported it will always appear in returning back to the Fountain-Head, that these Means arise from the Land of the Proprietor either in the two thirds reserved by the Farmer, or the one third which remains to the Landlord.

The relevance of these sections is not obvious at first but there is the fountainhead of the concept of surplus and value theory as it influenced the Pysiocrats, and which Adam Smith (over) simplified to Labour only and then Marx followed.

What we see here as Aspromourgos sets out in his magnificent survey of classical economics before Smith[5] is a simple formula. Put in a slightly different way in plain English

Village Population P = M farmers

Food production F= M x Number of Fields L x productivity/fertility of each field/farmer p

Proprietors Profit = Rent R – (M*F/consumption per farmer C)

Closing the system of equations requires more than one village and a treatment of differential rent and transport costs which is a tiny bit outside the main thrust of this article, the key issue is that profit can be seen in terms of a numeraire of wages goods, that rent is a deduction from profit and that a surplus over the subsistence needs of labour is always needed to generate a profit.

This concept of a population centre being only able to support a given degree of wage goods, with or without trade, is critical.

Back to the Concrete Mixer

So lets imagine a case – such as in England today – where it would be difficult to substitute a concrete mixer for 4 men? Why – because labour is relatively expensive to capital? Why, because if you took the value that might be generated by the concrete mixer and divided that by four the real wage might be less than the cost of wage goods needed to support that worker. Indeed the more productive fixed capital becomes the lower real wages have to be to see capital shallowing.

So why don’t we see floods of very cheap labour from the third world to substitute capital for labour – after all it could be profitable for capitalists? Two reasons, one food is expensive here, which pushes up the price of the real wage. Secondly it would be politically unacceptable. Finally when capital is highly productive then is requires very large numbers of labourers to substitute and this requires at times of rapid growth huge levels of in-migration. The housing etc for these cannot all be produced at the rate capital might wish to expand (the George/Hoyt theorem). The capitalist space economy therefore has an inbuilt capital deepening bias in ‘advanced’ economies.

Consider the other case of capital shallowing. Here we have in the Middle East a source of cheap labour close by, no democratic pressure to control immigration per se, expansion of the workforce through packing them in quickly, and cheap food imports nearby from India. A perfect combination of circumstances for capital shallowing. Indeed in some middle eastern countries the number of guest workers (without any rights) can be as high as 90%.

Lets leave aside world system aspects to this argument and look at Capital Intensive Economies, that is in the construction and manufacturing sectors. Here there are local housing and labour markets, so that if the increase in labour from inmigration is fixed – so that the investment horizon possibilities are constrained locally – then investment decisions will clearly be further and further biased over time towards capital deepening, as the alternative – capital shallowing, get proportionately more and more expensive.

So if TRPF is correct then in these regions the conditions for a falling rate of profit definitely will exist. The assumption here is that wages are a fixed cost under a long term contract and so less buffeted by current labour market conditions, not that unrealistic, especially when labour is imported from elsewhere.

Neither have we considered changes to the interest rate and the phenomenon of reverse capital deepening – where a lower (higher) rate of interest produces a lower (higher) capital per worker. Although with this model it is easy to see that if interest rates rise it may still be more profitable to hire more workers at higher wages if the payback period is long, for imported labour you only need credit during the period of production, whereas for fixed capital you typically buy it for its lifespan.

Of course its more complicated than that –we have only looked so far at a vertically integrated concrete economy with one consumer good and one wage good –  onto part two in a few days.


1.    Marx, K., Capital. 2001: Electric Book.

2.    Rieu, D.-M., Has the Okishio Theorem Been Refuted? Metroeconomica, Vol. 60, Issue 1, pp. 162-178, February 2009.


SHALLOWING OF THE 1990s. Estudios de Economía, 2002. 29(1): p. 35-45.

4.    Cantillon, R., Essay on the Nature of Commerce in General. 1931: Transaction Publishers.

5.    Aspromourgos, T., On the Origins of Classical Economics: Distribution and Value from William Petty to Adam Smith. 1996: Routledge.

My Letter to the BANE Inspector on Larger than Local Planning #NPPF

Bath and North East Somerset Council
Local Development Framework
Examination of Core Strategy DPD
Mr Simon James Emerson BSc DipTP MRTPI

Dear Sir

Bath and North East Somerset Council Local Development Framework Core StrategyRevised Post NPPF Soundness Tests

I am writing because of the implications of the publication of the National Planning Policy Framework on proceedings.

I note that the inspector has written to parties asking for comments on the implications of this publication and that of the Travellers policy statement.

It is surprising though that the note ID47 did not specifically refer to the new ‘positively prepared’ soundness test, and the major change to the effectiveness test, and ask for comments on implications, though it did ask for comments concerning housing.

The issue of the ‘Duty to Cooperate’ was raised during the Examination and the PINS legal advice – that it is not retrospective  (though challenged) was raised.  However there is now general consensus in planning that the Localism Act Duty is quite different from the soundness tests relating to larger than local planning.

The issue being that the duty relates to process at the time the time the plan was being prepared, whilst the soundness tests apply to outcomes at the time of your decision over the prospective plan period.

May I refer firstly to new PAS Guidance and advice from a senior inspector issued at an RTPI event this week both of which make this point very clearly.

Though the implications of cooperation/non co-operation were of course discussed during hearing a key aspect of the NPPF is that it is read as a whole (paras 6 and 14).  So it is not until the final version is out that one can fully assess the impacts of the new policy on each of the soundness tests including the new test (para 182).  For example larger than local issues don’t only effect the ‘positively prepared’ test but also in terms of justification of strategic based on proportionate evidence of that impact & effectiveness ‘based on effective joint working on cross-boundary strategic priorities‘ – as well as of course consistency with national policy (the NPPF as a whole).

I do not represent clients at this examination however as this is very like to be the first examination to conclude post NPPF it may very well be seen as a precedent and may very likely be subject to legal challenge.  Therefore I am writing solely to ensure that the process is not derailed by avoidable challenge and that other authorities learn appropriate lessons from the outcome.

I would advise then that parties be given opportunity to comment on the implications of the revised soundness tests and if necessary an additional hearing held. If this matter has already been considered and dealt with you in another way I apologise.

Yours Faithfully

Andrew Lainton
Cutting Edge Planning and Design
18 Bailey House London
SE18 4GD

The Commons #NPPF Debate Second Half ‘Labour – Not Fit for Purpose’

Hansard here

I think someone has been reading this website ‘paper thin’ etc.

Roberta Blackman-Woods 

On Tuesday night, the Minister sought to sell the NPPF in his usual erudite way. However, surely even he does not believe that everything is rosy in the NPPF garden. A number of challenges remain for the planning system, despite the many amendments to the draft framework…

the question today is whether the NPPF, as a blueprint for planning policy, is truly fit for purpose. The answer is definitely not. I will outline for the Minister some weaknesses that remain in the document. Given the immense criticism of his first attempt, the significant redrafting that followed and the remaining weaknesses, it is clear that the process of reform, taken as a whole, was shambolic even by the Government’s standards of incompetence.

First, the Minister has made much of strengthening the definition of sustainable development…, it is not clear how local authorities will apply that definition in practice when they determine planning applications. Paragraphs 8 and 10 of the NPPF are rather woolly, even by the Minister’s standards.

Secondly, much has also been made of the strengthening in the final version of the requirement for development to happen on brownfield land first. Since its publication, however, many have described the assurances on the subject as “paper-thin”. The NPPF only expects authorities to “encourage” development on brownfield land first. That is significantly weaker than the Labour policy of development being prioritised on brownfield sites. Nor is it clear what will happen if authorities do not encourage the development of brownfield land first, or whether they will have to apply any sequential tests or produce any evidence in that regard.

Thirdly, the existence of transitional arrangements is welcome, but two major issues remain. The first is that most commentators do not consider one year long enough for local authorities to get their plans up to speed. The second is that the announcement on guidance has created more of the unwelcome confusion that has characterised the whole review of planning policy. The Minister announced that all guidance in planning policy guidance notes and planning policy statements was being abolished, then he said it was not, and now he says it is being reviewed. Which is it? I would appreciate an answer from him. Further clarity on the status of the guidance would be most welcome.

Now for the key question that the Select Committee on Communities and Local Government posed in its excellent report on the NPPF…That question was whether the brevity of the NPPF had created greater clarity. The Minister must accept that the answer of planners is a resounding no. A recent survey of town planners revealed that 86% believed the NPPF would lead to more appeals because of the lack of certainty in the planning system and the vagueness of much of its language. No wonder that many are calling it a planning lawyer’s dream….We are saying that brevity should have led to clear language, but it has often led to obscure language, which will make it equally difficult for local communities and planners to argue a clear case….far from increasing the power of communities, which has been much championed by the Minister, the NPPF could lead to even more decisions being made by the Planning Inspectorate, which is removed from local communities…

Lastly, I come to the duty to co-operate. As the Minister will be well aware, there is growing concern that England does not have a national spatial plan, and that planning beyond the local authority level will be very difficult. Yet strategic issues, such as housing, transport, waste and energy, often need to be taken beyond that level. The Minister will claim that the duty to co-operate addresses this issue, but it is totally unclear what will happen if the co-operation fails or never takes place.

When taken together, all of the above shows that despite the changes made to the NPPF there are still a number of concerns—and the above list is by no means exhaustive. I could continue with examples, such as how, despite the Minister’s reinstatement of Labour’s successful “town centre first” policy, the lack of guidance continues, or the changes to the assessment of housing need, for which the definition has been improved but the method of implementation is again absent.

We will continue to monitor what is happening in practice. If the NPPF is stalling the growth in jobs and housing that we so desperately need, and failing to protect the environment that we all love, we will say so. Cutting pages from our planning guidance is no substitute for a proper economic policy focused on growth, and that is what we need the NPPF to deliver.

Clive Betts

The test of this document is not whether it is better than the first draft but whether it is better than the existing guidance that has been in operation up to now. The test is also whether it delivers better planning for communities and individuals, and for developers as well, because they are important in creating homes and jobs. What test do the Government want to apply to judge the success of the system? Is it a requirement to meet the Housing Minister’s target to build more housing in this country than we were building before the recession? Is it a requirement to ensure that we develop enough renewable energy projects to hit our climate change targets? I assume that those are the Government’s objectives. However, during our discussions on this matter, in the debate on the initial draft and in the comments on the Minister’s statement, an awful lot of Members on the Government Benches seemed to be saying, “We want a planning system that stops development in our areas.” .. How, in the end, does a planning system relate all the individual local decisions and wishes of local communities to the Government’s national targets to deal with climate change and house the people of this country?  I thought the hon. Member for Daventry (Chris Heaton-Harris) might respond to that question.

Chris Heaton-Harris: As a former Member of the European Parliament I can remember the directive that we passed, but it does not tell a country how to achieve its renewable energy targets by specifying which sectors it should promote; it simply sets a target, and there is an implication to hit it. Allowing local people to choose which types of renewable energy they would like to see in their local community would bring on more renewable energy projects, not fewer.

[Lots of giant dams instead of windfarms in Daventry then?]

Clive Betts: 

Ministers and Government Members need to accept that, however much they welcome the changes they have brought in, any change in the planning system will almost certainly lead to uncertainty and cause an initial slowdown in decision making. That is almost inevitable, so we should not be surprised if things do not go smoothly at first. Almost certainly, too, there will be unintended consequences from what they are putting forward. There will be misreading of the wording; inspectors will come to decisions on appeal that do not conform with the Minister’s aspirations; judicial reviews will reach different conclusions from those Ministers, local MPs or local councils might want. At some point, the Minister will have to put in place a review system and perhaps bring in some changes, simply to take account in practice of those sorts of issues. This is a technical  issue, but it could be crucial to how the system works. In the end, how it works in practice rather than what it says on a piece of paper is what will count.

“For 12 months from the day of publication, decision-takers may continue to give full weight to relevant policies adopted since 2004 even if there is a limited degree of conflict with this Framework.”What does a “limited degree of conflict” mean? There is an awful lot of room for an awful lot of lawyers to argue about that and make quite a bit of money. In the next paragraph, it states that

“after this 12-month period, due weight should be given to relevant policies and existing plans according to their degree of consistency with this framework”.

What does “degree of consistency” with the framework mean? Ministers may think they know what it means, but lawyers may have a different view and two lawyers may have two different views, and that can lead to an awful lot of expense, delay and, perhaps, the wrong decisions.

If  local plans are to be at the heart of the process, it is ridiculous that we should be dealing with plans many of which are 20 years old. That is not acceptable. We must find a way of bringing those plans up to date more rapidly. I do not know whether the system of local development frameworks, strategies and site allocation plans is too complicated to provide the necessary flexibility, but the Select Committee may wish to return to the issue, and the Government may wish to work along with us in exploring the technical issues further.

If local plans are to be at the heart of the process, it is ridiculous that we should be dealing with plans many of which are 20 years old. That is not acceptable. We must find a way of bringing those plans up to date more rapidly. I do not know whether the system of local development frameworks, strategies and site allocation plans is too complicated to provide the necessary flexibility, but the Select Committee may wish to return to the issue, and the Government may wish to work along with us in exploring the technical issues further.

Tristram Hunt

changes need to be managed properly. In that context, what we hoped for from the Government was a considered and rational strategy for planning reforms to safeguard our great towns, cities and countryside, while ensuring economic growth. Instead, Instead,  what we received was a botched draft planning policy framework, complete with ugly denunciations of such great English institutions as the National Trust and the Campaign to Protect Rural England, and of anyone else who dared to question the Government’s damaging proposals. We expected more from the Minister.

We now have the finished document, and I am happy to support some of the major U-turns the Government have adopted, such as the explicit recognition of the value of the countryside as a whole; the strengthened protection for the green belt; and the more balanced, if still ambiguous, definition of “sustainable development”. Those are all to the good, but there are some worrying omissions.

It is …worrying that the final draft of the NPPF talks only of “encouraging” the effective use of brownfield land, rather than, as Labour did, “prioritising” it. That does not amount to a robust “brownfield first” policy and is a weakening of the guidance in previous regulation. Hon. Members who are concerned about their towns and city centres would do well to reflect on that: an encouragement is not an obligation. As a result, and with no explicit brownfield development targets, there will be serious scope for legal battle involving developers, who will appeal to sections of the NPPF that emphasise economic viability and deliverability over sustainable brownfield development. That is all the more frustrating given that there are almost 62,000 hectares of brownfield or previously developed land in England ready for building on…

All of this debate points to a broader truth: the Government are underwritten by an ideological aversion to state regulation. Because of the monstrous failure of their economic policy, sadly revealed this week with a double-dip recession made in Downing street and £150 billion of extra borrowing, they have been thrashing round for excuses for economic decline. The Treasury stumbled on the idea that planning was stopping growth, but we know that good planning is no impediment to growth. Poor planning and a lack of planning as in Ireland and Spain have not resulted in the kind of economic growth that we would like. The Government would be better advised to devise a decent strategy for sustainable economic growth, rather than blame the planning system.

Mr Nick Raynsford (Greenwich and Woolwich) (Lab):

The ultimate test of the NPPF will be the outcomes it delivers, not the remarks made by people who were so relieved that the latest draft was less bad than its predecessor that they provided those quotes that the Minister enjoyed giving us the other evening.

Two days ago, the Minister of State sought to deny the disastrous state of house building in Britain, which has been seriously aggravated by the uncertainty and confusion that have existed since the Government began to tinker with the planning system in summer 2010.

The Minister claimed that there has been a 25% recovery in housing since the recession. Let us look at those figures. He is right in that there has been a recovery from the depths of the recession. What he needs to bear in mind is the fact that that recovery took place throughout 2009 and in the first six months of 2010….the Minister for Housing and Local Government…shows a certain levity with regard to his respect for the truthfulness of statistics.

Jack Dromey (Birmingham, Erdington) (Lab):

On Tuesday, the Chamber resounded to paeans of praise to the Minister from the Minister. It would be churlish not to acknowledge that a decent man with an open mind has listened to the powerful case that was made by Labour, the countryside, heritage representatives, the business community and the Select Committees.

There have been moves on brownfield development, albeit that they do not go far enough.

In our debates on the Localism Act 2010, the Minister of State, Department for Communities and Local Government, the right hon. Member for Tunbridge Wells (Greg Clark) listened and acknowledged that we needed “larger than local” decisions. He could not use the phrases “regional” or “sub-regional” because he would have been sat upon by the Secretary of State. Nevertheless, moves there were.

…Concerns remain about how the NPPF will work at the worst possible time, and significant weaknesses remain within it….

The planning system was not the problem that the Prime Minister pretended it was. It was preposterous of him to stand at the Dispatch Box and say that the problem with housing was the planning system. It was nothing of the kind. Planning applications were overwhelmingly granted speedily and there was development land with planning permission sufficient to build 300,000 homes. The fact that homes are not being built is nothing to do with the planning system; the principal problem is the failed economic and housing policies of this Government.

This has been a master class in how not to conduct a debate, with polarisation and the demonising of critics….

I have acknowledged that progress has been made. I will now turn to the problems. There is no vision for England—no spatial plan that brings together housing, economic development and infrastructure to ensure that if there is growth, all parts of England will grow.

There are no longer any strategic planning mechanisms capable of dealing with the problems that exist. I will give one example. Stevenage badly needs to build thousands of homes, but it cannot meet the demand in Stevenage. It will have to build outwith Stevenage in Hertfordshire. The chances of Hertfordshire co-operating with Stevenage to ensure that its housing need is met are remote in the extreme.

We now see in the NPPF the potential downgrading of the importance of affordable housing. The Wolfson paragraph, as I have come to call paragraph 173, allows affordable housing to be traded off in the development process. Lord Wolfson complained on “Newsnight” about how a friend of his, a developer, hoped to develop a major site in Clerkenwell but was unable so to do because the council insisted on affordable housing. The council was absolutely right to do so, and it is wrong to downgrade its importance in development.

Labour, as the champion of the countryside and the green belt, strongly believes in a brownfield-first presumption. On the subject of housing and more generally, our fear is that the planning system will be thrown into chaos at the worst possible time. Growth is key, but all the predictions from all those to whom we talk suggest that we run the risk of hiatus, confusion and planning by appeal

The Communities and Local Government Committee was right to say that brevity is not necessarily clarity. I am surprised that among the tributes read out on Tuesday there was not one from planning lawyers, because Ministers are the toast of planning lawyers. They believe that homes will be built as a consequence of the new NPPF, but they will be homes in Marbella—second homes for planning lawyers who make a killing on the back of the confusion and uncertainty that the Government are creating.

Andrew Stunnell

 It has taken the mystification out of the planning process and means for the first time that ordinary members of the public have a realistic chance of understanding the decisions that are taken around about them, and of playing an active part in those decision-making processes without the need first to resort to people with two degrees in planning….

It is also right—this was reflected in the debate—that the planning process is not about creating a fictitious Disney World; it is about resolving tensions, and competing interests and goods. Hon. Members have acknowledged that we neither have the free-for-all, wild west scenario that some of our sternest critics predicted in July last year, nor are we retaining the top-down, lock-down alienating system we inherited in 2010. This balanced document is part of a balanced framework….

What we maintain is that there is clear evidence that when local communities are put in the driving seat they fully understand the need for homes and jobs for their children and grandchildren, as well as parks and recreation spaces.

The transition arrangements have been agreed with the Local Government Association, so it is somewhat petulant for it to complain. It is also absurd for it to complain that this document contains obscure language, when it is responsible for the 1,000 pages and obscure and impenetrable language, which only people with PhDs in planning can understand, of the planning policy guidance document.