Letwin, Land Pooling and Homes England Assembly of Strategic Sites

Land Value Capture was a major theme of 2018, culminating in the Letwin review which the government isdue to respond to in Feb 2019.

The nature of the likely response is already given in the response to the MHLG Select Committee report on land value capture

Through the Housing and Planning Act 2016 and Neighbourhood Planning Act 2017,
the Government has recently taken forward wide-ranging reforms to make the compulsory purchase process clearer, fairer and faster for all. These reforms include extensive changes to the Land Compensation Act 1961. We are keen to let these recent reforms bed in but will continue to monitor their practical application and remain open to considering practical improvements to the framework. The Committee will be aware that the Rt Hon Sir Oliver Letwin has published his independent review of build out alongside Autumn Budget 2018. …The government will respond to Sir Oliver’s report in February 2019.

[those being CPO’d] are entitled to the market valueof the land to be acquired
, disregarding any increase or decrease in value caused by the ‘scheme’ (e.g. regeneration project, new settlement, trunk road etc) underlying the acquiring
authority’s Compulsory Purchase Order – or the prospect of that scheme. This is known as the ‘no scheme principle’, which was codified through changes in the Neighbourhood Planning Act 2017 which came into force in September 2017. The basic premise is that compensation should reflect what the land or property would be worth on the open market if the scheme to which the Compulsory Purchase Order relates did not exist (i.e. in the ‘no-scheme world’).
Compensation includes ‘hope value’ (i.e. value based on the land’s development potential) only insofar as it can be demonstrated to exist in that no-scheme world. The extent of this hope value will reflect the prospects of obtaining planning permission for an alternative development in the absence of the scheme, taking into account the risks, uncertainties and costs associated with implementing such a development. This includes the costs of providing the affordable housing, infrastructure and supporting facilities required to make the development acceptable in planning terms, as well as any Community Infrastructure Levy liability…. If land is acquired by a new town development corporation, compensation would be assessed in accordance with the no-scheme principle .
…If there are limited prospects of the relevant land being developed in the absence of the designated new town, the market value is likely to be the same as or close to existing use value.

All the Neighbourhood Planning Act 2017 did on this point was consolidate the caselaw regarding the ‘Point Gourde’ principle, that the ‘no scheme world’ was the value without the roads and infrastructure making the site developable in the first instance.

Therefore forget for strategic sites the land compensation act 1961, as the market value for compensation purposes is simply existing use value plus the level of ‘compensation’ dictated by caselaw on the ECHR.  Therefore primary legislation would not be needed to implement Letwin, who in any event recommended compensation recommended valuation at the bottom end of the 10-20x agricultural value embodied in current practice by the Harmen Report.

There is no need to rehearse the potential advantage soft land value capture here to further housebuilding through funding infrastructure and affordable housing.  The issue is whether landowners will take seriously a regime where the official value of there land is reduced by millions of pounds an acre and whether they will simply without their land, as the owners of the North Essex Garden Communities have, daring public authorities to acquire land compulsorily.  The risk is a regime that doesn’t offer some share in uplift to landowners will fail, as it has before, with authorities with little appetite or expertise in land acquisition to accept instead ‘leapfrog’ sites, sub optimal sites in terms of accessibility which don’t require assembly.  After all this was the problem with the implementation of the Uthwatt report regime and is very much the problem is many Asian and African cities where there is scattered and fragmented land ownership around major cities often leading to large scale leapfrog development to unsustainable locations.

The plea here is for a policy of pragmatism, not going for a policy on land value capture which leaves insufficient share of the cake for landowners so that strategic assembly is thwarted.  An appeal for pragmatism must be based on proposals that have been shown to work, and what has been shown to work is land pooling.

Land pooling, in some countries also known as land readjustment,  was an approach first implemented in German Planning Law

its origins are in Germany and are often attributed to the 1902 Lex Adickes of Frankfort-am-Main. This city’s expansion was hindered by ancient
inheritance laws, which created long, narrow strips of land difficult to convert for development. The mayor of the city, Franz Adickes, steered enabling legislation through the Prussian Parliament, the application of which was extended by the Prussian Housing Act 1918

and then adopted in Japan, and now widely copied throughout South east Asia and increasingly India as an alternative to large scale land appropriation.  It works as follows.  The land is subdividided by a public authority and land owners get back a smaller proportion of the land which recognises both the land needed to build roads, public spaces, community facilities and affordable housing and the sale of plots necessary to fund this enabling infrastructure.  There is a wide spectrum of type of pooling ranging from the voluntary to those facilitated by compulsory acquisition powers, from those where the landowners get back the bulk of land to those where they get back a smaller part but one of much higher value.  I have seen it successfully applied in several countries and its success in wide;y different cultures suggests to me that it is an idea begging to be tried.

There are several major advantages

  • It gives landowners an incentive to cooperate
  • Public authorities don’t need financing for the compensation, just grant of title back
  • It leads to more orderly development of strategic sites subdivided into smaller ones, sites that are more accessible without ‘leapfrogging’ and easier to service.
  • Landowners don’t need to forward fund the enabling infrastructure.
  • It created subdivided parcels with multiple landowners and potential developers, just what we want to see in oligopolistic markets such as England.

In England I suggest a very simple rule, land owners get back 1/4 of the area of sellable plots (not withstanding final land use) following subdivision and allocation for roads, parks and community facilities.  This would not be too dissimilar to the position that existing in case law and statute (dating back to the 16th century) prior to the 48 Act.  International experience suggests this is sufficient to enable most strategic sites to come forward with voluntary pooling in the large majority of cases.

A great example is the new Capital of the state of Andhra Pradesh Amaravati. It had an (admittedly dreadful) masterplan by Fosters, just the sought of plan which gives imperialistic planning of sites without seemingly visited the sites and imposing a geometry on it (ignoring even the flow of gravity of water to the adjoining river, and as originally planned without any public transport and giant squares with ridiculously pompously public buildings) but that aside it needed to be implemented over the top of a landowners pattern which gave typically a couple of dozen plots per superblock.  It could have used compulsory means but there heavy handed use had fallen into disfavour as farmers fought for grater compensation and against forced dispossession.

Out of the 24 villages approached to give up their land, 22 agreed within four months
of the scheme’s announcement. Following this, the returnable land plots were allocated through electronic lotteries for fairness.
These lotteries were held at the villages, with landowners receiving confirmation of their plot allocation via mobile message. Their plot allotment letters were also printed and handed out to them immediately, with softcopies made available online.

Within just 60 days of implementation, the government managed to persuade 25,000 farmers to give up 30,000 acres of land….To secure land necessary for Amaravati’s development, the state is moving to invoke the Land Acquisition Act, where
the villagers will be required by law to give up their land in return for
monetary compensation. These pockets of resistance, however, are small in comparison to the majority support, with nearly 90% of the required land already secured through land pooling.

The compensatory plots were around 1/4 of the original land.  My suggestion of 1/4 sellable reflects the higher ‘exaction’ for community facilities and public open space necessary in English Masterplans.

What would be needed to make this work in England?  Not a lot as it could be done initially on a voluntary basis with conventional CPO used a a fallback.  In the long-term though regulations would help, as part of a wider much needed powers for masterplanning and subdivision of land, to help resolve disputes bout the size and value of reallocated plots,.  Here there is a wealth of experience of such regulations around the world, indeed many land readjustment systems such as Japan were simply verbatim translations of the German law.

The government is faced with how to implement the potentially hugely complicated Letwin system.  Land readjustment based on an internationally tested systems of land assembly and subdivision offer a pragmatic way forward, and Housing England a potential body with the funding and expertise to do it, initially on a voluntary and experimental basis.  So far there is a lack of potential sites in development plans of Garden Community or Strategic growth location scale, but that will change and by the end of 2019 there should be several in development plans that offer great potential.

Proposed Rail Reopenings are ‘Confidential’ – Sky


The Department for Transport has confirmed it is actively working with a number of groups to explore the possibility of reopening old rail routes, axed under the so-called Beeching cuts of the 1960s.

It follows a call by Transport Secretary Chris Grayling a year ago, encouraging those in the public and private sector to submit proposals for potential projects to regenerate old lines.

The announcement will give fresh hope to dozens of campaign groups across the UK, who are still fighting to restore services cut more than half a century ago.

A spokesman for the Department for Transport told Sky News: “We are continuing to grow the rail network to deliver improvements for passengers, unlock new housing and support the economy, including by exploring opportunities to restore previously lost capacity.

“We have received a wide variety of proposals to enhance the railway from across the public and private sector, and are working with promoters to explore opportunities to re-open routes cut under Beeching.

“This is on top of exploring reopening the Northumberland Line for passenger use, supporting the reinstatement of stations on the Camp Hill Line, developing new rail links to Heathrow and a new station at Cambridge South.”

The spokesman said that due to the confidentiality issues around its market-led approach, the department was not yet in a position to release details of the proposed projects, but hoped to be able to provide more information in the year ahead.

South Oxfordshire Agrees Local Plan with ‘Green Belt Cherries’

Oxford Mail

PROPOSALS to build thousands of homes on Oxford’s Green Belt have taken a step closer after councillors finally accepted a controversial plan.

South Oxfordshire District Council voted to accept its Local Plan on Thursday, after another was rejected in March.

It wants to allocate seven sites for the building of thousands of homes but six of them currently lie in Oxford’s Green Belt.

The plan includes Grenoble Road, which Oxford City Council has wanted to build on for more than two decades. It owns part of the land, along with Magdalen College, Oxford and Thames Water.

About 1,700 homes could be built there, along with the city council-supported South Oxford Science Village.

Some Conservative councillors were scathing over their council’s plan. Elaine Hornsby, who represents Wallingford, said her ‘heart will bleed for rural Oxfordshire’ as it was passed.

As a result of it, 28,500 new homes will be built in the district by 2034.

While Sue Lawson, who represents Sandford and the Wittenhams, said she was ‘disappointed and saddened’ by the inclusion of so many Green Belt sites.

Prime Minister Theresa May said in March that ‘tearing up’ the Green Belt was an inadequate way of dealing with planning pressures.

But SODC’s leader Jane Murphy and its member for planning Felix Bloomfield insisted the plan was more legally ‘robust’ than the one rejected earlier this year.

Yet John Walsh, a former deputy leader of the council, said submitting the ‘very, very hurried’ plan would be ‘embarrassing’ and would be halted by an independent planning inspector next year.

Other projects close to the city council’s boundary with South Oxfordshire passed in the plan include Bayswater Brook, to the east of Oxford, and Northfield, close to the Mini factory. A total of 2,900 homes could be built there.

Some councillors said they were in favour of the Local Plan because it would be supported by ‘silent majority’ of residents, many of whom will be able to buy a new home.

Mr Bloomfield added: “This is a plan that will help South Oxfordshire continue to thrive and prosper – it’s not just about housing although it will bring many much-needed affordable homes, it is also about high-quality, well-paid jobs; it’s about shops, leisure and local green spaces; it’s about all the facilities needed to support thriving communities.”

In total, 22 councillors voted to accept the Local Plan; nine were opposed. They included former leader John Cotton, who said the proposal was the same as March’s – but with controversial ‘Green Belt cherries all over it’.

Public consultation opens on January 7

The Local Authority Skills Gap and the Post-Letwin Master Developer role

EGI has an interesting take from Alex Robinson of Grosvenonr

The last quarter of 2018 has seen a significant shift in housing policy, with the Letwin Review’s final report and Homes England’s five-year strategy signalling an important change of focus for future housing delivery.

Both Letwin and Homes England’s papers contain much that the development industry can get behind, from unlocking and enabling land through to infrastructure investment and removing obstacles for smaller housebuilders to play a larger role in delivery.

But there are also things that will ruffle feathers, including proposals to cap residual land values for large sites. Here, in particular, a more nuanced conversation needs to be had to ensure this approach results in more new homes and drives diversity of housing tenures, without discouraging landowners from putting forward their land for development.

The main change of direction, however, comes around who is best placed to deliver new homes: the private or the public sector. Letwin proposes that local authorities take on a master developer role, but many lack the skills and resource to do so. The private sector, on the other hand, is already deploying this model and is well placed to plug the gap.

We should not underestimate what a departure Letwin’s report is for a Conservative government, especially its emphasis on local authority delivery. For the first time in decades, the proposed use of local development corporations or infrastructure development companies challenges accepted wisdom around who should take the lead in unlocking sites and driving development.

Inevitably, this is not as straightforward as it seems. We should welcome local authorities taking a more direct approach, but right now few have the resources and expertise to perform the master developer role required for local development corporations and infrastructure development companies to be effective.

Over time, skills and experience will build within local authority teams, but in the interim we cannot afford to lose momentum on housing delivery

By pooling local authorities’ and developers’ complementary skills, we will be in a much stronger position to reach the target of 300,000 new homes a year.

In contrast to local authorities, private developers have been fulfilling the master developer role for a number of years – with positive results. Rather than seeking to reinvent the wheel by shifting this burden of responsibility, local authorities should work with developers, drawing on their knowledge and funding to build capacity in the public sector…

The master developer model works because it combines private funding and development expertise with councils’ detailed knowledge of what communities want and need, both now and in the future. It allows partners to build strong ties with existing communities so that they benefit from associated infrastructure and amenity improvements. Ultimately, this approach aligns with the principles of Letwin and Homes England’s strategy, but recognises that meeting their ambitions doesn’t have to rely on local authorities taking sole responsibility for delivery.

Reaching the government’s annual homes target is no easy task and Letwin is right to call for a change in direction.

However, the public sector cannot realistically take on a master developer role in the short term. In comparison, private developers are already adept at doing this, although we acknowledge that it is not always the norm for them to follow this model.

This is a very important point.  You should not underestimate what  cultural shift needed for local authorities to shift toward positive delivery of large sites.  Current local governments skills and processes are base around regulation, written policy, risk management and protecting local political consequences from negative publicity on controversial issues.  They are not based on running PMOs, design management, proactive investment and cash-flow management .  Often  whole generation of senior local government officers have not built or designed anything and capital projects are often designed and managed through frameworks agreements.  Those skilled at writing local plans are often not skilled in disciplines necessary for masterplaning and delivery of large scale communities.   It also requires a different approach, more interdisciplinary, commercially aware from the outset and more geared to interface management and management of design intent.  Mention design intent or interface management to 99% of English planners, at whatever level, you will get eyes glazed over.

But we shouldn’t expect either the private sector to necessarily have these skills.  Private sector led consortium’s  are rarely master developers.  The normal route is land promotion by land promoters and then sale to property developers.  Something as simple a new road to access a large site and the whole chain breaks.  Many large sites such as North of Horsham to take one example had laid fallow for a decade or more because of this gap in the way English Planning works.  Of course areas with development corporations have fared better.  For example South and West of Bedford the former local delivery body pieced together land from 25 landowners to secure the bypass opening up several large sites.  That was abolished and now Bedford has discounted a site to the South of Bedford in Marsden Vale for 6,000 because land assembly, reclamation and building the local distributor road was just too hard for the local planing authority (i suspect a tactical measure just to submit before the NPPF deadline, it will come back as part of the AECOM Arc vision report).

In terms of the appropriate role of the public and private sector a distinction needs to be made between the different phases of delivery and planning and the extent to which a coordinated approach exists between existing landowners.  In those cases where landowners have not come up with a framework to fund the masterplanning and division of costs and benefits from enabling infrastructure and final plots sales the public sector will need to take a lead in masterplanning and site subdivision.  In many cases local authorities will need support from private sector design and engineering companies, as well as Homes England.

When it comes to infrastructure delivery, site preparation and land sales local development corporations are widely recognised as a good model and it is likely that they will mostly recruit from the private sector.  There seems little case from this to be led by the private sector as the development corporations can operate framework agreements with the large engineering and property firms as they see fit.  With economies of scale many landowners and/or housebuillders who purchase large subdivided plots may see benefit on coordinating infrastructure and constriction contracts formally or informally setting up ‘master developer’ arrangements.

Overall the situation will be complex with only a small number of major property companies having strategic landownings, scale and funding to enable them to operate as master developer on large strategic sites.  In many cases Homes England will have to take a risk assessment about where the key gaps and risks lie on strategic sites and work with local authorities and landowners to put in place bespoke arrangements for masterplanning, and master development.

What has passed I think is the past assumption that the public sector is expected to only capture a small proportion of land value uplift and the primary risk and rewards for large site lie only withe landowners.  We are likley to see  shift to the model common on the continent where housebuilders operate more like utility operators rather than land speculators, with lower but shorter and less risky returns.


National Infrastructure Commission Concerned at ‘Freight Sprawl’

NIC interim report on freight

The forgotten element of spatial planning
Growing demand for faster, cheaper, and more convenient deliveries means planning for freight is ever more important. Delivery of new houses naturally remains the priority for local areas. Yet, whilst certain essential services required for balanced and sustainable communities – such as schools and medical centres – are planned for, freight is overlooked. National policy for planning and development has only two references to freight, and local authorities rarely have the resources or expertise to properly consider freight in their areas….

An absolute focus on increasing the supply of homes comes at the expense of a sustainable balance of land uses and supporting infrastructure. Gaps in planning
policy and guidance give planners little understanding of why and how to plan for freight, leaving the needs of the freight system far down the priority list. Over time, a lack of holistic, freight-aware decisions will erode the capacity of the freight system to deliver the goods that communities and businesses want and need in the most sustainable way possible.
The current approach to planning can mean that freight is forgotten in plans for new developments and, even where it is considered, it is not a holistic assessment. Often plans for new developments only reflect consideration of the final delivery of goods,
neglecting the fact that this is the result of the successful functioning of a whole supply chain, finely tuned and optimised, often spanning borough, county, and even national boundaries…

Sufficient storage and distribution capacity is needed for the freight system to work efficiently. There is evidence to show that there is an increasingly limited supply of land for storage and distribution operations in key markets, particularly the land required for last mile logistics in London. A recent report for the Greater London Authority (GLA) stated that there is a rapidly dwindling supply of warehousing space
in London, and that the present vacancy rate is four per cent,53 “by far the lowest rate of any region of the country.”54
Last mile logistics providers, such as parcel carriers or retailers and producers, need to be able to serve customers in urban areas quickly, often within short delivery windows. Providers therefore need space for final distribution operations in areas where their drive time to the end destination is minimal. In some places
the periphery of the urban area will do, but in London, and other large and densely developed towns and cities, a short drive time to customers means a need for space inside the urban area.
Demand for such space has increased at the same time as the supply has been actively reduced. A recent upsurge in demand for last mile logistics space in London (triggered by population growth, increasing e-commerce activity, and demand for faster delivery times and shorter delivery windows) has coincided with a period of the release of industrial land for non-industrial land uses – most often housing. This
was facilitated by a succession of pro-release policies in London planning policy. The limited supply of affordable, suitable premises in central locations means that logistics providers need to look further afield for the right solution. Some commentators have referred to this trend as ‘logistics sprawl’55 56 – logistics providers can no longer find affordable premises in central London and so ‘sprawl’ further and further from the centre, and then out of the city altogether. This increases a providers’ stem mileage (the distance from the distribution point to the first delivery address) – wasting a larger proportion of the journey distance, with knock-on effects for emissions, congestion, and operational efficiency.

Regional Evidence Bases and STBs A New Lingo for Regional Plannng in England


This is every bit as important as the NPPF for joint strategic plans as it sets down the new framework for appraisal, planning and funding of the scale of transport infrastructure necessary to support strategic scale growth locations.This demonstrates the further reg

The expectation is that investment in the major road network and other major road schemes that don’t form part of the strategic road network.  should be through ‘Sub National Transport Bodies’  either dedicated bodies, such as Transport for the North, or the formative Transport for teh Midlands, or joint groups such as England’s Economic Heartland.  This demonstrates the further ‘regionalisation’ of infrastructure in England.  If you arn’t yet part of an STB (think Kent , Essex or Yorkshire,- cities or Greater) you will be at the back of the queue.  Local authorities will be expected to organise themselves and prioritise schemes.

Sadly the funding and planning of roads is separate from rail and rapid transit (which still has no formal funding or bidding process – it is put off till the spending review and the government response to the national infrastructure assessment due in the same timeframe.

Equally the planning of transport is separate from the planning of land use.  Though two factors are bring these closer together.  Firstly the process of ‘regionalisation’ will often mean some planning responsibility for these bodies.  Secondly the requirement for ‘Regional Evidence Bases’ will largely depend on the evidence that infrastructure will support growth base in terms of housing and local economies

We havnt had a formal strucre for ‘regionalisation’ of any kind of planning since 2011.  This doument is at least a start.


Wokingham Refuses Bus Rapid Transit Scheme for Second Time

BBC Berkshire  

The proposal is included in the Core Strategy

Plans for a £20m riverside travel route connecting two Berkshire boroughs have been blocked by councillors.

A proposal for the Mass Rapid Transit (MRT) between Reading and Wokingham was refused by Wokingham’s planning committee on Wednesday night.

Reading Borough Council has already approved the scheme.

However, Wokingham councillors voted 6-3 against the plan. The authority had received more than 300 objection letters citing environmental concerns.

Members of the public booed at the start of the meeting when they were told the scheme had been recommended for approval by planning officers, according to the Local Democracy Reporting Service.

In a council report, planning officers said the proposal for the route along the Thames for buses, cyclists and pedestrians “would encourage a model shift to public transport”.

They added that “additional planting” had been included in the plan since it was last refused by councillors in June.

But the meeting heard representations against the plan pointing to the potential environmental impact and changes to the landscape.

Councillor Andy Croy said: “It still looks like a concrete jungle being dumped onto Wokingham Borough by our neighbours… and it is still a road, not an MRT.”

Members of the public cheered and clapped when the decision to refuse the application was made.

Details of the scheme were first published in July 2016 as a solution to congestion problems in Reading.

Lodge Hill Medway – Down from 5,000 to 2,000 to 500 Homes to Protect Nightingale SSSI

This the site where George Osbourne threatened Natural England and they rightly did there statutory job.  Medway is annoyed as they now have to find 1.500 houses elsewhere in their local plan.

Homes England

Homes England has proposed a new approach to the Lodge Hill development on the Hoo Peninsula in Medway, which will avoid direct Special Scientific Interest (SSSI) impacts on the Lodge Hill site.

Following further careful consideration of the environmental sensitivities in and around the site, the new plans are for up to 500 new homes, rather than the 2,000 originally proposed.

Prior to the submission of a planning application, Homes England will develop the masterplan proposals in more detail, which will be presented as part of a public consultation. It will also continue to promote the site through Medway Council’s Local Plan process.

Ken Glendinning, Head of Strategic Land, at Homes England said:

“We remain committed to creating new homes at Lodge Hill in line with the government’s policy on use of surplus land, and we have always been aware of the sensitivities surrounding the important environmental elements of this development. After careful consideration, we believe that this approach will avoid any impact on the SSSI, while still making an appropriate contribution to Medway’s housing need for local people.

“We are grateful to all of our stakeholders and partners, including Natural England, for their support and advice to date.”

Homes England will look to consult on development proposals for the site in 2019 through contact with stakeholders including local residents.


Naughty Step Wirral Backs Down on Green Belt Release in Local Plan – Whilst pretending not to

Cabinet 17th Dec

Councillor George Davies, Cabinet Member – Housing & Planning (and Deputy
Leader of the Council), said:
“Making sure Wirral residents have a choice of good quality, attractive housing is vital. We’ve got to have a robust Local Plan so we are able to meet those needs.
We’ve also got a responsibility to our residents. They have told us, unequivocally, that they do not wish to see Green Belt land developed for housing. We agree, and we have told Government Ministers the same thing.
“We must have a Local Plan. We understand this, and we are committed to developing one within the timeframe we have set out. We will do everything we can to protect our local environment and the Green Belt which is so important to our residents.
“We have consistently lobbied Government to allow us to use the recent, more accurate household projection figures published by the Office of National Statistics in September this year. Using these figures would mean we need release almost no Green Belt land for development.
“At the moment, the Government are refusing to allow us to lower our projections, so we must continue to plan for the bigger housing target – 12,000 over the next 15 years.

“I want to thank every Wirral resident who took part in this consultation. I want to reassure them that we are on their side, and pledge to do everything in our power to protect our borough and our unique environment.”

This is saying we dont want to build on the Green Belt but the government wont back down in the OAN issue so we will have to.

This is conformed in the report.

Counsel has advised that the Council should rely on the standard method forassessing local housing need set out in national policy and guidance, pending the outcome of the Government’s recent national consultation on proposed revisions to the national standard method for local housing needs.
The Council has submitted its formal response that any final decisions on the figures to be used in assessing local housing need, including any variance from the outputs from the standard method, should be retained at local level, and to state that the Council wishes to be able to adopt the most up-to-date 2016-based household projections (which result in a reduced minimum requirement of 488 dwellings per year) as a basis for assessing the future housing needs of the Borough.

The recommendation is to sumbit a revised LDS to full council in teh new year and to ‘continue to lobby’ over the OAn nuber.  But the report does not recommend breaking the law by not revising or submitting its local plan.  If as in inevitable the government does not give Wirral a special pass on OAN different from any other authority then the report would mean inevitably submitting a plan involving Green Belt release.  In not even setting a date for the revised LDS or target date for submission it is deliberately stringing things out.  Expect a deadline for submission by the SOS as soon as the OAN national consultation is concluded.

#CAMKOX Is there Poetry in the Parking lot?

Is there poetry in the parking lot?
In the grid like lines of Milton Keynes?
Behind the scenes the dead wind rustles and shakes water’s sea-ward dreams
Is there poetry amid the reeking refuse and overflowing bins?
Here is a flutter of wings as the flyer burns with freedom’s fire and turns upon the wind to the sound of the evening choir
‘And what about you? Is it in you too? ‘ it sings.

Is there poetry in the harsh reflections of the glass
In the regimented streetlit boulevards?
Underground the village ghosts turn and float their frosted lips across the cars
In stars and patterns etched along each stretched out hand of every tree
And lace-like silhouettes where startled birds take off in muted moon-like light
Turning to the sun mid-flight
‘And you? Is it in you too? ‘ they cry.