Local Plan Inspector – Stop ‘Latching on’ to Covid-19

Herald Series on South Oxon EIP

Councillor Neil Fawcett, who spoke on behalf of the Liberal Democrat group, also highlighted the importance of taking into account the current state of ‘big economy downfall’.

He said: “Clearly when this process started neither Covid-19 nor the prospect of a no-deal Brexit could have been foreseen.

“It is highly likely we will have enormous difficulties in delivering a high figure of homes in the early years of the plan.”

But instead of addressing Mr Fawcett’s concerns, planning inspector Jonathan Bore, who lead the first day of the examination, put his foot down and dismissed them.

He told speakers to ‘steer clear’ from talking about politics and to stop ‘latching onto’ Covid-19.

Two months ago Mr Bore also inspected and signed off Oxford City Council’s Local Plan, which includes 724 homes in the Green Belt and is dependent on surrounding districts like South Oxfordshire building homes to ‘meet Oxford’s need’.

Read more: Interactive map shows housing plan for South Oxfordshire

Councillors, however, found it difficult to refrain from the subjects when debating the future of the housing market.

Addressing the planning inspector, Ms Roberts said: “I really do not understand how we can hope for a fair outcome with this process.

“I am sorry our officers have to defend the impossible and that you have to inspect a plan that must not fail, otherwise further intervention action will be taken by Robert Jenrick.”

Local Plans are no Longer the Single Source of Truth – and that’s the Problem

One of my favorite concepts is that of the Single Source of Truth (SSOT) It comes from information science and means that you always need a single reference for any piece of data. If you don’t you cant be sure what the ‘truth’ is, which requires an enormous waste of energy to check the truth.

Local plans are no longer that single source. Take RAF Manston, or Shenfield Aereodrome, where the local plans state one thing and DCO promoters state another and there is no clear NPS statement saying what the ‘truth’ of the zoning is. Take also Cambridgeshire where an elected mayor has one transport strategy and the growth partnership has another.

This massive confusion and waste is just not tenable in a zoning system where the whole point is to simply and clearly state what the truth is in terms of the information state is of what will get consent.

Brent Dykes on Forbes

Unlike in some political circles where alternative facts appear to be acceptable, you can’t afford to have them in your organization. They must be eradicated at all costs if you want to run your business effectively and efficiently. Having multiple versions of the truth can lead to confusion, paralysis and bad decision making. Inconsistent, contradictory data erodes trust in the numbers and impedes the ability of an organization to understand its current performance or forecast into the future with confidence.

Its benefits though are often misunderstood. The aim is not to replace gut feeling with ‘evidence based ‘ decisions but to avoid a loss of energy validating or going over decisions where the amount of evidence is sufficient to justify a gut feeling decision. its all about replacing the discredited 19th century view of rationality that still predominates in planning – the subject of my forthcoming book.

Strategic Planning and Uncertain Post-Covid Economic Geography

This will be important week for planning in England with the publication of the planning ‘Beigepaper’ or whatever colour it turns out to be. I will write on the issue of the future of zoning in another article.

Today though I want to focus on a key uncertainty that makes planning, especially strategic planning, difficult.

Strategic Planning is to a large extent predicated on forecastable growth. Forecastable economic growth by geography translates into household growth. That growth translates into household growth, which planning lagged behind, with household growth numbers used to set housing need by area. If an area was high growth but highly constrained then a strategic plan could distribute that growth to high potential but low constraint areas.

In the post-war system each element formed one tool in an integrated toolbox. Green Belt was designed to prevent cities expanding beyond a point where the cost of providing infrastructure became inefficient. The Green belt acted as a constraint but also designed to divert growth beyond it to partially economically self sufficient new Garden Communities/New Towns. Garden Communities/New Towns fell away in a period of constrained household growth when centralization was discouraged. that was in retrospect very short lived as inner urban economies recovered. In retrospect also chasing household formation was a mistake. During periods of recession household formation dropped and governments wrote to local authorities getting them to reduce targets in structure and local plans, further exacerbating long term deficiencies. Now there is more awareness than households form only where there are houses for them to form into and in many areas of England there has been massive suppression of household formation (concealed households) to the extent that the household formation projections are no longer a safe guide for strategic planning. This begs the question-what will be the agreed replacement?

In addition the ‘urban system’ that underlaid this was predictable. International in migration to cities, then migration of growing families to small growing towns and commuter belt areas, as well as young people from more economically depressed areas. In addition growth has expanded to most UK cities, but not the small towns forming belts of smaller industrial areas around them o remoter rural areas – other than those favoured by retirees. Now some of those certainties have fallen away. The level of international migration is anyone’s guess. Though it is likely that an aging population and collapsing fertility will require replenishment by international migrants – all all wages levels – to avoid an excessive dependency ratio which would cripple the welfare state.

Also the post-war Reginald Perrin World of commuting into City Centres seems broken. There are savings from home working to companies and productivity benefits from propinquity in offices, as well as indirectly to shops and catering outlets. These will effect individual companies differently. There can be little doubt however that a key constraint on planning, overloaded commuter rail lines’ is far less of a constraint than it was.

Take a back of the envelope calculation. Lets say the number of daily commuters into London fell by half to around 600,000 per day. It requires the space occupied by around 3 workers (including communal space) to free up space for one one person unit. So even if this dramatic fall were permanent it would only free up space in London for around 1 years national housing supply. It helps but with less demand for central London working there is less demand for suburban London cramming as well with census figures showing a dramatic and unsustainable increase in multi-household sharing of the existing stock. Ultimately covid will simply excerbate two long terms trends, more city centre living for these that can afford it and more decentralisation from suburban areas to growing areas in urban hinterlands.

Strategically that presents a number of challenges. Sustaining the fairbox for regional commuter networks and providing for zero carbon movement around much more dispersed living and working patterns. Ultimately I think this requires the underpinning of regional transport networks by some form of land value capture tax. If you assume that in future land values will be created by such networks, rather than internal combustion engine or heavy battery access, then this makes perfect sense.

It also makes sense to plan around areas where growth is enabled. Whether ‘science led’ growth areas like Oxford and Cambridge or the rings of small mill towns around northern cities that with better transport investment could extend the spillover economic effects of innovation to wider areas. After all it is now obvious that Brexit has killed off advanced manufacturing, the special advantage of the City of London in terms of access to the EU, and firms that relied on JIT trade to Europe. We don’t have much left other than science led growth.

In the short term we don’t have a firm platform for forecasting where future economic growth will be. But with commuting patterns disrupted by Covid jobs led approaches to strategic planning now make far more sense that outmoded housing led ones.

In addition many of the capacity arguments that prevented for example, arguments for a commuter station at Calvert or more strains to Marks Tey look ridiclous.

So as a future path for strategic planning I would suggest something like the following. How many jobs will we need in the future by City Region? There will be some interregional migration yes but opportunity areas in left behind areas should be pursued, whilst not assuming diversion away from areas where economic growth has hitherto been constrained by excessive inward commuting (like the arc). Such an approach would make much better sense for planning for areas like for example Cambridge and Oxford where the majority of people who need to live there cannot now and so dont show up in the household growth numbers.

A link series of nationally commissioned models (in partnership with LEPS) should form the new basis for strategic plans. LEP based models cannot at the moment as all of them double count the same workforce many time over. For example a Kent LEP assuming a worker from Yorkshire will move to Kent and a Yorkshire LEP assuming the same worker will stay in Yorkshire. Only a national balance sheet adjusted system (as we have in Ireland) can account for this. This also would demand the discipline of focusing growth on areas of potential – avoiding the ‘every crossroads town’ assumption (the lesson learned from the first wave of Irish national planning and fro the failures of Welsh strategic planning). As I have written here you dont need a single national plan just a series of regional plans with compatible economic assumptions.

Linked to this you will of course need it backed up by proper infrastructure plans.

The underlying assumptions of the old system makes it an unreliable guide for future strategic planning. But planning, especially zonal planning. cannot operate without the Oxygen of strategic planning. Ultimately covid has simply sped up economic geography trends that were occurring anyway. We cannot predict the forms that will occupy new business locations in 20 years for growth areas being planned now, however we can create the growth that will fill them by good strategic planning.

Cambridgeshire Chaos Turns Government Against Combined Authorities

There are endless legal complications around combined authorities between counties, districts and unitaries, especially when it comes to development plans and SDS.

The reports that the forthcoming devolution white paper requires unitaries and an elected mayor for a growth deal is wise. It was clear something was going on when work on growth deals halted earlier this year. Its pretty obvious what was going on. The near status and confusion of decision making where you had a separation between a combined authority, counties and elected mayors, most dramatically by the farce of James Palmer in Cambridgeshire opposing every king of interim transit solution but without having the balls to propose any kind of alternative for fear of a vocal minority bus hating pseudo-eco Nimbys opposing it – arrgh buses they are so ugly even though they replace 20 far uglier cars.

Thank you James – your legacy is abolition of the structures you so mishandled.

Government Admits I was Right About the Farage Garage – It Requires Planning Permission – SDO to be Issued

I covered this here an SDO is to be issued which will require an EIA screening


The Department for Transport has signed off on the purchase of a vast site in Kent for a Brexit border facility and confirmed that it will be partly used as a giant lorry park just days after the cabinet minister Michael Gove insisted that was not the “intention”.

The facility needs to be in place to accommodate checks for up to 11,000 lorries going to and from Dover and Eurotunnel in Folkestone every day.

Rachel Maclean, MP and parliamentary undersecretary of state for transport, has also apologised to local residents in Ashford that they had to learn the news from the press.

“We sincerely apologise that information on this matter made its way into the press before we were able to communicate with you directly,” she said. “We have not been able to inform you of our interest in the site before now for reasons of commercial confidentiality.”Local anger over plans for post-Brexit ‘lorry park’ at AshfordRead more

News of the plans for the 1.2m sq ft “Mojo” site between Sevington and Mersham villages came out of the blue on Friday night, infuriating the local Conservative MP, Damian Green, who told Gove on Monday it was “wrong-headed” to agree a secret deal with no consultation with locals.

He demanded to know what “environmental impact assessment” the government had conducted given the site was next to a planned housing estate and the local hospital.

“So many new houses are being built in that area and it will mean people are buying homes in good faith not knowing this was planned.

“It’s also close to the William Harvey hospital, where any disruption to traffic in the local area could literally be fatal,” he told Kent online.

Maclean has confirmed that the site will get approval via the secretary of state and not the usual local planning processes through what is known as a “special development order”, or SDO.

“We can however now confirm that the Department for Transport (DfT) has purchased the site and intends to make use of it in the context of our planning for the end of the EU transition period,” she said.

“Our use of the site will require further planning consent, which the government intends to pursue by means of a SDO process,” she added.

The site would be used both for customs clearance and as a holding pen for lorries if there was any congestion in Dover.

She said: “First, government departments envisage using it as a permanent site for facilities related to future border processes, notably HMRC (as an office of departure/arrival for goods moved under ‘transit’ arrangements) and Defra (as a border control post for goods needing sanitary and phytosanitary checks).

“Second, the site may also be used as a contingency lorry holding area for the particular, foreseeable risk of significant disruption at the end of the transition period.”

Locals expressed anger at the potential noise and air pollution with the “stop-start” of lorries through the night and constant noise of refrigeration trailers.

A Green party spokeswoman, Mandy Rossi, also expressed concern that the congestion on the roads would hold up ambulance services and could ultimately lead to the closure of the hospital as there is talk of a super-hospital to combine three A&Es in the county.

The customs clearance site is needed from 1 January next year, when the UK leaves the customs union and the single market and all those who trade with the EU will require customs declarations in addition to other paperwork.

HM Revenue & Customs estimates that 400m customs declarations will need to be processed a year but it only unveiled its detailed plans on Monday, less than six months before the most dramatic change to international trading systems since 1993, when the single market was introduced.

Maclean told residents there would be no problems if businesses did their bit and got Brexit ready.

“Significant problems at the border are not inevitable if businesses take the action necessary to prepare for the changes to come,” she said.

The government is expecting to purchase or lease between 10 and 12 sites across the country for Brexit border facilities, including sites near other ferry ports, including Holyhead and Portsmouth, in a £427m infrastructure programme. Gove confirmed on Thursday that the government had identified five sites in Kent where it intended to build new infrastructure to carry out checks

A DfT spokeswoman said: “This site will form part of our ongoing plans to help ensure the free flow of freight at the border as we make our new start at the end of the transition period.”

The Vast ‘BojoMojo Brexit-Port’ at Ashford Requires Planning Consent and The Government is Breaching Planning law


Does the current B8 Mojo consent on the edge of Ashford cover an inland dryport customs processing facility. I should declare an interest in that my Day job is designing the largest and most modern land ports in the world.

It needs consent – back to first principles a dryport customs processing facility is neither ‘storage’ [only confiscated goods are stored] or ‘distribution’ there is no intermodal or break between multiple origin and destination. Dry ports are used where there are insufificent space at an international border for customs clearance – so checking and clearance is moved inland. As part of the EU there was no need for customs clearance the UK being part of a customs union.

There really is no precedent here. For so long as the B8 use class has existed there has been no need for customs clearance at the border to the continent, and sea ports have been covered by DOT permissions and then the DCO regime. Where dryports have been developed in the UK they have taken the form of ICDs – intermodal container deports – where TEUs are custom cleared to and from the non EU, and involving break bulk and or ‘distribution’ transferring from vehicles to and from the port to vehicles to and from the original point of origin or destionation. No ‘distribution’ takes place at M{b}ojo it is a classic inland dry port shifting only customs processing from the sea port. It is a sui gneric use requiring planning permission. Commencing the M[B]ojo consent is commencing only the B8 consent. If customs operations commence it would be unlawful.

As the queues comning to and from the port will bring the M2 and Ashford to a gfrinding halt Ashford and Kent CC should let injunctions or emergency stop notices fly.

The government has secretly purchased 11 hectares (27 acres) of land 20 miles from Dover to site a vast new Brexit customs clearance centre for the 10,000 lorries that come through the Kent port from Calais every day.

It will be the first customs post erected in the UK to deal with goods coming from the EU for 27 years.

Work will begin on fencing off the vast 1.2m square foot “Mojo” site on the outskirts of Ashford on Monday. The local council were given only a few hours’ notice that the land was now in public ownership.

After being informed on Friday afternoon, the council leader has been forced to rush out hand-delivered letters to local residents to warn them of the disruption, Paul Bartlett, a Conservative councillor, told the Guardian.Government launches new ‘Get Ready for Brexit’ campaignRead more

The letter, from Rachel Maclean, MP and parliamentary undersecretary of state for transport, will say: “We are writing to inform you that the Department of Transport has purchased the site known as ‘MOJO’ (Church Road, Sevington, Ashford). Preliminary works are scheduled to take place on the western parcel from Monday 13 July 2020. This will include: securing the site with fencing, grass and weed vegetation cutting, extensive survey work, the constructing of a temporary site office, and the constructing of a temporary access to the site from the A2070 link road.

“Plans have not yet been finalised for the use of this site, but is anticipated to form part of the Department’s strategy to minimise potential disruption at Kent ports for the end of the transition period. This is likely to involve temporary capacity for the holding of delayed HGVs and facilities for border-related controls to be carried out by government agencies (eg HM Revenue and Customs). More detailed information will be provided in due course.”

The emergency purchase of the site is expected to be unveiled on Sunday by Michael Gove, who is to tour TV studios publicising the government’s multi-million-pound Get Ready for Brexit campaign. Businesses are bracing themselves for the publication of the first official details of the new border operating model and immigration system on Monday.

The government has been forced to introduce customs controls because of the decision to leave the EU’s single market and the customs union on 1 January.

When the single market came into being in January 1993, trade barriers across the bloc disappeared along with tariffs that many will remember as marking the end of duty-free alcohol and cigarettes. But from 1 January, the UK will revert to a system whereby importers will have to make customs declarations.

Mojo site

The first customs post for goods coming into the UK from the EU will be sited at Ashford. Photograph: Corporate brochure for the Mojo site off the M20 in Kent

There are fears locally in Kent that it could lead to massive congestion and tailbacks on the motorways from both the port of Dover and the Eurotunnel freightway in nearby Folkestone.

Last year contingency plans known as Operation Brock had to be put in place to guard against gridlock in the event that the UK crashed out of the EU with no deal.

Bartlett said it was no surprise that the land was going to be developed as it had been empty for almost 10 years and that HM Revenue & Customs operations would be more welcome locally than the rumoured Amazon warehouse. “It is a huge tick that this creates skilled jobs,” he said.

But he was concerned about the government rushing the new trading environment through. “Boris [Johnson] needs to be careful that these customs and tariff arrangements are finalised and in place in time, because otherwise there could be serious congestion, and we don’t want that.

“There is an enormous amount of trust involved in Boris and his counterparts in Europe to get us where we need to be for 31 December and time is not on our side,” he added.

Multiple government spokespeople declined to comment on plans saying details would be revealed “over the weekend”.

The Opinion Corridor of Plan Making

It’s a Swedish term åsiktskorridor meaning opinion corridor.  The band within political discourse is expected to happen, outside of which discourse is considered deviant.  Its a very useful concept in describing Sweden’s post war desire for consensus building, and I don’t use it pejoratively, as some would, to criticise the lack of oxygen for extreme views in such a society.  I use it normatively to describe the expectation of the parameters for acceptable discourse.  It is particularly useful to describe the parameters of debate used in the UK by the BBC, which can be exploited by those operating outside it, for example by climate change deniers and those with a tangential relationship to the truth, who use publicity to normalise and shift debate towards extreme views (the related concept of the Overton window).

The problem with plan makers and plan objectors is that they now operate in barely overlapping opinion corridors.  Those opposing are branded Nimbys, those promoting are accused of being dinosaurs promoting climate unfriendly policy. If you are the losing side of a plan debate demands for cllr resignation,  This is stifling of genuine debate on matters of profound importance.

The post war plan making system assumed a single opinion corridor.  This was broken by the onset of localism which institutionalized views outside it but with penalties for non delivery.  It was further broken by planning straying from a discourse based on evidence (of housing need).  It became a rule rather than a norm at precisely the point the evidence (past household formation) ceased being a useful predictor.  With plan making divorced from rational evidence it has become a battle of opposing world views with a supposition of bad intent of the opposing side.

Now successful plan making effort can occur without successful maintenance of a wide opinion corridor from beginning to end.   It is not just the promotion of inclusive participation.  That is barely 10% of it.  It is mostly about structuring a discourse on the impact of alternatives.  This rarely takes place.  Sites come through a developer led call for sites process, are chosen through smoke filled room meetings excluding the non ruling group and those impacted feel excluded and feel obligated not just to oppose (within the bounds of the system) but to seek to overturn that system as the only guaranteed means of success.

If the planing system is to remain democratic (as opposed to drifting further towards buying consent with favours) it needs to find ways to nurture and protect an inclusive opinion corridor for genuine realisable alternative visions of sustainable futures.

Chairman National Infra Commission – More Council Homes and Building on Green Belt Needed to Hit 300k Target


A huge expansion of council housing, including using the green belt, will be needed to meet Boris Johnson’s “build, build, build” commitments, a government infrastructure adviser has said.

Sir John Armitt suggested that the government was stuck in the 1980s with “ideological” objections to social housing as he warned that tweaking the planning system was not enough to hit a target of 300,000 homes a year.

He told The Times: “I’ve made this point to housing ministers over the last couple of years on a number of occasions. Clearly they don’t agree. But I am convinced that we will not get to what we need to get to if we rely simply on the private sector.”

Boris – Not Just Brownfield Sites

It is important to read the full text of Boris’ ‘Build, Build, Build’ speech – because the most important passage has not been reported on at all

‘We will build fantastic new homes on brownfield sites

and other areas that with better transport and other infrastructure could frankly be suitable and right for development

and address that intergenerational injustice

and help young people get on the housing ladder in the way that their parents and grandparents could

and it is to galvanise this whole process that this government will shortly bring forward the most radical reforms of our planning system since the end of the second world war’

One can imagine the MCHLG and Number 10 advisors taking a red pen to add that line, as rightly brownfield sites, as we know, are not enough.