‘Levelling Up’ Regional Policy under a New Name?

The first thing ministers should do with their newly free bandwidth after the conclusion of the Brexit negotiations is to work out what “levelling up” really means. They all have slightly different definitions, which suggests that if Johnson knows what it means, he hasn’t shared it with his senior ministers….Levelling up is in danger of becoming the sort of nebulous political catchphrase like the “big society” that David Cameron waffled on about. “It is an utterly meaningless, meaningful-sounding phrase,” complains one senior backbencher.

Isabel Harman Guardian

No it isn’t. How is it anything different for example than regional policy, or the definition of it by the EU which terms it ‘‘Cohesion policy‘.

Cohesion policy is the European Union’s strategy to promote and support the ‘overall harmonious development’ of its Member States and regions.

Enshrined in the Treaty on the Functioning of the European Union (Art. 174), the EU’s cohesion policy aims to strengthen economic and social cohesion by reducing disparities in the level of development between regions. 

Spatial economic disadvantage needs to be seen through the lenses of competitiveness and the economics of agglomeration. Agglomeration economies has two components. Industrial – cost advantages of industries locating close to each other, and urban – innovation spillover effects from concentration.

Across Europe the areas which saw the greatest agglomerations were mainly coal mining areas. It is sometimes claimed the locational decisions of industrial pioneers were arbitrary, for example Wedgewood did not locate at St Austell where his clay came from. However that was not the main transport cost – that was coal. After all the Lancashire cotton mills were not located on the Missisipi.

Regional policy has had its ups and downs in the UK but is now on a resurgence. Its focus and policy tools have shifted. For a while the focus was ‘levelling down’ forcing relocation via tools such as development certificates and wrong headed policies such as preventing the growth of Cambridge or even Birmingham. Elements of this even persisted recently, for example John Prescotts disastrous view that you you shouldn’t plan for 20 years housing in the South East as by then people would be moving north. In the event the Blair Government has highly successful in reviving the economies of the Core Cities but this simply generated more housing need in the North and has done nothing to create a flow of South-North migration.

The term ‘levelling up’ does not mean ‘squashing down’ so it implies a rejection of policies to restrict housing or employment growth in the South. I’m not sure MPs in the south see it that way.

At a time of deindustrialisation it made sense to concentrate on urban economics of scale. There has been some cluster development in the North – for example financial services in London and Leeds, but other attempts at cluster development – such as for Culture and sports in Sheffield, have been less successful.

The core cities do not have a housing problem which is all the more odd why housing targets policy are concentrating on them. Apart from Bristol and Brum/Wolverhampton they are all exceeding their targets even the new ones. Therefore the new standard method will do nothing towards levelling them up, rather it is maintaining the cap on authorities in the South East with high affordability problems.

The real problems are in the rings of mill and manufacturing towns in the north around the core cities. It should be noted that most of England does not have the problem prevalent in Europe of depopulation in remote areas and rural hinterlands of industrial conurbations. This is because few areas in England are truly inaccessible and the ability of many to set up business in rural areas, often from home. In England its often escape to the Country rather than escape from it.

Expanding urban economies of scale will be difficult with the centrifugal shifts exacerbated by covid. However many northern towns are poorly connected to Urban Cores and cities to each other.

Two issues stand out – the lack of a rapid transit system in Leeds /Bradford – easily the largest conurbation in Europe to lack one, and of course the core Northern Powerhouse goal of better connecting Leeds and Manchester. There are also a number of potential ‘quick wins’ such as the potential to kick off Wirral waters through restoring the Birkenhead Docks branch as a streetcar system. Here the DOT should do a deal, we will fund it for a share of land value uplift on sales.

Across Europe the plan for most ‘peripheral’ deprived towns has been planned decline of population with considerable public monies spend on scrubbing up form coal and steel areas. England is unusual in having a number of good practice cases of reversal of population decline. Most notably Corby -aided by its central location and many shovel ready inward investment plots made by the former New Town Development corporation, as well as European Money to restore the former steel site. This does suggest that public intervention at key locationally attractive sites can make a difference.

For areas lacking in connectivity there are opportunities to make new links. I am not one normally to argue for new Motorway Links but the M65 was cut short and stops at Colne having crossed the Pennines and doesn’t get to Bradford. It was extended in the 1990s then momentum ran out. The DOT is now studying a link.

Are Modern Masterplans too Dominated by Giant Swales?

I hope i’m not being too contrarian here. The introduction of Sustainable Urban Drainage has been an undoubted good. After accessibility the fundamental driver of masterplanning is gravity. I have long learned there is little point in beginning a masterplan without a hydrological study. Waters flows downhill and that dictates street layouts in large parts.

However I have noticed in many recent masterplans swales dominate. It is almost if the strategic landscape layout has been designed by a water engineer rather than a landscape architect or masterplanner.

Part of the reason for this is the Environment Agency rule that run off from the site needs to be no more than its greenfield state. This requires large areas of water storage. As the slopes of Swales cant be too steep they have to be long and fairly wide. However they are often not usable for public open space. Wet swales are not safe and dry swales you cant put paths in their centre. When they are full of nice planting they become purely ornamental rather than something you recreate in. Hence because of their size they squeeze traditional networks of open space. District and local parks seem non-existent. All that is left is pocket parks, and a large open space at the lowest and boggiest part of the site. What is worse there is a risk of repeating the great error of 1970s layouts, clusters houses separated not unified by open space. There is also a discouragement of truly urban layouts with narrow streets and high figure ground ratios.

What can be done? Check dams can be used to increase storage and reduce swalle size. More can be done to increase water storage at source, such as rain gardens in and at the edge of properties. French drains (ground level) can be used instead of gutters and storage area integrated into front and rear gardens. Urban streets can be designed as ‘cloudburst’ streets designed to flood to a set level. The concept is to retain water in the higher parts of the layout and gradually release it, rather than overly dominating the layout with a marshy lower level retention area.

You can also use permeable pavements and surfacing. Finally the longer the transect along the flow of water the more opportunities you get to slow runoff. Therefore you need to think strategically and ensure as far as you can that sites and linked ‘with the grain’ of shallow slopes. In Wuhan for example rather than assessing runoff parcel by parcel they have a strategic city wide target of containing 70% of runoff. This is a much smarter target than the Environment Agencies In areas with medium to high slopes with can zig zag layouts along contour lines and create parks on the inside the ‘v’.

Note the terms ‘Spong City’ SUDS and Water Sensitive design are all used around the world to mean essentially the same thing.

OANishambles 2 leads to Loss of 7 years work on Joint Stoke -Newcastle Under Lyme Local Plan

Stoke Sentinal

Controversial housing blueprint looks set to be scrapped after years of delays and hundreds of thousands of pounds spent.

The joint local plan between Newcastle Borough Council and Stoke-on-Trent City Council could have seen around 33,000 homes built across the two areas.ADVERTISING

It included some highly contentious sites, such as the former Keele golf course, where more than 1,000 homes were earmarked on Green Belt land.

A consultation exercise, beset by delays, was finally set to go ahead in autumn, after being delayed again by the coronavirus crisis.

But now the borough council has announced it it ‘taking a step back to review’ it, citing economic fears of Brexit and the fallout from the pandemic.

Its cabinet met last week and hammered the final nail into the beleaguered plan.

The joint local plan will cover Stoke-on-Trent and Newcastle
The joint local plan will cover Stoke-on-Trent and Newcastle

Instead, Newcastle planners will begin a ‘standalone borough plan’, for which a cost of £635,000 has been earmarked. The costs include staffing, external commissioning and examinations, and could go higher.

More delays are also predicted for the timescale of the new standalone plan.

The cabinet report states: “Work has now been ongoing for a period of approximately seven years to produce a plan, with a range of council employees, agency and specialist commissions deployed on various aspects of the plan preparation to date.

“To cease the preparation of a Joint Plan at this stage will mean that that funds will have been deployed on a project which is not progressed to fruition.

“Newcastle-under-Lyme’s expenditure to date on the preparation of the joint local plan is estimated to be circa £316,000, plus staff time. A further £90,000 in external commissions would be required to progress to adoption.”

Council leader Simon Tagg said: “I feel at this stage, as the report says, it is the time to pause and ask for some advice and to consult with those people and bring something back in January, so if we do decide to do our own borough plan, we can get on with it.

“The borough then will be the centre of the thinking for our local plan, instead of being attached to a large city which has got different ambitions and different growth targets than a borough.

“I’ll just say, Staffordshire Moorlands, which is the other side of the conurbation from us and the rural area out towards the peaks there, has its own local plan, and has had one in place for a few months now.

“They cracked on and got their local plan on their own and I don’t see why us as a borough can’t get on and do that.”

Cabinet member for planning and growth, Paul Northcott, said: “It’s important that we take a step back now, while we have the chance to look at this.

Of course the real reason – hinted at above is the 25% uplift applied to only Stoke as a Labour Authority. Of course Newcastle will be bound to fail the DTC if it doesnt take its fair share.

Lets hope its reassesses as well. Kelle Golf course is quite the worst major housing site I have seen of very many I have walked. Its 25 degrees in large parts, heavily wooded and forms a clear green belt function on the edge of the green bowl that separates it from Keele. The only reason it was persued was because it was council owned. There are far far better sites.

The Justification of Local Plan Strategies – the Problem and how to Fix it?

At last weeks MCHLG Planning White paper hearing there was a discussion over sub-regional planning (the minister used the term) where he rightly said the DTC wasn’t working as it should and gave an example – SW Devon (he could have added Newcastle Gateshead) as an example of where it worked. Of course there are so many more where it has fallen apart – such as Greater Exeter, North Essex, Greater Manchester and West of England. The DTC ensures that plans that fail to plan strategically fail. But does nothing to ensure strategic planning succeeds.

This is the greatest problem with strategic planning now, less the lack of it, the bigger problem is when it is tried it fails. This is the central problem my forthcoming book – Big Planning – aims to tackle – and it gets quite technical with GIS and other techniques used around the world. The underlying theme though is very simple. Big problems need to be reduced to small world problems.

Planning is still fixated on the more evidence the better. Even though Herbert Simon’s dictum that there is never enough time to gather all the information you need – so decisions will not necessarily be optimal is well understood the underlying dictum is that this is somehow sub-optimal and explains ‘irrational’ decision making.

This is not rational. Producing and digesting evidence consumes time and energy. This can be counterproductive. The consumption of time and energy has a cost, and if animals such as humans consume too much they can risk their survival. It is only rational to spend time on energy on evidence if the cost of gathering it outweighs the delay and benefits of making a faster and more frugal decision earlier. This new approach is called ecological rationality.

The greatest and consistent source of Non DTC failure at plan examinations is failure to plan for realistic options – typically leading to failure of the SEA directive.

In terms of evidence all you need is JUST enough evidence to reliably differentiate between a limited number of realistic options. Any more you risk taking so long to gather the evidence it will be out of date.

Here PINS are often to blame – such as issuing 150 questions, have you done this have you done that – at the outset of examinations.

Most planners of this generation have been schooled in the doctrine of Eric Reade that too much planning in the past was not evidence based. He was right but now the bigger risk is evidence overload.

I would add the need for three techniques to go on an evidence diet (more details in my book).

The first is structured simplification of the data;

The second is to provide a common reporting structure for the data you need to differentiate options

The third is to produce a simple, consistent model to produce the outputs needed for that structure.

The first and third of these require longer treatment than this blog post. There are examples of projects from several countries in my book.

This post refers to the common reporting structure.

Evidence for a plan is of two forms Baseline (self explanetory) and Options Report.

The report is the same as the environment report for SEA, they are not seperate things

Each option is a table, anticipated development by when, so the impacts of an option at various phases can be tested.

One of the most contentious things at examinations these days is years to start and completions per year. This means the majority of completions take place after plan end date. This is not a big deal when a garden community say meets a strategic need. However where and how strategic needs shall be me met is not even covered by national policy. It is entirely unhelpful. To simplify planning the Government needs to set down standard assumptions such as no more than 5 years from a development corporation stating to first completions – unless there are unusual infrastructure perquisites – and 4-600 units a years completions (as achieved at the peak on MK completions). Nor should it be assumed that a few hundred completions before say a major junction is upgraded is a big deal – the extent of additional harm will be minimal and then the problem will be fixed. This is precisely where the Government and Homes England need to proactively derisk strategic developments through land value capture and near zero interest rate borrowing – and make all the silly circular arguments that developments are unviable because of hope value go away.

Back to the common reporting structure. Not a bad one is Home England’s Garden Communities prospectus (though it is very inconsistent with the prospectus) form. Some of the financial requirements are excessive and it needs to have more info on options considered and their planning implications, but is a structured starting points. PINS should not be asking for more unless it relates to pressings and specific local circumstances.

The Fastest Way to Reduce Carbon Emissions in Britain – Get Rid of Farming on Marginal Land and Let Trees Grow

It has recently been suggested that the best way of rewilding is to simply let areas naturally seed and reforest. Of course this requires removal of grazing.

England’s current woodland covers only 10% of the country and current regenerative plans are only planning to increase this by 2%, by 2050.

If woodland cover was increased to 26%, 10% of the nation’s carbon would be adsorbed naturally, whilst supporting dwindling wildlife.

Rewilding – allowing woodland to regenerate naturally on a large scale – is the most effective way to increase woodland cover.

Allowing trees to naturally establish over huge areas could massively expand Britain’s woodlands more effectively and at a fraction of the cost of tree planting, according to research by Rewilding Britain.

Britain is one of Europe’s least wooded countries. Rewilding Britain says the UK government’s draft England Tree Strategy, open for public consultation to 11 September, is woefully inadequate for tackling the climate and nature crises. More ambitious targets and a fresh approach are needed.

The government’s unambitious plans also focus on manual tree planting as a quick fix. But a Rewilding Britain study to be published later this year shows that allowing and enhancing natural regeneration – supported by native tree planting in suitable sites – would be the most effective long-term approach for landscape-scale reforestation.

There is scientific support for this, as the areas around the world that have most rapidly reforested are those that have experienced the most rapid reforestation are those that have experienced the most rapid rural depopulation. Removal of grazing leads to natural forest regeneration.

Gulmi District and many other parts of Nepal — especially its middle-hills region — have experienced a forest resurgence over the past several decades. A forthcoming paper by a NASA-funded research team, using the most detailed analysis of Landsat satellite images of Nepal to date, has found that forest cover expanded from 26 percent in 1992 to 45 percent in 2016. This makes Nepal an exception to the global trend of deforestation in developing countries.

Many locals and experts attribute the forest regrowth to policy changes from about three decades ago, when the government began devolving management authority from bureaucrats to local communities across the country. Community forestry helped to reduce illegal logging, and many villagers undertook tree-planting campaigns to re-establish local woodlands.

One study showed that areas with the highest out-migration experienced the most forest recovery.

But there is another factor at play in Nepal’s forest resurgence: human migration. In recent decades, millions of Nepalis have left the country to work in the Persian Gulf, Southeast Asia, and beyond. As Nepalis wire money home, population and economic pressures shift away from agriculture to other types of rural and urban livelihoods. The families of migrants often rely less on forest products or they abandon farmland, aiding reforestation and helping create what one 2016 study termed a “remittance landscape,” referring to the funds sent back to Nepal. A 2018 study, which mapped the spatial distribution of reforestation and out-migration in Nepal, showed that the areas with the highest out-migration experienced, on average, the most forest recovery. There is a “strong positive effect of international out-migration on forest regeneration in Nepal,” the researchers concluded.

Globally, migration has important – though complex, and often ignored – impacts on forests. In many countries, forests appear to recover as people leave rural areas for work elsewhere. In El Salvador, for example, rural migration to cities and the United States has contributed to a forest rebound, as people have become less dependent on farming. 

Of course farming on marginal land in Britain is not a natural state of affairs. It only exists because of subsidy, a subsidy which puts animals on the land which fart vast amounts of methane – a greenhouse gas. Of course there are many upland areas whose natural state would not be forest but heath or moorland. These are the areas where it is defensible to use public subsidy to maintain a Beatrix potter landscape of Hardwick sheep and rare breeds cattle. On the rest of marginal land we should be refocusing subsidies overtime towards coppicing of naturally regenerated woodland to create woodchip zero-carbon biofuel. If we plough the fields we biochar from woodchip waste we even have a negative carbon cycle. Its no argument to say areas will return to bracken. Bracken is a superb biofuel.

There is no argument here about loss of food, as I have written here many times. We can easily make this up through zero carbon greenhouses and market gardening on better land nearer urban markets, as they are doing in netherlands where energy consumption of the horticulture sector has halved in the last 20 years.

So pension off the ‘dog and stick farmers’ we subsidise to chase around there cows and sheep to increase global warming. They are carbon dinosaurs.

Note the NFU report that we can offset beef emissions through biofuel makes no sense – where does the lane for biofuel come from – err beef or other food production. Its just special pleading.

Why Rejection of a Rail Mode for the Lower Thames Crossing has to be Revisited

As the Lower Thames Crossing Grinds its way to examination.

New Civil Engineer

Infrastructure projects like the Lower Thames Crossing should be “multi-purpose” and span more than one sector, according to Expedition Engineering director Alistair Lenczner.

According to Lenczner, the Lower Thames Crossing should be redesigned to include a road and railway.

He added that this would help improve the project’s benefits and reduce its carbon impact.

“No one thinks about integrated projects and this is a perfect example where there is a clear opportunity and a clear benefit,” he said. “We need to think of a complete picture of national infrastructure.”

The current set-up in the UK “conspires against” such collaboration, Lenczner said. He added that the National Infrastructure Strategy (NIS) – published last month – misses “significant opportunities” by organising infrastructure in separate “silos”.

Roads, railways, airports, energy and water, for example, are currently planned and delivered by separate agencies, with none responsible for identifying opportunities for multi-purpose projects that could deliver benefits across two or more sectors.

“It’s a complete blind spot and opportunities are being missed,” Lenczner said.

“There’s nothing in the NIS which looks at the potential for projects which are across sectors – road and rail, rail and energy – they’re all just doing their own thing but no one’s looking at it. Combining projects could allow better land use, better value and delivery of infrastructure in a more effective way.”

We have of course promoted the concept of a Kent Essex Rail on here several times.

Lets look at why it was rejected by government.

Options for a Lower Thames Crossing 2013

The Department for Transport commissioned a study in 2009 to review
the ways in which the capacity constraints at the existing crossing could
be addressed. The 2009 study concluded that there was a problem at
the existing crossing which required resolution through the provision of
additional road-based river crossing capacity in the Lower Thames area.
It also concluded that the provision of rail freight as part of any new Lower
Thames crossing would not address the rail freight capacity issues that are
forecast for the area. Passenger flow volumes on a cross-river rail route east
of London are also likely to be limited, meaning the inclusion of passenger
rail services would be unlikely to represent value for money.
As such, rail infrastructure has not been included within the proposals discussed in
this document.

The study referred to be xxx is here although it has not been archived properly and links to the chapters are broken. As I understand it however it modelled ‘as is’ rail movements and transport modelled existing points of trip origin and end plus growth.

There is of course a problem here – much like the much quoted fable of Brent Toderian saying ‘there is no demand for this bridge how many people do you see swimming this river’.

All I am suggesting at this stage is that after digging the three tunnels the digging machine rather than burying itself under the Thames turns and digs two more tunnels that are capable for fitting out for rail in the future. The marginal cost therefore is very low.

We have of course not seen any South Essex strategic plan, or one for North East Kent. I doubt we ever will as 5 years of work has never seen the light of day. One can only conclude the authorities are afraid of the blowback given that almost all strategic development options outside one in Basildon would be on Greenbelt. No one authority however can solve housing growth by themselves given the tight boundaries every startegic site spills over. The local authorities therefore are in a hang togther or hang apart scenario.

The new standard method means that there are all currently planning for 1/3rd to one half of there new ‘capped’ standard method numbers. The shortfall needs to be met elsewhere. Strategic plans in the past always assumed shortfalls would be met in the greatest concentration of brownfield in the South East. The Thames Gateway. Which is here and not considered ‘urban’ in the new standard method. When of course it is one of the most heavily urban parts of Europe alongside comparable areas such as the Randstadt. Imagine the Randstad with no bridges across the Rhine and no rail travel between Rotterdam and Amsterdam. This is the equivalent here. Nor does it account for the network benefits of new train paths – for example rail freight being totally taken out of the eastern side of London and freeing up capacity of terminals at cpacity such as Fenchurch Street, enabling more trains into London and more stops at development nodes at stations.

Given that over 150,000 units will need to be allocated both North and South of the Thames where shall it go? One obvious location is around South Hornden Station which potentially could be an interchange station between a Kent Essex Rail and C2C linking to Brentwood in the North and Medway and Gravesend to the South. This would radically reduce trips that would otherwise be forced to cross the Thames by car. Furthermore HS1 disappears beneath the Thames at Grays. The only reason Ebbsfleet happened was because Thurrock in their well known shortsightedness campaigned against a station. There is still potential however to link in HS1 to C2C nd its very fast and satright line to Southend. A 2km tunnel would link this to Soutehnd Airport (Southend International rail station) and the massive potential for rail based growth north of Southend and Essex largest brownfield site at Foulness Quinetec Ranges. More importantly it creates new travel to work areas and increases the economic benefits of urban agglomeration. Remember this was considered the MAIN benefit of the CAMKOX Arc, yet in the Thames Estuary 2050 Project (as the Gateway in now known) these potential benefits not even been studied.

There are a number of structural problems here in government. The first of course is the inability of the MoT to consider land use options not just transport options. The second is the ability of the MCHLG to lose interest in the Estuary every few years as progress has been so slow and the lack of progress by local authorities – always begging for money and never producing plans for more housing.

A Definition of Zoning

I don’t like many of the definitions of zonig I have seen, some capture the legal meaning, some the regulatory and some the act of planning, but not all three. Some cover land use, some development. So I will have a go based on one of the Cambridge English Dictionary definitions but more specific.

Zoning

The act of setting rules in a regulatory ordinance affecting real property  for the use and/or the design of development that can or cannot be built on geographically specified areas of land.

Some thoughts on the Proposed Class E to Resi High Street PD Right

  • The requirement for natural light means it will be hard to apply to zone A deep fronted vacant high street stores – there development will require PP to form light wells
  • The right is more likely to be applied to small shops on fringes of town centres and in local areas
  • The lack of any shopping need test – unlike the current A1 to C3 right – means it will most likely be applied to much needed shops in high value areas (Like Belgravia and well heeled villages) with disastrous consequences to local services.
  • We have too many shops for modern needs, especially in linear traditional high streets, and especially in more distressed towns.
  • There are often calls for such linear centres to be compressed, taking away shops at the edges.
  • However the most depressed areas of many centres are not at the outer edges, which are often nearest railways stations and car parks, but at the centre where the big stores like BHS, Marks and Spencers etc. used to be – examples Northampton and Southend.
  • The peripheral areas often have more mixed uses such as cafes and residential which add to footfall.
  • This questions the ‘planning dogma’ of primary frontages. Much of the evidence for them is discredited. I think of the old Unit for Retail Planning Information 35% rule – which suffered from spatial autocorrelation – i.e. poorly performing areas were more likely to be in depressed areas with low footfall.
  • Primary frontages are unlikely to be relevant unless in the very busiest regional centres e.g. Nottingham and Cambridge and no longer relevant in 95% of areas.
  • Permitted development is likely to hinder land assembly for comprehensive redevelopment at higher densities – we already see this with office PD rights in London.
  • I have blogged here many times about the latest research on vibrant centres suggesting the key to survival is introduction of mixed uses which bring footfall – cafes etc. The town centres most dependent on retail are thiose most struggling. We have to abandon 1970s ‘primary frontage’ thinking.
  • Dead frontages more more walking and is the enemy of vitality – it would make more sense for pd rights to apply to upper floors and rear storage areas than frontages.
  • There is big suppressed savings from the lockdown in more wealthy areas, expect a big recovery in spending in 2021.
  • Large centres anchored on department stores are dinosaurs.
  • Emerging clothing retailers, especially from Europe and Asia, still struggle to find space in the UK locked out by long leases – just compare the names say from a mall in Dubai. I’m sure there would be a market for splitting large footprints into concessions and administrators need to be more imaginative.
  • Town centres biggest assets are their open car parks, now wasted providing spaces for stores that are no longer there. Develop them for housing. Charge a premium for the remaining structured parking, parking and shopping floorspace find a new equilibrium.
  • Rebuilding town centres and assembling mixed use sites requires intervention and good planning. Crude PD rights wont help here. Much better there ws NPPF revisions and a PPG based on the latest research and best practice.

West Kents Conspiracy to not Cooperate on Meeting Housing Need – Once Sevenoaks Fell so Must Tonbridge and Malling

Inspectors Letter

Sevenoaks District Council (SDC) considers that it is unable to meet all of
its own housing needs. It is a neighbouring local authority and forms a
large part of the West Kent Housing Market Area which also includes a
significant part of Tonbridge and Malling Borough. Our letter will focus on
the engagement of Tonbridge and Malling Borough Council (the Council)
with SDC, in relation to housing and how any unmet needs might be met.
This is a strategic matter for the purposes of S33A…

it appears from the evidence before us that the Council knew for
a number of years, prior to the submission of their plan for examination,
that it was highly unlikely that SDC would be able to meet its housing
requirement in full. Despite this there is no evidence that the Council
engaged in any meaningful discussions with SDC to consider how the
strategic matter of unmet need could be resolved. Instead the Council
has relied on the fact that SDC did not formally ask them for help…

there is no evidence that at any time the Council cooperated or
even considered cooperating with SDC on a joint review of the Green Belt
to understand the comparative quality across the two districts and any
potential to amend Green Belt boundaries to fully or more fully meet
needs. The Council say the reason for this is that the two LPAs were at
different stages of plan making, however the plans were submitted for
examination within months of each other…

Turning to the matter of the Memorandums of Understanding (MoUs) that
have been submitted5. They were composed and signed after the
submission of both plans and provide no evidence of constructive and
active engagement prior to the submission of the plan and are therefore of
no help in demonstrating the Duty has been met…

On the basis of the evidence currently before us, for the reasons set out
above, it is reasonable for us to conclude, having carefully considered all
the evidence, that the Council has failed to engage constructively, actively
and on an ongoing basis in the preparation of the plan, so far as it relates
to the strategic matter of housing, and that the DtC in Section 33A of the
2004 Act has not been complied with. This cannot be remedied during the
examination of the plan.

Trump can’t live at Mar-a-Lago – it’s Zoned as a Hotel

Planetzen

Manuel Roig-Franzia and Carol D. Leonnig report on a strange turn of events for President Donald Trump’s plans to reside in Palm Beach, Florida once his presidential term is over: his future neighbors don’t want him to live it Mar-a-Lago, and they say that an agreement signed by the president in 1993 prevents him from doing so.

“In the demand letter, obtained by The Washington Post, an attorney for the Mar-a-Lago neighbors says the town should notify Trump that he cannot use Mar-a-Lago as his residence,” write Roig-Franzia and Leonnig. “Making that move would ‘avoid an embarrassing situation’ if the outgoing president moves to the club and later has to be ordered to leave, according to the letter sent on behalf of the neighbors, the DeMoss family, which runs an international missionary foundation.

The 1993 agreement signed by Trump prohibits club members from staying in the club’s guest suites for more than 21 days total a year, and limits stays to no more than seven days consecutively.

“The legal maneuver could, at long last, force Palm Beach to publicly address whether Trump can make Mar-a-Lago his legal residence and home, as he has been expected to do, when he becomes an ex-president after the swearing-in of Joe Biden on Jan. 20,” according to the article.

Roig-Franzia and Leonnig note, however, that Palm Beach has been lax in enforcing other parts of the agreement.

Another article by Zack Budryk provides additional coverage of the controversy.

Both articles note that Trump’s disagreements with neighbors of Mar-a-Lago date back to before Trump’s presidency, but complains about traffic jams and other frustrations have continued throughout the past four years.