Planning Reform Week

The first bit

On the day that I started writing this the Prime Minister has confirmed in a move considered intellectually incoherent by some that hundreds of new oil and gas licenses will be granted in the UK, which signals that it is ‘Energy Week’ on the Government’s summer recess comms grid. A line appears to have been drawn from the role of an Ultra Low Emission Zone policy in securing a marginal win for the Conservatives in the Uxbridge & South Ruislip by-election to the softening of commitments to a net zero energy strategy.

Seven days ago the Prime Minister launched the grid’s ‘Planning Reform Week’ by announcing that the Government will meet its manifesto commitment to build 1 million homes over this parliament, which would represent “another important milestone in the government’s already successful housebuilding strategy”. It is notable given the ground that Labour has gained on housing in recent months that the first week of the parliamentary recess was devoted to trying to push back the red tanks from what has hitherto been seen as a traditionally blue lawn.

Maths was never my strongest of suits, but I do know that 1 million homes over a five year parliamentary term represents only two thirds of 300,000 a year, which was also a manifesto commitment, but may or may not still be depending upon which member of the Government you speak to on any given day.

(Setting oneself two targets in this way is quite canny to be fair and an approach that I might adopt myself over the next couple of months. I could tell my Managing Director that I will respond to all of the consultations that were launched last week and will respond to at least one of them. Upstairs for thinking. Downstairs for dancing.)

Looking back my tendency towards verbosity was better suited to English (and planning…), but I remember little of my GCSEs apart from a pathetic fallacy being the attribution of human emotion to the weather or a season to reflect the mood of a character or to create a tone. As the cavalcade of Planning Reform Week announcements emerged I was listening to rain bounce chaotically off the roof of a static caravan under a melancholic Devonshire sky. Make of that what you will.

By pretty much every conceivable metric (output, the number of children living in temporary accommodation, homelessness, housing waiting lists, the private rented sector, the Affordable Housing Programme, local plan delays, applications being submitted, application timescales, applications being determined, neutrality-related moratoriums, the plight of the SME sector, and so on…) the vast majority of housing and planning professional would question whether the government has a housebuilding strategy let alone whether it has a successful one.

Housing and planning professionals do though represent quite a small proportion of the electorate and it is instead to the non-housing and planning professionals, which represent a much larger proportion of the electorate, that the Prime Minister is speaking. The comms strategy being adopted by the people responsible for the comms grid is presumably that if you repeat something sufficiently frequently and assertively enough, such as Labour wanting to concrete over the countryside, then people will eventually be ground down into believing it.

The Prime Minister’s announcement, it soon became apparent, was actually only the appetizer to ‘Planning Reform Week’. The main course, served by Michael Gove was, to continue the tenuous culinary analogy, a smorgasbord of reheated leftovers and whatever else could be cobbled together from the back of the cupboard.

A mere ten days after the LUHC Select Committee published the findings of an inquiry into reforms to national planning policy and requested the Government response to the last consultation on the NPPF, the Secretary of State cocked a snook at the Committee’s concerns about the stop-start nature of the different proposals since 2019 by announcing a new “long-term plan for housing”.

The “long-term plan for housing”

Fans of Mr Gove will have been pleased to see references in his speech to Winston Churchill, the Medici model, Gaudi’s Barcelona, Haussmann’s Paris and Nash’s Regent’s Park, but will have been disappointed that the B.I.D.E.N. principles did not get a specific mention.

The first of the long-term plan’s ten principles (which is a nice round number) is the regeneration and renaissance of the hearts of 20 of our most important towns and cities.

There is reference in London to “Docklands 2.0”, which would be an eastward extension along the Thames (with reference, naturally, to the original Heseltonian vision) taking in Charlton Riverside and Thamesmead to the south and the area around Beckton and Silvertown to the north. There is reference elsewhere to a “programme of 20 city-centre renewals” that will “focus on the Midlands and particularly the North”. Three areas of Leeds get a mention in relation to future development, as do parts of Wolverhampton, Sheffield, Manchester, Birmingham and Newcastle in relation to recent development and recent disparate funding streams of which more are promised.

Most surprisingly Barrow-in-Furness gets a mention too. There is no doubt a compelling case for Barrow to become “a new powerhouse for the North, extending beyond its current boundaries with thousands of new homes and space for new businesses to benefit from the scientific and technical expertise already clustered there”, but one wonders what the good people of Barrow made of that. The comments underneath an article breaking the news on a local news website express a healthy degree of scepticism.

News that “supercharging” Cambridge, “Europe’s science capital”, certainly seemed to take Cambridge City Council by surprise, perhaps because when asked about the OxCam Arc proposition just last year Mr Gove reportedly mimed sitting on a lavatory and pulling the chain.

Peter Freeman, the Chair of Homes England, is to lead a ‘Cambridge Delivery Group’ tasked, in concert with national and local partners and backed by £5 million, to scope out a (as yet unidentified) major new quarter for the city, built in a way that is in-keeping with the beauty of the historic centre, and to advise on a long-term delivery vehicle for it.

Cambridge City Council’s Twitter account posted when news of the proposals were first mooted in The Sunday Times a few weeks ago that the “the Council has not been consulted on these ideas, which we note are described as being at the ‘concept’ stage”. A statement on the City Council’s website posted on the day of Mr Gove’s speech stated that “the emerging Greater Cambridge Local Plan proposals to 2041 have an emphasis on meeting housing and employment needs through sustainable development, climate change, environment and wellbeing, and creating great places to live” and that “the Government requires councils to plan ahead in this way to better ensure that new homes, services and infrastructure are delivered by partners in the right way and in the right timeframe.”

Will this be plan-led development? Perhaps if top-down, transformative change is to be delivered by way of a development corporation-type model it can be done out with the local plan process? Who knows. Somebody hopefully.

The news also seemed to come as a surprise to Conservative MP for Cambridge South Antony Browne who swiftly derided the idea as “nonsense”, but, 30 miles away in Peterborough, another Conservative MP, Paul Bristow, welcomed the plans as “great news” and made an immediate pitch for a fast transport link of some kind between the two.

All being well Mr Gove will take up an invitation from Peter Usborne, chair of the Cambridge Association of Architects, to go to Cambridge “to understand how our historic city, its skyline and green belt will be protected and explain how he proposes to safeguard sustainable goals and community engagement.”

Cambridge also got a mention in Mr Gove’s speech in relation to a new “supersquad” (a working title I am led to believe) of “expert planners”, backed by £13 million of new funding, to “unblock major housing and infrastructure developments”. “This team will first land in Cambridge to turbocharge development that contributes to the (as yet undefined) vision for the city, but it will also look at sites across the eight (mostly undefined) Investment Zones in England, to help provide high quality homes which complement the high-quality jobs that are being created”. One can only speculate as to how news of the imminent arrival of a “supersquad” was received within the award-winning Greater Cambridge Shared Planning service.

Just to recap then on the first of the long-term plan’s ten principles, there is seemingly a programme for the renewal of 20 city centres, but it is not known yet where they will be. They could be the centres with the most transformative local and national economic potential. They could be the ones most in need of transformative social change. They could even be ones that are subject to the 35% urban uplift included in the current construction of the standard method (which would have a modicum of logic), but then the reference to Barrow, which is not one of those, suggests that they will not make up the list. Who knows. Somebody hopefully.

The flippancy with which the last few paragraphs is imbued masks a few points that are worthy of comment.

Firstly, it is, of course, manifestly sensible, logical and desirable to focus development in the most sustainable locations, to redevelop and regenerate under-used previously-developed land, and to densify existing areas as and where appropriate. Matthew Spry has written about the drive for ‘urban renaissances’ under the last Labour government (and the implications of ‘brownfield first’ being interpreted as ‘brownfield only’), but there are clear differences between then and now in that then there was a policy commitment at the heart of Government rather than the periphery and a backing up of that commitment in policy and guidance. The “long-term plan for housing” has been published seemingly out with those factors.

It also goes without saying, but I will say it anyway, that the regeneration and renaissance of the hearts of 20 of our most important towns and cities is not and cannot be a substitute for full local plan coverage and meeting housing need across the whole country; cannot and will not meet in full the needs of the housing market areas of which those towns and cities form the heart; and that the need of those market areas cannot be met on previously-developed land alone.

That being said, an accompanying press statement to Mr Gove’s speech notes that, “densification, done the right way, will transform the opportunities available to people across the country – our inner cities have much lower population densities than comparable Western countries, impacting our productivity”. The right way to my unsophisticated mind is positively-prepared, inclusive, collaborative area action plans, or local development orders, or masterplans adopted by way of supplementary planning documents, or brownfield registers, or any of the other myriad existing dusty pieces of kit in the planning tool box.

Mr Gove stated that the “failure to turbocharge the redevelopment of inner city London is putting further pressure on the suburbs. If just 5% of the capital’s built-up area had the density of Maida Vale, it could host an additional 1.2 million people without the need to expand outwards”. If that is the ambition for ‘street votes’ and permitted development rights (more of which below) then it betrays a narrow understanding of both the issues and how to address the issues without creating new ones.

Just finally in relation to densification and the coherence of recent announcements, it has been suggested that the Government’s intention to mandate second staircases in new residential buildings above 18m will compromise the viability of the kind of flatted developments that would increase densities. It has also been suggested that Mr Gove’s recent decision in relation to Marks & Spencer’s flagship Oxford Street store will increase the scrutiny being placed on the embodied carbon associated with the demolition and re-development of existing buildings.

Another point worth dwelling on is one made by Daniel Slade, which is that these proposals were actually spun into something approaching a spatial vision for England. As Daniel notes, “it might not be the spatial vision that many want, and its outcome will depend on a huge number of practical considerations, but it does prioritise a kind of spatial development – densification – and name particular places across the country that are being targeted for urban transformation”.

A clearly defined urban policy would obviously be a very welcome thing, as would at some point a sensible conversation about the future of Green Belt policy. Now imagine if those two things were amalgamated, with, for example, other greater-than-local initiatives like Local Nature Recover Strategies, into a Plan for England to shelter national and regional priorities like the Oxcam Arc and the Garden Communities programme (remember that?) from the vagaries of election cycles. It’s easy if you try…

Coming back down to earth, I shan’t dwell on the other principles of the “long-term plan for housing” other than to highlight that despite a clear steer from the centre that Barrow and Cambridge should be a focus of future development it remains the Government position that communities take back control of their future. Oh, and Green Belt protection gets a mention because Labour want to concrete over the countryside. Oh, and we need to make architecture great again.

In a nod to what we might look forward to from the next draft of the NPPF as, when and if it emerges, there are three points of note in the accompanying press statement. The government is apparently clear that:

• “Development should proceed on sites that are adopted in a local plan with full input from the local community, unless there are strong reasons why it cannot;
• Local councils should be open and pragmatic in agreeing changes to developments where conditions mean that the original plan may no longer be viable, rather than losing the development wholesale or seeing development mothballed (PPG has subsequently been updated in relation to this); and
• Better use should be made of small pockets of brownfield land by being more permissive, so more homes can be built more quickly, where and how it makes sense, giving more confidence and certainty to SME builders.

This is all welcome and, going further, it would be extremely helpful in this writer’s humble opinion if in relation to each:

• A national scheme of delegation raised the threshold at which applications on allocated sites or reserved matters submissions pursuant to outline consents were referred to planning committees;
• The Levelling Up & Regeneration Bill (LURB) can be further amended to support the use of drop-in planning applications in the wake of the Hillside Parks decision in the Supreme Court; and
• Much, much more use of the afore-mentioned brownfield registers can be fostered.

If the Prime Minister’s announcement was the appetizer to ‘Planning Reform Week’ and Mr Gove’s speech was the main course we were also treated a number of amuse-bouches (or unamusing-bouches depending on your point of view) in the form of new consultations, responses to past consultations and other missives.

Permitted development rights

A consultation has been launched on permitted development (pd) rights across a range of sectors, including a number to support housing delivery.

These include the doubling of the present 1,500m² cap on the amount of commercial, business and service use that can be converted without the need for formal consent; the removal of the need for such premises to have been vacant for a continuous period of at least three months; the change of use of hotels, boarding houses and guest houses; and more flexibility for the conversion of food takeaways, betting offices, pay day loan shops, launderettes and agricultural buildings.

Nothing exposes the divide between paternalistic and laissez-faire thinking than a conversation about permitted development rights, but it is perfectly right and legitimate to question the quality of places and homes created by way of pd rights to date and how the extended use of such rights can be reconciled with aspirations for quality in the built environment, communities “being in control” and contributions to infrastructure and affordable housing.

The consultation material states that the proposed changes “will support the delivery of additional homes across England that might otherwise have not come forward through a planning application”. Again, this planner’s unsophisticated mind wonders whether some of the other afore-mentioned dusty tools in the planning box might encourage development in a way that is actually consistent aspirations for quality in the built environment, communities “being in control” and contributions to infrastructure and affordable housing.

It is acknowledged in the consultation that hotels and guest houses play an important role in the tourism industry, helping to stimulate economic activity and drive footfall in their localities. The Government argues though that in areas of high housing need, these buildings may better serve their local communities if repurposed as housing. Is that not a decision best taken by LPAs since, you know, communities should be able to take back control of their future?

The answer to most questions is better planning, not less planning, but then I suppose that every unit waved into an existing building is a home that does not need to be fought for anywhere else.

Plan-making

A consultation has also been launched on the implementation of plan-making reforms, which is worthy of a 5,000 word blog in it's own right.

(Such a blog could also take in the history of plan-making reform. A Planning Advisory Group was established to make recommendations on simplifying the process of producing plans and increasing the speed at which they were prepared in 1964.)

At the front and in the centre of the consultation is a proposal to set a timeframe of 30 months to prepare and adopt a plan, which, it is noted with delightful understatement, “is much faster than currently”. Five years faster to be precise.

As far as I can see the 30 month timeframe is an 'expectation' rather than an obligation, but, regardless, to my, again, unsophisticated mind there are broadly three ways of getting anywhere near it.

The notion of a 30 month plan process was promulgated in 2020’s now mythical, seminal, perhaps even legendary ‘Planning for the future’ White Paper, which also introduced us to National Development Policies: Growth, Renewal and Protection Areas; National Development Management Policies; the Infrastructure Levy; and a centrally-set, binding housing requirement. In the magical, mystical planning system of the future imagined by the authors of that document, with all of those elements introduced and operating harmoniously in tandem, a much shorter process, if not a 30 month process, might very well be achievable. Let us put that option in the 'maybe' pile.

Coming back down to earth again though, the second way of getting closer to 30 months would be to address the reasons why it takes an average of 7 years to adopt a local plan at the minute. These invariably involve housing requirements and / or the distribution of unmet need across administrative boundaries, which also invariably expose the Green Belt elephant lurking somewhere in the room (and Labour want to concrete over that, remember). Both Mr Gove’s “long-term plan for housing” and the consultation on the implementation of plan-making reforms are silent on the intended approach towards the standard method, the urban uplift, and the alignment test that is to replace the Duty-to-Cooperate. Until those nettles are grasped the average time taken to adopt a local plan will not decline, so let us put that option in the 'too difficult' pile.

The third way would of getting closer to 30 months would be to simply make it easier to get plans found sound.

The consultation states that "the amount of evidence produced to support a local plan or minerals and waste plan takes a significant amount of time and resource to produce and can often feel disproportionate".

This is the argument for removing the ‘justified’ test of soundness as proposed in the NPPF consultation, which requires a local plan to be “an appropriate strategy, taking into account the reasonable alternatives and based upon proportionate evidence."

As some commentators (me) stated in response, it would be interesting to see the evidence that the ‘justified’ test itself is adding to the burden upon LPAs because it might reasonably be contended that it is in situations where an LPA is pursuing a strategy that does not take into account reasonable alternatives that it finds itself having to provide ever more evidence for doing so.

The need for a local plan to consider reasonable alternatives is a fundamental plank of plan-making and it cannot be assured that it would addressed in relation to the remaining tests of soundness. Whilst alternative approaches can be considered by the environmental and sustainability assessments regimes, these, as the current consultation, would change over the time because of the move from SEA to EOR.

Plan-making is a laborious process less because of the evidence required to show that the approach taken to meeting housing need is a reasonable one and more because of the greater than local obstacles that local plans have to address.

A drive for proportionality is a welcome one, but this should not be expense of the robustness of the overall plan and the rigour with which it is examined locally. A drive for a greater quantity of local plans should not be at the expense of the quality of local plans, but, with one option on the 'maybe' pile and the other option on the 'too difficult' pile there are likely to be fears amongst the development community especially that this might be this Government's preferred option.

All of that being said (and cognisant of actually adding another 5,000 words about local plans), regardless of the merit of some of the proposals in this consultation (and if the are the policy planners in place to implement them there is certainly merit in, for example, a focus on visioning at the start of the process, monitoring at the end, gateway checks in between, and standardisation and digitalisation all the way through), it is arguably the timing of this consultation that is most concerning.

As the LUHC Select Committee recently noted, uncertainty around the reform agenda has resulted in 58 LPAs publicly stalling, delaying, or withdrawing local plans, 28 of those since the December 2022 NPPF consultation endorsing the effective dis-appliance of the standard method. These are just the LPAs with a public position remember. “Contrary to the Government’s objective of facilitating local plan-making”, the Select Committee notes, “the short-term effect of announcing the planning reform proposals has been to halt the progress of local plans in many areas”.

Plan-making is unquestionably at a modern nadir. The number of plans published in draft, submitted for examination and adopted in 2022 was already the lowest for a decade and it is inevitable that 2023 will be worse. the mere mention of the words ‘roll out’ and ‘transition’ will be manna from heaven for recalcitrant LPAs more than content to ‘await clarity before proceeding further’.

Despite this Government never intervening in plan-making before, the present Housing Minister Rachel McLean in addressing the House of Lords Built Environment Committee this week warned LPAs that are delaying their plans that things "will not end well" for them and that there would be "consequences" for so so doing. "A spokesman for DLUHC would not confirm the “consequences” Maclean was referring to."

Before moving on to application fees it is worth me highlighting that Community Land Auctions (CLA) get their own chapter in this consultation document. The LURB, you may know, provides for time-limited CLA pilots.

In the same way that pd rights expose the divide between paternalists and free-marketeers, CLAs expose the divide between progressive think tankers obsessed with public policy in Scandinavia and development professionals that have to make a living in the real world. I very much subscribe to Simon Ricketts' view that the introduction of CLAs would inevitably be harmful to to the principled operation of the planning system.

Land buyers should always be cautious of sites that look good upon first inspection but have not come forward despite being marketed multiple times because there is clearly a real problem lurking somewhere beneath the surface. CLAs are described in the consultation as a "longstanding idea" and caution should be applied to them for same reason.

Application Fees

The statutory instrument required to increase planning application fees was tabled on the day Parliament rose for the summer recess and the Government published the response to the consultation on so doing alongside the “long-term plan for housing”. The two areas that seem to have attracted the most attention, perhaps unsurprisingly given the unanimous pan-sector agreement that fees need to increase, relate to ringfencing and the free go.

88% of respondents agreed with the proposal to ringfence the additional income generated by the increase, but the Government “will not take ringfencing forward through legislation as this would impose a restriction on local authorities when they are best placed to make decisions about funding local services, including planning departments”. This has long been the government position and so comes as little surprise, but it does beg the question as to why ask the question if the answer was already known.

Instead there is an expectation that LPAs “would protect at least the income from the planning fee increase for direct investment in planning services”. This might be easier to achieve if each planning team was being led by a Chief Planning Officer reporting directly into an authority’s Chief Executive.

Even when the fees have gone up though a continued deficit in the provision of development management services; the clear and compelling need for planning teams to undertake non-statutory and non-fee generating activity; and the ongoing pressure on local authority budgets will all remain and all make the case to put the resources available for all planning functions on a long term, self-sustaining basis.

The removal of the free go divided opinion. 38% agreed that it should, 34% thought that it should not, 18% supported retention subject to a reduced fee, 7% disagreed with all these options, and 3% did not know.

Free go applications might not be necessary as part a coherent and operationally functional planning system, but are considered by the development industry to be a very important component of the UK planning system.

As was noted by recent PAS research, substantive, prompt and reliable pre-application advice can be very difficult for applicants to secure. The ability to withdraw an application so as to make an amended one to address issues that do arise post-submission means that a LPA can protect performance targets and an applicant can still secure approval locally without the need for a potentially costly and lengthy appeal. Even if substantive, prompt and reliable pre-application advice is received there will almost always be unforeseen issues or changes of circumstances that arise on the part of both LPA and applicant and a ‘free go’ affords the ability to deal with them.

As some commentators (also me) suggested in response to the fee consultation, the ability to make a free go application should not be withdrawn until substantive, prompt and reliable pre-application advice is available as the norm rather than the exception.

Just finally on fees, whilst there was unanimous pan-sector agreement that fees need to increase, there is likely to be some disappointment amongst the development community that commitments around commensurate service improvements have seemingly been rowed back from.

The consultation material stated that:

The government is only prepared to introduce fee increases if planning performance also improves. We want to ensure that all applicants experience a high-quality and timely service. This consultation therefore also proposes a new approach to how the performance of local planning authorities is measured across a broader set of quantitative and qualitative measures. This will provide greater transparency of service delivery and earlier and more targeted support to local planning authorities where needed.

The government response states that:

We are clear that an increase in planning fee income and resourcing to local planning authorities must lead to improved performance. It is our intention to introduce a new planning performance framework once we have increased planning fees and invested in supporting the capacity and capability of planning departments. However, we recognise that local planning authorities need a period of adjustment to any new planning performance framework, and we would reiterate our commitment to consult further on detailed proposals, including thresholds, assessment periods and transitional arrangements from the current performance regime.

LPA resources

Penultimately, Planning Reform Week included an announcement on “building planning capacity and capability to support local planning authorities to attract, retain and develop skilled planners”. This short announcement included:

• a LPA skills and resources survey, the results of which are expected in the autumn;
• an extension of the RTPI bursary scheme that that provides 50 students with £5,000;
• support for the LGA’s ‘Pathways to Planning’ graduate programme that will place an initial 30 people;
• a £24 million Planning Skills Delivery Fund to tackle application backlogs and boost internal capacity and capabilities;
• a £13 million programme that will deploy teams of specialists into LPAs, starting with the “trailblazing pathfinder” in Cambridge;
• £1 million for Public Practice to help councils recruit and develop skilled planners;
• funding for PAS; and
• funding to support delivery of targeted technical training, to address both the current skills gaps and to build readiness for change that will be required to meet the needs of the future planning system.

All of which I am sure is welcome, but is not the “comprehensive resources and skills strategy for the planning sector to support the implementation of our reforms” promised by the 2020 White Paper and which the Select Committee was told was being worked on as recently as May last year. Tellingly in more recent correspondence between the Government and the Committee there was no reference to such a strategy.

In its recent report the Committee recommended that the government “should publish a comprehensive resources and skills strategy for the planning sector, in line with its commitment to us. The strategy should clearly explain how the resourcing and skill needs of local planning authorities will be met; and should be published before future reforms to national planning policy are implemented.”

Rather than holding our collective breaths for that we might perhaps all be as well asking what we and our respective organisations can do to champion the role of planning such that next government might be encouraged to value it more than the present one evidently does.

NSIPs

Finally insofar as the cavalcade of Planning Reform Week announcements is concerned, a consultation has also been launched on reforms ‘to ensure the existing Nationally Significant Infrastructure Projects (NSIP) system can support our future infrastructure needs by making the consenting process better, faster, greener, fairer and more resilient by 2025’.

This strays a fair way from my narrow area of limited expertise and is probably notable from a housing point of view only because, despite what Mr Gove had to say about “the spirit of Poundbury animating new garden towns and villages across the country”, major new residential-led developments are still not part of the NSIP regime, which, linked to more formal status being afforded to the afore-mentioned Garden Communities programme in a ‘Plan for England’, could expedite the delivery there of.

The last bit

So there we are.

Just another week in the fast-paced, ever-changing, rock ‘n’ roll world of town and country planning.

The LUHC Select Committee noted that “the housing sector is hungry for clarity, consistency and certainty over the Government’s national planning policy”, but, as stated right back in the first bit, the Government is not speaking to us.

As the Observer noted in an editorial at the end of Planning Reform Week, “some of his (Mr Gove’s) ideas sound good, but on examination his proposals look less a serious effort to address the huge and complex issues of housing and planning than an attempt to curry favour with voters worried about development in their backyards”.

Such is the febrile politics of all of this that the Government is simultaneously trying to bring together two wings of the Conservative party that have very different ambitions for housing policy whilst at the same time trying to portray a clear divide with a Labour party intent on concreting over the countryside.

A line also appears to have been drawn from the role of planning reform in securing a resounding win for the Lib Dems in the Chesham & Amersham by-election to the softening of commitments to getting anything built anywhere. All things are being said to all people.

As well as London, Leeds, Cambridge, Wolverhampton, Sheffield, Manchester, Birmingham, Newcastle and Barrow, the other two places in this country to get a mention in Mr Gove’s speech were Barnet and Bromley.

This is because “making sure we unlock all the potential of London’s urban centre – while also preserving the precious low-rise and richly green character of its suburbs such as Barnet and Bromley – is critical to the nation’s future success”.

Really?

Seriously?

Preserving the precious low-rise character of Barnet is critical to the nation’s future success?

At this point all we can really do is doff our collective caps and admire the chutzpah of it all.

For it was, of course, Conservative MP for Chipping Barnet Theresa Villiers who was sufficiently emboldened from campaigning against development on the car park at Cockfosters tube station (and is now campaigning against the sensible-looking redevelopment of the Spires shopping centre) as to exploit the ‘top-down target’ farrago by tabling the fateful standard method-related amendment to the LURB that would have prohibited mandatory targets, which precipitated the NPPF consultation, which the Government still has not responded to.

(Bromley's mention may simply have been down to Mr Gove's journalistic flair for alliteration. Conservative MP for Bromley & Chislehurst Bob Neill was not a signatory of the Villiers amendment, although he does not appear to have been a fan of the 2020 white paper reforms.)

Planning is politics, as they say, and politics is planning, and we can look forward to at least another twelve months of this knockabout chicanery.

The afore-mentioned Simon Ricketts suggested to me last week as I was trying to keep up with the “long-term plan for housing” that it will not happen, that the proposals will change again before we are all back from holiday, or that will happen regardless of what anybody has to say about it.

That may be the state of affairs that we have come to expect, but that is not to say that we should not demand a lot, lot more.