🎯 Objective

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To reward integrity and reliability in development by introducing a national accreditation system that distinguishes trustworthy developers from repeat manipulators. TDA ensures that compliance, transparency, and delivery are not just ethical expectations — but pathways to faster approvals and better access.

📜 Policy T1 – Trusted Developer Register

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What it does:
Creates a national Trusted Developer Register, listing developers who:

• Consistently meet delivery commitments
• Maintain transparent corporate ownership
• Do not engage in frequent renegotiations or speculative delay

Accredited developers receive a formal status that unlocks access to faster planning processes and reduced scrutiny.

Why it’s needed:
Currently, all developers are treated equally — regardless of track record, delivery history, or behaviour. This system flips the model: compliance becomes an advantage, not just a duty.

International Analogy:

• The UK’s ConstructionLine certifies contractor competence, but is not tied to planning.
• TDA adapts this logic to land use and housing delivery.

📉 Policy T2 – Pre-Agreed Viability Simplification Protocol

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What it does:
Allows Trusted Developers to use streamlined viability assumptions, such as:

• Fixed land value ceilings
• Pre-approved build costs and profit margins

In exchange, the developer waives the right to renegotiate Section 106 contributions or affordable housing quotas post-permission.

Why it’s needed:
To reward transparency and speed — and eliminate viability gamesmanship from those who agree upfront to fair parameters.

International Analogy:
The NHS tariff system applies fixed payments for defined services. This replicates that logic for development finance.

🚀 Policy T3 – Fast-Track Plan Allocation Eligibility

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What it does:
Gives accredited developers priority access to:

• Local Plan allocations
• Strategic growth zones
• Government land tenders and disposal schemes

Trusted status becomes a competitive edge, replacing political proximity or profit maximisation as the key access driver.

Why it’s needed:
To make doing the right thing faster and more profitable than manipulation or evasion. TDA shifts the economic logic of developer behaviour.

International Analogy:

• Sweden gives preferred site access to firms meeting green delivery and conduct criteria.
• Singapore fast-tracks land access for “trusted builders” under public land sales.

📘 Summary

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The Trusted Developer Accreditation Portfolio (TDA) reframes planning as a performance-based system — not an open gate for any actor, regardless of behaviour. TDA aligns economic rewards with ethical conduct, delivery consistency, and public purpose, using tools like simplified viability, priority access, and reputational certification. It builds a planning culture where integrity is competitive — and speculative behaviour is a disqualifier, not a strategy.

🎯 Objective

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To build an oversight ecosystem that makes planning enforcement possible, public performance visible, and trust in the system durable. PGO introduces independent roles, institutional audit tools, and national transparency protocols that turn planning from a paper system into an accountable one.

🕵️ Policy G1 – Planning Integrity Commissioner Role

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What it does:
Creates an independent, statutory national role: the Planning Integrity Commissioner. This body is empowered to:

• Investigate suspected misconduct in planning decisions
• Audit local planning authorities (LPAs)
• Refer serious cases of fraud, collusion, or systemic failure to enforcement agencies

The Commissioner operates independently of ministers, LPAs, or developers — ensuring neutrality and public confidence.

Why it’s needed:
Currently, oversight is fragmented. The Local Government Ombudsman is reactive and complaint-based, while PINS (Planning Inspectorate) is technical and case-specific. No entity has the power to investigate patterns of abuse or systemic misconduct.

International Analogy:

• Australia and Canada use national integrity commissioners with powers to audit, investigate, and escalate cross-sector ethical and procedural breaches.

🧩 Policy G2 – Integration of Portfolios into PINS Inspector Protocol

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What it does:
Requires that PINS (Planning Inspectorate) formally integrate the following portfolios into its appeals and inspector training protocols:

• VAP (Viability Abuse Prevention)
• CEAP (Coordinated Enterprise Abuse Prevention)
• PMI (Planning Market Integrity)
• EIA (Environmental & Infrastructure Assessment)

This ensures these reforms are not dismissed as “non-material considerations” during appeals.

Why it’s needed:
Planning inspectors sometimes override local decisions because they are not bound by newly introduced policies unless integrated nationally. This allows developers to exploit a backdoor exemption route during appeal.

International Analogy:
In Switzerland, national environmental and housing policy must be factored into every zoning appeal — regardless of local interpretation.

📈 Policy G3 – Enforcement Score Transparency Framework

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What it does:
Mandates that every LPA annually publish a Planning Integrity Scorecard, including:

• Section 106 (S106) enforcement rates
• Affordable housing delivery vs approval
• Number and outcome of developer renegotiation requests
• Appeal reversal rate
• Vacancy-to-Delivery Ratios (VDR), where applicable

The scorecard must be:

• Published online in a standardised format
• Audited by the Planning Integrity Commissioner
• Submitted to DLUHC (Department for Levelling Up, Housing and Communities)

Why it’s needed:
To introduce public benchmarking pressure and performance visibility — creating parity between LPAs and giving citizens the ability to track and challenge underperformance.

International Analogy:
The OECD recommends enforcement benchmarking as essential to credible regulation — and many sectors (e.g. health, finance, education) already publish key performance indicators.

📘 Summary

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The Planning Governance & Oversight Portfolio (PGO) creates the legal spine and visibility layer for your entire reform system. It enables policies in VAP, CEAP, PMI, and EIA to be measurable, enforceable, and appeal-proof, while publicly tracking LPA performance. PGO makes planning accountable to outcomes — not just paperwork — and ensures the system is observed from both within and above.

🎯 Objective

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To raise environmental standards in housing delivery by ensuring that carbon intensity, energy infrastructure, and future efficiency are not afterthoughts — but central, enforceable parts of the planning test. This portfolio prevents development that undermines climate targets and embeds long-term environmental failure.

🔥 Policy Z1 – Site Carbon Intensity Threshold

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What it does:
Requires every planning application to submit:

• A projected build-phase and lifecycle carbon footprint
• Emissions benchmarks based on site size, materials, and layout

Applications that exceed a defined carbon intensity threshold will be:

• Automatically refused, or
• Required to submit mitigation and redesign plans

Why it’s needed:
Planning approvals that enable sprawl, inefficient materials, or high embodied carbon undermine the UK’s legally binding net zero goals. Without carbon thresholds, even “compliant” projects can be climate failures.

International Analogy:

• Norway and Sweden require carbon modelling in all large-scale development proposals.
• France mandates lifecycle emissions disclosures as part of its “RE2020” regulations.

⚡ Policy Z2 – Energy Source & Demand Mapping Requirement

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What it does:
Requires all major applications to:

• Identify how the site will access renewable or low-carbon energy
• Forecast total projected energy demand
• Flag any potential grid strain or fossil lock-in risks

Applications must demonstrate that demand can be met without overloading infrastructure or increasing local dependency on gas.

Why it’s needed:
Too many developments are approved in areas where the grid is already stretched, or where new builds lock in reliance on high-emissions systems.

International Analogy:
Denmark requires energy infrastructure mapping for every major project, ensuring sustainability starts with the grid.

🧱 Policy Z3 – Retrofitting Viability Safeguard Clause

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What it does:
Mandates that developers demonstrate — at planning stage — that buildings will be:

• Structurally capable of retrofitting (e.g. for insulation, solar, or heat pumps)
• Designed with future adaptation in mind (e.g. loft height, wall load, boiler conversion)

This includes submitting a retrofitting readiness statement, to be assessed alongside layout and materials.

Why it’s needed:
To stop the approval of buildings that can’t be adapted to future climate legislation — creating stranded assets, higher retrofit costs, and social displacement.

International Analogy:

• Germany’s KfW energy efficiency codes assess retrofitting potential at design stage.
• The EU Taxonomy for Green Buildings requires future-proofing as a green finance condition.

📘 Summary

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The Environmental Performance Portfolio (EPP) transforms environmental planning from lofty policy into binding design criteria. By requiring carbon thresholds, energy demand integration, and future retrofit viability, it ensures the homes we build today are compatible with the environmental standards of tomorrow. EPP is not about incremental improvement — it is about refusing development that would bake failure into the system.

🎯 Objective

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To restore public sector leadership in development by equipping local and regional authorities with tools to assemble land, directly deliver homes, and intervene where private actors delay, speculate, or fail to act. PSD ensures the state can lead or rescue development in the public interest — not just wait and hope.

🧩 Policy S1 – Public-Led Land Assembly Mechanism

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What it does:
Empowers local planning authorities (LPAs) and combined authorities to:

• Strategically assemble fragmented land parcels
• Use soft compulsion (e.g. voluntary purchase backed by planning incentives)
• Trigger Compulsory Purchase Orders (CPOs) where needed

Land can then be transferred into public or community-led development vehicles.

Why it’s needed:
Delivery often stalls not because of policy, but because land is fragmented, unavailable, or hoarded. Public-led assembly cuts through this gridlock.

International Analogy:

• Germany and the Netherlands give municipalities the legal and financial tools to assemble land for housing and infrastructure routinely.

🏗️ Policy S2 – Local Development Corporations (LDCs)

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What it does:
Establishes mission-driven, public or public-private delivery bodies (LDCs) to lead major housing or regeneration schemes, including:

• Public land transformation
• Mixed-tenure delivery
• Infrastructure-led masterplanning

LDCs may have statutory backing and operate with delivery mandates.

Why it’s needed:
Private-led delivery can be speculative, fragmented, or misaligned with local need. LDCs ensure delivery is led by public purpose, not just market cycles.

International Analogy:

• Canary Wharf and London’s Olympic Park were delivered through LDCs.
• France uses établissements publics fonciers as public land corporations for strategic delivery.

🛑 Policy S3 – Compulsory Purchase Activation Trigger

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What it does:
Creates a statutory right for LPAs to initiate CPO proceedings if a developer:

• Fails to commence delivery within a specified timeframe (e.g. 3 years post-permission)
• Uses site holding purely as a speculative asset

This power may be coupled with reduced compensation if delay was unjustified.

Why it’s needed:
To give LPAs a credible enforcement option when land is granted permission but not brought forward — preventing long-term speculation and withholding.

International Analogy:

• Scotland’s land reform framework includes CPO tools triggered by delay or non-use, particularly in rural or community-led contexts.

📘 Summary

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The Public Sector Delivery & Intervention Portfolio (PSD) rebalances power in planning by ensuring the public sector is not just a referee, but a capable developer, enabler, and enforcer. Whether through land assembly, direct delivery, or compulsory purchase, PSD equips the state to intervene where private actors fail — ensuring that housing and regeneration do not stall for lack of will or coordination.

🎯 Objective

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To rebalance housing delivery and spatial planning across the UK by accounting for internal migration trends, digital-era working patterns, and over-concentration in overstretched areas. This portfolio ensures that planning becomes a national strategy, not a disconnected set of local burdens — tackling both overdevelopment and under-utilisation.

🧭 Policy N1 – Internal Migration Adjustment and Housing Allocation Rebalance

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What it does:
Establishes a mechanism to adjust housing targets based on verified internal migration data — increasing targets in high-absorption areas and easing pressure on overstressed authorities that have already taken disproportionate growth.

Why it’s needed:
Planning decisions often rely on crude population forecasts that ignore actual internal movement — especially post-COVID. This creates unfair housing expectations and systemic overload in certain districts.

International Analogy:
Germany’s federal-state distribution formula adjusts targets based on intra-national mobility and employment shifts.

🏡 Policy N2 – Strategic Growth Zones for Remote-Work Enabled Settlements

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What it does:
Designates new growth zones in areas with:

• High digital connectivity
• Housing availability
• Underused infrastructure

Backed by investment in co-working hubs, local transport, and digital services, these zones support settlement redistribution through planning.

Why it’s needed:
COVID-19 reshaped geography of work, but the planning system didn’t adapt. This unlocks dormant housing capacity without creating new stress points.

International Analogy:
Portugal and Estonia launched remote work village programmes with planning incentives tied to broadband infrastructure and green lifestyles.

🚦 Policy N3 – Infrastructure-Ready Area Bonus Scheme

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What it does:
Provides planning incentives and funding uplifts to LPAs that allocate growth in areas with existing capacity headroom, including:

• Spare school or NHS capacity
• Available road, water, and transport bandwidth
• Local authority brownfield preference zones

Why it’s needed:
Most development currently chases profit, not infrastructure logic. This policy rewards smart siting and steers growth to where it can be absorbed with the least harm.

International Analogy:
The Netherlands’ VINEX policy channeled development into serviced areas to protect rural heritage.

🏥 Policy N4 – Affordable Relocation Incentives for Key Workers

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What it does:
Offers targeted support to key workers (e.g. NHS staff, teachers, care workers) to relocate to housing-abundant areas, using:

• Stamp duty reductions
• Deposit guarantees
• Rent-to-buy schemes

Why it’s needed:
There’s a chronic spatial mismatch between where people work and where housing is available. This reverses the logic — bringing people to homes, not just homes to jobs.

International Analogy:
Finland and Japan both used relocation grants and housing discounts to rebalance workforce distribution in under-occupied regions.

🧯 Policy N5 – Saturation Brake for Overbuilt Zones

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What it does:
Establishes a statutory “saturation index” based on:

• GP and school overload
• Traffic congestion
• Planning density thresholds

If the index is breached, the area enters a temporary moratorium on further permissions (with exceptions for affordable-only or infrastructure-embedded schemes).

Why it’s needed:
Communities are being overwhelmed by approval flows that don’t match service capacity. This protects them from planning-induced collapse.

International Analogy:
Singapore uses designated “white zones” to temporarily halt development in high-stress areas — until infrastructure catch-up occurs.

📘 Summary

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The Nationwide Development Distribution Portfolio (NDD) reframes housing delivery as a coordinated national system, not a fragmented burden on already-stressed communities. Through target rebalancing, incentive alignment, remote-work era zoning, and saturation brakes, NDD brings planning into line with real-world population dynamics, infrastructure conditions, and digital flexibility — ensuring that where we build makes sense.

🎯 Objective

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To ensure that public consultation in planning is meaningful, accessible, and democratically legitimate — not procedural or tokenistic. DPP empowers citizens to participate with clarity, confidence, and traceable impact, transforming planning from an expert-controlled process into a shared civic space.

🧒 Policy D1 – Youth-Led Plain Language Planning Literacy Initiative

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What it does:
Creates a national programme where local authorities partner with:

• Schools
• Colleges
• Youth councils

Together, they co-produce plain-language versions of key planning processes and concepts. These resources are then shared widely across communities — especially among groups often excluded from planning discourse.

How it works:

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• Youth teams are mentored by local planning officers or RTPI volunteers.
• Outputs may include:
  • Leaflets (e.g. What is a planning application?)
  • Short videos or animations
  • Infographics for material vs non-material objections
• “Planning Cafés” hosted by youth teams offer drop-in civic explainer sessions.
• Best materials are published nationally via a web platform with open-source access.

Why it’s needed:

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Most planning documents are opaque, and the public (especially younger generations and renters) are disengaged as a result. This initiative builds lifelong civic confidence, while improving community understanding in real time.

International Analogy:

• Scotland and Finland embed youth-led planning literacy into participatory budgeting.
• Barcelona runs Urban School to educate citizens on their rights in city planning.

🧾 Policy D2 – Structured Consultation Format for Material Relevance

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What it does:
Standardises public consultation forms to guide residents in submitting legally relevant (material) comments, such as:

• Traffic impact
• Flood risk
• Visual design

And to distinguish these from non-material objections, such as:

• Developer reputation
• House price concerns

Why it’s needed:
Many objections are technically valid but procedurally ignored. Structured forms help the public comment effectively, and ensure their views carry legal weight.

International Analogy:
Ireland’s An Bord Pleanála publishes public guides on submitting effective planning objections and distinguishing relevance.

🔁 Policy D3 – Consultation Feedback Traceability & Planning Impact Matrix

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What it does:
Requires LPAs to publish a Consultation Impact Matrix summarising:

• What issues were raised
• Which were deemed material
• What impact they had on the final report or outcome

Why it’s needed:
Public feedback often disappears into a black box. This policy creates feedback traceability — showing where and how the public voice mattered.

International Analogy:

• The Netherlands and Denmark publish structured response logs that trace public comments to formal decisions.

📨 Policy D4 – Civic Inclusion & Notification Rights Protocol

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What it does:
Expands statutory notification rights to include:

• Renters
• Schools and healthcare providers
• Local charities or community interest companies (CICs)
• Residents with significant functional, not just geographic, proximity

Why it’s needed:
Current law only requires notifying adjacent landowners, excluding key local users. This change ensures informed consent, not just procedural compliance.

International Analogy:
Canadian cities notify tenants, community groups, and service organisations for all significant applications.

📘 Summary

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The Democratic Planning Participation Portfolio (DPP) transforms planning from a technical silo into a civic dialogue. By introducing plain language, structured consultation tools, traceable feedback, and broader inclusion, DPP ensures that the public is not just allowed to speak — but empowered to shape outcomes. It gives voice to those long excluded and brings legitimacy to every stage of the planning process.

🎯 Objective

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To replace subjective and inconsistent “planning balance” judgements with a national, transparent, and measurable evaluation system. PERA empowers both planning officers and the public with predictable tools, grounded in risk sensitivity, to ensure fairer and more accountable decisions.

🧮 Policy R1 – Universal Points-Based Evaluation Framework for Major Applications

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What it does:
Creates a national scoring system for major planning applications, based on defined and weighted criteria such as:

• Sustainability and climate performance
• Affordable housing delivery
• Infrastructure adequacy
• Developer conduct history
• Environmental and cumulative risk

Why it’s needed:
Currently, planning decisions are made through a vague “balance of factors”, which varies by officer or political context — making it prone to manipulation or inconsistency.

International Analogy:

• The UK Home Office uses a points-based system to assess immigration applications.
• Sweden applies weighted rubrics in regional and urban development evaluations.

📋 Policy R2 – Public-Facing Evaluation Scorecard Format

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What it does:
Requires all planning authorities to publish an easy-to-read scorecard alongside each application, showing:

• How each factor was scored
• How it was weighted
• Final pass/fail or risk band result

Why it’s needed:
To build trust and accountability. The public, councillors, and even applicants need to see why a scheme passes or fails.

International Analogy:

• Ireland’s Housing Delivery Action Plans include performance scorecards.
• New Zealand mandates public-facing development risk ratings.

🛑 Policy R3 – Trigger Thresholds for Independent Review or Call-In

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What it does:
Introduces automatic “red flag” thresholds that trigger:

• External review
• Call-in by the Secretary of State
• Referral to an independent panel

These are activated by:

• Extremely high-risk scores
• Developer misconduct flags (e.g. from CEAP)
• Discrepancies between officer score and LPA committee outcome

Why it’s needed:
To prevent controversial or borderline applications from sliding through unexamined.

International Analogy:
The UK Planning Inspectorate already handles call-ins — this system adds objective criteria for when it must happen.

⚠️ Policy R4 – Risk Weighting Based on Developer History or Coordinated Control

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What it does:
Applies higher risk scores to applications from developers who:

• Have failed to deliver in the past
• Renegotiated obligations post-permission
• Used shell companies or artificial land control splits

Why it’s needed:
To allow LPAs to exercise structured caution against developers who have undermined the system previously. Trust must be earned, not presumed.

International Analogy:

• Credit rating agencies increase scores for borrowers with defaults or hidden liabilities.
• This system brings similar risk sensitivity into planning.

📘 Summary

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The Points-Based Evaluation & Risk Assessment Portfolio (PERA) makes planning decisions explainable, predictable, and defensible. It reduces subjectivity, raises transparency, and empowers communities and officers alike to understand how and why decisions are made. By incorporating risk weighting, independent review triggers, and public scorecards, PERA helps restore trust and stops decisions being shaped by discretion alone.

🎯 Objective

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To modernise the UK’s Environmental Impact Assessment (EIA) screening process and infrastructure analysis tools. This portfolio ensures that cumulative development, real-world service capacity, and environmental resilience are fully factored into planning decisions — especially in vulnerable rural or edge-of-settlement locations.

🌿 Policy E1 – Strengthened EIA Thresholds for Rural and Edge-of-Settlement Sites

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What it does:
Reduces the default thresholds for triggering a full Environmental Impact Assessment (EIA) on:

• Multi-phase rural development
• Edge-of-settlement proposals
• Sites in ecologically or hydrologically sensitive zones

Why it’s needed:
Current EIA thresholds allow developers to “salami-slice” proposals into smaller parcels to avoid assessment. This leaves fragile landscapes underprotected and blindsides communities.

International Analogy:
Ireland and Germany lower EIA thresholds in Natura 2000 zones and other rural or heritage-sensitive areas to reflect their higher ecological sensitivity.

🔁 Policy E2 – Cumulative Development Screening Requirements

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What it does:
Requires that EIA screening for any new application also considers:

• Other recently approved developments nearby
• Sites allocated but not yet built
• Speculative applications awaiting determination

Why it’s needed:
Current screening often ignores existing approvals, enabling developers to exploit blind spots in cumulative impact — particularly where several small schemes add up to a major footprint.

International Analogy:
Canada’s Canadian Environmental Assessment Act (CEAA) mandates landscape-level analysis in cumulative contexts, especially in Indigenous and northern territories.

📊 Policy E3 – Numerical Infrastructure Capacity Requirement (N-ICR)

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What it does:
Introduces a mandatory requirement for developers to submit quantified evidence of local infrastructure capacity, including:

• School place availability
• GP and NHS service capacity
• Flood risk thresholds and water pressure zones
• Traffic volume data and junction performance

Why it’s needed:
Consultee responses are often non-numerical and generic. This policy ensures decisions are based on real, measurable service pressure — not vague assumptions.

International Analogy:
Tokyo requires granular data on electric grid loads, public transport peak strain, and stormwater capacity for all major development approvals.

⏱️ Policy E4 – Long-Term Monitoring of Rural Impacts

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What it does:
Creates a statutory duty to monitor environmental and public service impacts for at least 10 years after completion of:

• Rural development
• Large phased projects
• Sites with known ecological, hydrological, or transport constraints

Monitoring reports must be publicly published and used to shape future permissions.

Why it’s needed:
Issues like biodiversity loss, drainage failure, and service overload often only become visible years after occupation — when it’s too late to mitigate.

International Analogy:
The Netherlands integrates post-occupancy audits into its spatial and zoning regulations for both environmental and infrastructure impact tracking.

📘 Summary

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The EIA Reform Portfolio restores discipline and foresight to the UK’s development approvals system. By enforcing lower screening thresholds, cumulative awareness, numerical infrastructure checks, and long-term monitoring, it protects rural communities and ecosystems from untracked, under-assessed growth. EIA aligns UK practice with international environmental standards of precaution and preparedness — making it clear that development must respond to real-world conditions, not abstract projections.

🎯 Objective

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To expose and dismantle coordinated developer abuse within the planning system — including shell company networks, false independence of applicants, and systematic delivery failure. CEAP provides investigatory tools, misconduct tracking, and enterprise-wide enforcement to stop abuse at its organisational root.

🧾 Policy C1 – Developer Misconduct Register (with Sanctions)

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What it does:
Creates a public, national register that lists developers who have:

• Failed to deliver as approved
• Repeatedly renegotiated obligations
• Submitted misleading documentation
• Been found in breach of planning or financial ethics

Inclusion on the register directly reduces planning weight in future applications and may trigger enhanced scrutiny.

Why it’s needed:
To disincentivise repeat abuse, protect community expectations, and shift developer culture from risk-free manipulation to transparent delivery.

International Analogy:
The UK’s Financial Conduct Authority (FCA) publishes misconduct registers for regulated firms. CEAP brings similar institutional discipline to planning.

🏢 Policy C2 – Mandatory Group-Level Enforcement Powers

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What it does:
Empowers planning authorities to treat connected developer entities as one “economic actor” when enforcing delivery obligations — closing loopholes where one shell company defaults while others proceed unaffected.

Why it’s needed:
To stop rotation schemes, where control is split across technical subsidiaries that escape enforcement individually.

International Analogy:
The EU’s Anti-Money Laundering Directive and U.S. Beneficial Ownership rules target exactly this kind of layered legal concealment.

⚖️ Policy C3 – Financial Crime Referral Protocol

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What it does:
Mandates that local planning authorities (LPAs) and the Planning Inspectorate refer suspected cases of:

• Intentional misrepresentation
• Land banking for manipulation
• Coordinated shell behaviour

to the National Crime Agency (NCA), HM Revenue & Customs (HMRC), and Competition and Markets Authority (CMA).

Why it’s needed:
Because current planning fraud often goes uninvestigated and unprosecuted due to unclear jurisdiction and lack of a statutory offence.

Note: This policy is enabled by the April legal reform proposal: “Statutory Planning Fraud by Misrepresentation or Omission”.

International Analogy:
In finance, banks are legally required to file Suspicious Activity Reports (SARs) to trigger criminal investigations — CEAP C3 brings that logic to planning.

⛔ Policy C4 – Planning Moratorium Power

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What it does:
Grants LPAs and the Secretary of State the legal power to suspend all applications and appeals associated with a developer or group under active investigation for misconduct or fraud.

Why it’s needed:
To prevent ongoing abuse during investigations, and restore trust by signalling that bad faith applicants will not proceed unchecked.

International Analogy:
Financial regulators suspend licences and trading rights — CEAP creates the planning system equivalent.

🕵️ Policy C5 – Statutory Right to Investigate Ownership & Control

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What it does:
Gives LPAs the right to demand full beneficial ownership disclosure of landowners, applicants, and all associated entities during the planning process — including trust structures and offshore holdings.

Why it’s needed:
To stop entities from hiding control, gaming multiple applications, or bypassing thresholds using shell proxies.

International Analogy:
The UK’s Economic Crime (Transparency and Enforcement) Act 2022 created similar rules for overseas property ownership disclosure.

🧠 Policy C6 – Internal Land Registry Monitoring Directive

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What it does:
Establishes a planning intelligence partnership with HM Land Registry to proactively monitor:

• Patterns of land flipping
• Suspicious clustering of shell company ownership
• EIA (Environmental Impact Assessment) threshold gaming via site fragmentation

Why it’s needed:
To detect speculative coordination early — not after communities are overwhelmed.

International Analogy:
Canada’s real estate data reforms now monitor ownership concentration and market distortion through land registry analytics.

📘 Summary

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The Coordinated Enterprise Abuse Prevention Portfolio (CEAP) recognises that planning manipulation is not just policy failure — it’s systemic, enterprise-level misconduct. CEAP introduces tools to detect, investigate, and stop developer networks that misuse the planning system to hoard land, evade obligations, or delay delivery. It protects the public interest by ensuring that control, not just paperwork, is accountable — and that abusers are stopped, not rewarded.

🎯 Objective

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To close the loopholes in viability assessments that allow developers to reduce or eliminate affordable housing obligations, delay delivery, or inflate costs and profits. VAP reasserts local authority control, mandates transparency, and ensures the public shares in development gains — not just in its risks.

💸 Policy V1 – Viability Benchmark Caps

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What it does:
Sets national or local authority-approved upper limits for developer profit margins, land value assumptions, and cost baselines used in viability assessments.

Why it’s needed:
Developers often claim a scheme is “unviable” based on inflated expectations — particularly for land value or profit. This policy defines what is reasonable, making manipulation harder.

International Analogy:
Ireland’s Land Development Agency caps land valuation inputs to ensure affordable housing remains deliverable within realistic profit margins.

🚫 Policy V2 – No Post-Permission Renegotiation

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What it does:
Prohibits developers from revising Section 106 (S106) obligations or affordable housing commitments after planning permission has been granted — except in rare, predefined, and fully transparent circumstances.

Why it’s needed:
This stops the “bait-and-switch” tactic where a generous proposal is used to secure permission, then renegotiated down once the land value rises.

International Analogy:
New York City’s Mandatory Inclusionary Housing model locks in affordable delivery expectations at approval stage.

🔁 Policy V3 – Profit Clawback Clause

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What it does:
Requires developers to share any excess profits with the local authority if actual returns exceed what was forecast in their viability appraisal — even if all units are delivered.

Why it’s needed:
To ensure public benefit from successful schemes and to discourage deliberate underestimation of profits at submission stage.

International Analogy:
London’s mayoral development process includes a “review mechanism” to capture uplift in profit margins for public reinvestment.

🔍 Policy V4 – Mandatory Viability Transparency

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What it does:
Requires the full publication of all viability assessments, assumptions, land purchase agreements, and financial modelling used to justify developer claims.

Why it’s needed:
To expose manipulation, empower scrutiny, and restore public trust. Currently, many viability assessments are shielded by “commercial confidentiality.”

International Analogy:
Toronto’s affordable housing approvals require full public disclosure of developer financial assumptions.

🧾 Policy V5 – Developer Conduct Registry

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What it does:
Creates a centralised public register of developer behaviour, including:

• Renegotiation history
• Missed delivery obligations
• Legal or enforcement actions

This registry can be used in future viability tests, weighting the credibility of repeated “unviability” claims.

Why it’s needed:
To penalise serial abusers of the viability system and reward developers with consistent delivery records.

International Analogy:
The UK’s Financial Conduct Authority (FCA) publishes records of misconduct by regulated firms. This applies the same principle to planning actors.

📘 Summary

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The Viability Abuse Prevention Portfolio (VAP) targets one of the planning system’s most damaging failure points: opaque, exploitable financial appraisals that strip out public benefit under the guise of viability. VAP restores discipline, credibility, and fairness by requiring developers to prove, not just claim, that they cannot deliver — and by making sure that when profits rise, so does public return.