01 – Planning Market Integrity Portfolio (PMI) 🏗️

🎯 Objective


To restore fairness, accountability, and functional land use in the UK planning system by ensuring land is developed responsibly, transparently, and in alignment with public need — not held speculatively or manipulated for private timing advantages.

⏱️ Policy P1 – Time-Bound Delivery Enforcement (with Financial Consequences)


What it does:
Mandates developers to begin and complete construction within defined timeframes post-permission. Non-compliance triggers:

  • Financial penalties
  • Potential revocation of permission

Why it’s needed:
To end speculative land banking and ensure planning approvals translate into housing supply.

International Analogy:
In Germany, planning approvals often expire if unused — forcing delivery or release.

🌍 Policy P2 – Progressive Land Tax or “Use-It-Or-Lose-It” Measures


What it does:
Applies escalating annual taxes to undeveloped land with planning permission.

Why it’s needed:
To disincentivise land hoarding and unlock land supply.

International Analogy:
France imposes a rising tax on idle, zoned land to push development forward.

📉 Policy P3 – Deliverability Penalty Points for Developers


What it does:
Implements a national points system where developers accumulate reputation penalties for:

  • Delivery failure
  • Repeated renegotiations
  • Speculative withholding

Points affect access to future planning approvals and land release opportunities.

Why it’s needed:
To reward track records — not merely capacity — and deprioritise habitual manipulators.

International Analogy:
New South Wales (Australia) uses a performance-based weighting system for future bids.

🧾 Policy P4 – Mandatory Transparency: Land Ownership and Control Monitoring


What it does:
Requires developers to disclose:

  • Full beneficial land ownership
  • Offshore structures and related parties
  • Changes in control post-permission

Why it’s needed:
To expose land speculation via shells and trusts, and stop ownership opacity being used to evade delivery duties.

International Analogy:
The UK’s Register of Overseas Entities (ROE) addresses similar opacity in real estate.

🏘️ Policy P5 – Front-Loading Affordable Housing & Infrastructure


What it does:
Mandates that a significant share of affordable housing and essential infrastructure be delivered in the first phases of large developments.

Why it’s needed:
To prevent deferral tactics and ensure communities see real benefit early.

International Analogy:
The Netherlands requires upfront provision of infrastructure and social housing in masterplan agreements.

🧮 Policy P6 – Raised Affordable Housing Requirement on Speculative or Tilted-Balance Sites


What it does:
Increases affordable housing quotas where applications are:

  • Approved under reduced policy standards (e.g. due to 5YHLS shortfall)
  • Made outside plan allocations or on appeal

Why it’s needed:
To ensure speculative gain is matched by elevated social return.

International Analogy:
Many U.S. cities use inclusionary zoning escalators in high-opportunity or speculative locations.

🏚️ Policy P7 – “Stay or Pay”: Primary Occupation Requirement for New Residential Properties


What it does:
Requires new homes to be occupied as primary residences within 12 months of legal completion. Failure to do so triggers a progressive annual vacancy tax. Applies to individuals and legal entities (e.g. developers, trusts, holding companies).


🔐 Anti-Circumvention Clauses:

  • Rolling Occupancy Clock: Clock continues through ownership transfers — resale or shell transfers do not reset it.
  • Portfolio Holding Limits: Entities may not retain >2 unoccupied units/phase beyond 12 months without triggering tax.
  • Strict Exemptions: Only registered social landlords, Homes England-accredited affordable schemes, or key worker leasing models are exempt.

📊 Reporting Obligation: Vacancy-to-Delivery Ratio (VDR)

Developers must publish quarterly:

Vacancy-to-Delivery Ratio (VDR):

VDR = Units unoccupied > 6 months Total completed units that year

VDR is used to:

  • Influence S106 negotiations
  • Inform developer penalty scoring (P3)
  • Guide permission eligibility

💸 Vacancy Tax Schedule:

Vacancy DurationAnnual Tax (% of property value)
Year 1 (grace)0%
Year 22%
Year 34%
Year 4+5%
  • Assessed on Land Registry sale price or banded council valuation (whichever is higher)
  • Indexed annually to inflation or price indices

🧾 Enforcement & Public Transparency:


  • LPAs must maintain a “Homes In Use” register
  • Tax revenue ring-fenced for affordable housing and local infrastructure
  • Randomised audits and occupancy declarations annually

⚖️ Strict Auditable Exemptions:


  • Probate/delay due to owner death
  • Hospitalisation or institutional care
  • Active key worker tenancy
  • Armed service deployment

International Analogies:


  • Vancouver’s Empty Homes Tax: 3% vacancy tax → >$115M raised for housing funds
  • Singapore’s ABSD: Up to 30% surcharge on unoccupied second properties
  • Banking Analogy: Similar to capital charges on idle or underperforming assets

📘 Summary


The Planning Market Integrity Portfolio (PMI) dismantles the speculative logic embedded in the UK’s planning system. It ensures land is not only approved for use, but used for homes — with delivery, transparency, and occupancy enforced. PMI transforms speculative permissions into enforceable promises, and realigns private strategy with public need.

🧾 Update: Parliamentary Request for Action on Planning Fraud and Developer Deception


🏠 The Hidden Economics: Landbanking, House Prices, and the “Need” Myth


Local authorities should function like dialysis — not to cure the disease, but to filter out harm, maintain system function, and prevent collapse while the root pathology is addressed.

But the core disease here is not poor planning. It’s an organised, developer-aligned oligarchy — not yet criminal by classification, but operating in sync, exploiting loopholes, applying pressure to an already compromised system, and then presenting themselves as the solution. It’s not just corruption of process; it’s a system under stress, being deliberately stressed further for gain.

Housing targets themselves – as they are calculated now – are not fixed metrics; they are reactive. They rise in areas where house prices rise faster than wages. If the key driver is the Affordability Ratio — the ratio of median house prices to median local earnings — then the higher the ratio, the greater the assumed “need” for housing, and the higher the target — regardless of whether local supply is being withheld or manipulated upstream.

🧠 Context:


If you think of an Environmental Impact Assessment (EIA) as the diagnostic filter used to protect a critically ill patient on dialysis — identifying external stressors that could trigger collapse — then the EIA screening opinion is like triage: does the proposed intervention (the development) show symptoms or risk factors that justify closer investigation to protect the patient — the land, the community, the environment?

Legally, councils are required to give reasons for why an EIA is or isn’t needed. But in practice — by their own choice, since nothing in the NPPF prevents them from designing a more robust process — many Local Planning Authorities treat this screening as a tick-box exercise.
They reuse vague phrases like “not likely to have significant effects,” lean on the selective blindness of individual officers — sometimes framed as “expert opinion” — ignore cumulative developments, and rely on outdated or incomplete assessments.

It’s like checking the vitals but skipping the bloodwork — ignoring infection markers to keep the charts looking stable.
Each individual site passes, but no one asks why systemic stress is escalating. It’s a system that refuses to detect organ rejection or environmental shock — because each stressor, viewed in isolation, still meets the baseline.

Worse still: they get away with it — because the only way to challenge it is through Judicial Review. And very few residents or parish councils have the resources to go to court.

Meanwhile, councillors are under political pressure to deliver housing numbers — but it is the planning officers who prepare the reasoning reports, interpret public responses, summarise consultee feedback, and determine what information is shared (or withheld) during the process. Officers who consistently deliver “results” may be mistakenly seen as high performers, even when the delivery is built on procedural shortcuts, minimised evidence, or filtered consultation.

In this self-reinforcing cycle, councillors hear what reassures them, officers see what confirms their intent, and together, they say only what’s needed to justify hearing nothing else.

Public consultation becomes another compromised tool.


Instead of informed consent, it’s like giving the patient a form with the critical risk section left blank — or worse, pre-filled with misleading data — then asking them to sign off with a space that says, “Tell us something about yourself.”
A question designed not to inform treatment, but to create the appearance of participation, while ensuring that any response can later be dismissed as non-material to the outcome.
Omissions are routine; relevant questions go unasked; dissent is procedurally acknowledged and practically ignored.

📍 Where We Are Now


On 16 April 2025, I formally submitted a request for Parliamentary action to Rt Hon Damian Hinds MP, raising concerns over the growing exploitation of loopholes in the planning system by major developers.

My submission included:

  • A letter requesting that Mr Hinds support the creation of a new criminal offence:
    “Planning Fraud by Misrepresentation or Omission”
  • A one-page proposal outlining the rationale and legal basis for this reform, including specific recommendations for Parliamentary and Select Committee action.

Damian Hinds’ office responded supportively and offered to forward the submission to the relevant Minister for a response on whether a legal gap exists.

I’ve confirmed that I welcome this step — but have also asked Mr Hinds to share his personal stance on the matter and consider using the other Parliamentary avenues at his disposal to support action. This issue goes beyond ministerial delegation: it is about public integrity, enforceability, and preventing systemic abuse in planning across the country.

This is the first step in what I hope will become a wider campaign to close the legal gap around developer deception and protect communities from coordinated planning manipulation.

More updates will follow as the response progresses.

The Proposal


I have asked Damian Hinds MP to:

  • Table a Private Member’s Bill, or support legal reform through other routes;
  • Refer the issue to the Housing and Local Government Select Committee;
  • Raise the matter in Parliament;
  • Use his position to support legislative engagement with DLUHC (Department for Levelling Up, Housing and Communities).

📉 What is Stock Market Manipulation?


Stock market manipulation refers to deliberately misleading the market to distort prices or trading volumes for personal gain. Common forms include:

  • Pump and dump schemes (artificially inflating share price then selling)
  • Spreading false or misleading information
  • Coordinated trading to create a false sense of demand
  • Wash trading (buying and selling to yourself to simulate activity)

⚖️ Is It Illegal in the UK?


Yes — under the Financial Services and Markets Act 2000 and Market Abuse Regulation (EU MAR), such conduct is strictly prohibited. The Financial Conduct Authority (FCA) can:

  • Impose fines
  • Ban individuals from working in financial services
  • Pursue criminal charges, which can carry up to 7 years’ imprisonment

🧩 So Why Is This Relevant?


Because in the planning system:

Developers can as of yet legally engage in landbanking, planning pressure tactics, and even site suppression for leverage — all of which are comparable in structure to stock manipulation — but face no criminal penalties.

In essence:

If you manipulate shares, you risk prison.
If you manipulate planning policy, you might get a bonus.

Criminalising deception is a starting point — an absolute must — even if only as a preventative measure to make potential beneficiaries of such disinformation think twice before doing it again.



✊ A Word About the Campaign


I’m just one person. A one-person orchestra trying to show the path forward — but I don’t expect things to change unless others stay vigilant too. One of the quiet goals of oligarchic systems — whether in authoritarian states or hidden within corporate lobbying — is to wear down public vigilance. To make the average person believe it’s too complicated, too fixed, or too late to challenge what’s wrong.

But it isn’t.