Category: References

📰 Speculative Development as Inverse Harm: Why East Hampshire Needs a Planning Position Statement Now

🧭 What Is a Planning Position Statement (PPS)?

A Planning Position Statement (PPS) is a non-statutory document issued by a Local Planning Authority (LPA) to clarify how it interprets planning policy or evidence in the short term — particularly during periods of policy uncertainty or when a Local Plan is under review.

A PPS is not part of the statutory development plan, but it is a material consideration under planning law. That means it can influence decisions on planning applications and appeals.

It is legally supported by:

  • Section 70(2) of the Town and Country Planning Act 1990
  • Section 38(6) of the Planning and Compulsory Purchase Act 2004
  • Paragraph 48 of the National Planning Policy Framework (NPPF), which recognises the relevance of emerging and interim policies

A PPS is especially important when:

  • A five-year housing land supply cannot be demonstrated
  • The “tilted balance” in NPPF Paragraph 11(d) is triggered
  • The harms of development are not being properly accounted for in planning decisions

⚖️ Paragraph 11(d): What Was It Really Meant to Do?

Paragraph 11(d) of the NPPF introduces a presumption in favour of sustainable development when local policies are out of date or a five-year housing land supply is missing.

But crucially, it includes a safety valve:

Planning permission should be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework as a whole.

This clause was designed to ensure that planning decisions still reflect the public interest, not just housing targets. It was never meant to reward unplanned sprawl, unchecked landbanking, or speculative development that exploits technical shortfalls in supply.

Yet that is exactly what is happening.

🏗️ The Inverse Impact of Speculative Development

Note: The term “inverse harm” is used here to describe how speculative development and landbanking not only cause adverse impacts, but actually reverse the intended outcomes of national planning policy — particularly the sustainable development aims of the NPPF. In policy terms, these are adverse impacts under NPPF Paragraph 11(d)(ii), and must be treated as such in decision-making.

When the tilted balance is triggered without safeguards, it:

  • Encourages speculative applications with little regard for cumulative harm
  • Enables landbanking, where permissions are secured but not delivered, inflating perceived supply gaps
  • Overburdens infrastructure with no mechanism for timely mitigation
  • Erodes public trust in planning

These effects are not neutral. They are demonstrable harms.

If the NPPF requires decision-makers to weigh adverse impacts, then speculative behaviour and its systemic consequences must be part of that assessment.

These effects:

  • Undermine the delivery of actually sustainable development
  • Distort land value and delivery patterns
  • Prevent democratic, plan-led growth
  • Delay meaningful infrastructure upgrades

This is precisely the kind of situation Paragraph 11(d)(ii) was built to prevent.

📌 Why a PPS Is the Fastest, Legally Defensible Response

A Planning Position Statement can:

  • Define speculative development and landbanking as adverse impacts with measurable consequences
  • Provide interim criteria or saturation thresholds for assessing cumulative harm
  • Clarify how EHDC interprets the “significantly and demonstrably outweigh” test under current evidence

Because it is evidence-based and locally relevant, it qualifies as a material consideration in decision-making. It empowers the council and the Planning Committee to reject harmful schemes — even under tilted balance.

And crucially: it can be published quickly, without requiring examination or full Local Plan adoption.

🚨 It Is Against the Public Interest Not to Act

To allow speculative development to go unchecked — when its harmful consequences are known and preventable — is to subvert the very purpose of national policy.

  • Paragraph 11(d) was never designed to bypass planning.
  • It exists to balance the need for housing with the right to protect communities, landscapes, and services from unplanned strain.

Not using available tools like a PPS — when harm is demonstrable and growing — is not neutrality. It is a failure to act in the public interest.

🧭 Who Has Been Formally Asked to Act — and Why

We have submitted a formal request for a Planning Position Statement (PPS) to the following elected representatives, all members of the Conservative Party, who hold key responsibilities within East Hampshire District Council (EHDC) and at national level:

Cllr Anthony Williams
Chairman, Planning Committee

Cllr Charles Louisson
Vice-Chairman, Planning Committee

Rt Hon Damian Hinds MP
Member of Parliament for East Hampshire

While MPs do not decide planning policy at district level, Mr Hinds has been informed of this request in his role as constituency representative. We believe he is in a position to:

  • Champion the proposal as a matter of public interest and planning fairness;
  • Encourage EHDC to consider this approach seriously and transparently;
  • Support wider reform at national level to prevent further misuse of the tilted balance.

His support would help ensure the council acts in the spirit of sustainable, plan-led development — not speculative gain.

The request has also been formally shared with all three ward councillors for Four Marks & Medstead — Cllr Roland Richardson (also a Planning Committee member), Cllr Ilena Allsopp, and Cllr Neal Day.

As our elected representatives, they are expected to respond to the concerns of their constituents and take a public position on the call for a Planning Position Statement. Their support could help push EHDC to act decisively .

Cllr Ilena Allsopp
Ward: Four Marks & Medstead

Cllr Neal Day
Ward: Four Marks & Medstead

Cllr Roland Richardson
Ward: Four Marks & Medstead

📣 The Ask

EHDC must urgently issue a targeted Planning Position Statement recognising:

  • That speculative development and landbanking constitute adverse impacts
  • That the cumulative effects in places like South Medstead significantly and demonstrably outweigh the benefits
  • That clear thresholds or local impact triggers are necessary for fair decision-making under tilted balance

Doing nothing is not passive. It is permission by silence.

This is the lawful, rapid, proportionate intervention our district needs — and it is long overdue.

Rapid Local Intervention to Mitigate the Tilted Balance: Temporary Mechanism to Curb Speculative Development
Request for Planning Position Statement-red

Rapid Local Intervention to Mitigate the Tilted Balance: Temporary Mechanism to Curb Speculative Development

Context:

Where a local planning authority (LPA) cannot demonstrate a five-year housing land supply (5YHLS) or fails the Housing Delivery Test, the “tilted balance” under NPPF Paragraph 11(d) applies. This shifts the presumption in favour of granting permission unless adverse impacts “significantly and demonstrably outweigh” the benefits.

This document proposes a lawful, fast-acting local mechanism to mitigate speculative harm during this vulnerable period.

1. Purpose of the Mechanism:

To ensure that speculative applications — particularly those outside the Local Plan or settlement boundaries — do not benefit automatically from the tilted balance if:

  • The applicant controls deliverable land but chooses not to bring it forward
  • The application undermines infrastructure sequencing, cumulative capacity, or spatial strategy
  • The delivery benefits are overstated or unsupported by commitment

2. Action: Immediate Planning Position Statement (PPS) An LPA may adopt a Planning Position Statement to:

  • Clarify how speculative applications will be assessed during the tilted balance period
  • Establish that developer conduct and local delivery context are material to the planning balance
  • Provide transparency to planning officers, developers, and the public

3. Key Policy Points for PPS:

a. Developer Delivery Behaviour as Material Consideration

  • Where an applicant controls deliverable land and is not progressing it, this undermines their credibility in claiming housing need benefit.
  • Applications may be refused where the applicant has failed to deliver on previously approved or controlled sites.

b. Landholding Declaration Requirement

  • All applicants for major development outside the settlement boundary must submit a declaration of:
    • Land under ownership or option in the district
    • Planning status and delivery timeline
  • Failure to provide this may be treated as a procedural deficiency or reduce the weight of the application’s benefits.

c. Infrastructure & Spatial Harm Threshold

  • Proposals that exacerbate infrastructure deficits or undermine spatial planning objectives will be assessed with enhanced scrutiny.
  • LPAs may treat speculative intrusion into non-strategic locations as harm to plan coherence.

d. Temporary Weight Adjustment Clause

  • The LPA reserves the right to adjust the weight of housing delivery benefits in the planning balance where the applicant’s wider land conduct weakens the credibility or urgency of the claim.

4. Implementation Timeline:

  • Draft PPS in under 14 days
  • Publish and notify via planning portal and website
  • Apply immediately to all new speculative applications
  • Reference in all relevant officer reports and planning committee briefings

5. Legal Basis:

  • PPS is a lawful tool under the LPA’s discretionary power to define planning practice during evolving national policy contexts
  • Material considerations are determined by LPAs under established case law (Cala Homes v SSCLG, 2011)
  • No conflict with NPPF; rather, provides structure for assessing benefits versus adverse impacts more accurately
📰 Speculative Development as Inverse Harm: Why East Hampshire Needs a Planning Position Statement Now

🧾 Workplace-Based Affordability Ratios – East Hampshire (2011–2024)

YearMedian House Price (£)Median Earnings (£)Affordability Ratio
2011265,00025,79610.27
2012259,95024,73510.51
2013267,00023,41011.41
2014285,00024,14911.80
2015310,00026,84411.55
2016340,00026,43912.86
2017360,00029,44812.22
2018365,00028,99912.59
2019376,00027,97913.44
2020369,99829,65612.48
2021407,00028,50414.28
2022437,50034,02512.86
2023420,00033,13312.68
2024425,00034,48112.33

src: House price to workplace-based earnings ratio

🛡️ Myth vs Reality: Why Criminalising Planning Deception Is Justified

🎯 Proposal:

Introduce a new criminal offence:
“Planning Fraud by Misrepresentation or Omission”
— to deter coordinated manipulation, dishonesty, and systemic gaming of the planning system.

🧱 Developer Objection 1:

“Planning is already regulated.”

🔍 Reality:
Planning law governs procedure, not truthfulness.

  • Developers can submit misleading viability data, overstate constraints, or suppress sites — and still be “compliant.”
  • There is no penalty for false strategic submissions unless it crosses into provable document fraud — a nearly unreachable bar.

🧠 Ask yourself: Why does the financial sector punish misrepresentation, but planning — which governs land, public services, and environment — does not?

⚖️ Developer Objection 2:

“It’s too hard to prove intent.”

🔍 Reality: The Fraud Act 2006 already handles this.

It criminalises:

  • Dishonest false representation
  • Failure to disclose when there is a duty
  • Abuse of position

➡️ The bar is clear: knowing dishonesty or reckless disregard.
➡️ Honest developers have nothing to fear.
➡️ Only those who game the system would be caught.

🏗️ Developer Objection 3:

“It will chill investment and slow delivery.”

🔍 Reality:
That same argument was made before financial regulation reforms — and was wrong then, too.

Regulation does not stop investment. It stops fraudulent enrichment and system distortion.

In truth:

  • Manipulative tactics like landbanking and site suppression already delay delivery
  • Criminal deterrents would accelerate honest delivery, restore public trust, and unlock consent where it’s currently gridlocked

🧭 Bottom Line:

If false statements about share prices can land you in court…
then false statements about housing, infrastructure, and land use — affecting real people’s lives — should too.

✅ Criminalising deception is not red tape.
✅ It’s basic public protection.

✅ What is the Environmental Information Regulations (EIR) 2004?

The Environmental Information Regulations 2004 (EIR) are a UK legal framework that gives the public the right to access information held by public authorities about the environment. These regulations are separate from, but similar to, the Freedom of Information Act 2000 (FOIA). While FOIA covers a wide range of public information, EIR is specifically focused on environmental matters and often provides stronger access rights.

🌍 What counts as environmental information?

Under EIR, “environmental information” has a broad definition. It includes any information (in written, visual, aural, electronic or any other form) on:

  • The state of elements of the environment: air, water, soil, land, landscape, natural sites, biodiversity
  • Factors affecting the environment: substances, energy, noise, radiation, waste, emissions, discharges
  • Measures or activities: policies, plans, programmes, legislation, administrative measures or agreements that affect or are likely to affect the environment
  • Reports on the implementation of environmental legislation
  • Cost-benefit analyses and other economic aspects of environmental decision-making
  • The state of human health and safety as they relate to environmental factors

This means that information about things like local planning decisions, pollution levels, biodiversity loss, infrastructure development, and even the cumulative impact of housing on healthcare services may fall under EIR.

🏛 Who must respond to EIR requests?

EIR applies to any public authority, including:

  • Central and local government bodies
  • NHS trusts and Integrated Care Boards (ICBs)
  • Utility companies and private contractors performing public environmental functions
  • Regulators like the Environment Agency or Natural England

If a body performs public functions that relate to the environment, even if it’s not strictly a government department, it likely falls under EIR.

✍️ How do I make an EIR request?

You don’t need to mention EIR by name, but it’s often a good idea to explicitly say that you are making a request under the Environmental Information Regulations 2004 to ensure it’s handled correctly.

To make a request:

  1. Contact the relevant authority by email or post
  2. Be specific about the information you want
  3. Include a request for the information to be provided electronically (if that’s your preference)
  4. Provide your name and contact details

🕒 Authorities must respond within 20 working days. They can extend this by another 20 working days if the request is complex.

⚠️ Can they refuse?

Yes, but only under specific exceptions — and they must apply a public interest test to justify withholding the information.

Common exceptions include:

  • The request is manifestly unreasonable
  • The information is still in draft form
  • The request concerns internal communications
  • Disclosure would affect public security or intellectual property rights

However, under EIR, authorities are expected to interpret exceptions narrowly and lean towards disclosure.

💡 Why use EIR instead of FOIA?

  • EIR gives access to draft documents and background data more readily than FOIA
  • EIR imposes a public interest test on all exceptions — FOIA does not for all exemptions
  • EIR has a broader definition of what counts as public authority

This makes EIR especially powerful for environmental activists, local campaigners, journalists, and concerned residents.

🛠 Example situations where EIR applies:

  • Requesting documents related to a housing development’s impact on local GP surgeries
  • Accessing ecological surveys submitted with a planning application
  • Getting water pollution records near your area
  • Finding out about tree removal plans or pesticide use by a council

📞 What if they refuse or delay?

You can:

  1. Ask for an internal review
  2. Complain to the Information Commissioner’s Office (ICO)

The ICO takes EIR rights seriously and can require authorities to release information.

✅ Bottom line:

The Environmental Information Regulations 2004 are a powerful but underused tool that lets you hold public bodies accountable for their decisions about the environment. Whether you’re concerned about planning, pollution, or infrastructure — use your right to know.

Knowledge is power. Use it well.

It ain’t over till the fat lady singsIt Ain’t Over Till the Fat Lady Sings: Parish Council Update on Beechlands Road Planning Application

📍 Current Status of the Planning Application:

StageStatusDeadlineImplication
Committee Decision✅ ApprovedCompletedCommittee voted to approve, but not yet legally binding.
Decision Notice❌ Not Yet IssuedAwaiting S106No formal planning permission currently exists.
Section 106 Agreement⚠️ Still Outstanding30 April 2025 (official extension)Must be completed before the decision notice can be issued.
S106 Final Deadline⏳ Soft LimitOctober 2025Final fallback deadline unless explicitly extended by senior officers or councillors.
Judicial Review Window⏳ Not Yet OpenedStarts at Decision Notice publicationJR challenge can only formally start once the decision notice is published.

What’s Happening Now?

Despite approval by East Hampshire District Council’s (EHDC) Planning Committee, the Beechlands Road planning application is not yet legally binding. This means the final decision notice hasn’t been published, and planning permission isn’t officially granted.

Why the Delay?

Before EHDC issues the formal Decision Notice, they must complete a Section 106 (S106) Agreement—a legal contract ensuring that developers deliver necessary infrastructure, affordable housing, or public open space. This crucial document is still outstanding, and EHDC has set a formal extension to complete it by 30 April 2025, with an ultimate fallback deadline of October 2025.

Parish Council’s Response

Understanding the importance of the situation, Medstead Parish Council has taken decisive steps:

  • Legal Advice: They’ve decided to seek legal opinions from two independent sources:
    • A Specialist Planning Barrister, who generously offered a free review of the Judicial Review grounds.
    • The Hampshire Association of Local Councils (HALC) Planning Consultation service.

The Parish Council has promptly provided essential documents to the barrister.

Next Steps

The Parish Council will carefully review both legal opinions once received. This proactive approach ensures they’re fully informed and ready to respond swiftly and effectively.

What Does This Mean For Residents?

  • Judicial Review: Residents still have an opportunity to challenge the decision. It’s important to note that a Judicial Review is not an appeal; rather, it examines whether the decision-making process was lawful and fair, rather than reconsidering the planning merits themselves. The Judicial Review clock only begins when EHDC publishes the formal Decision Notice.
  • Application Vulnerability: If EHDC fails to finalise the S106 Agreement by 30 April 2025, the application risks lapsing unless officially extended.
  • Stay Engaged: Community vigilance is crucial. Monitor updates closely, as the finalised S106 terms and conditions could still influence the local impact significantly.

As always, your active involvement and support remain essential. Stay informed, stay engaged, and remember—it’s not over until the final decision notice is signed and published.

Stay tuned to this page for further updates.

Special thanks go to Parish Councillor Patricia Hughes and Clerk Mrs Julie Russell, whose dedication and swift actions have been instrumental in coordinating these critical efforts.

Medstead saw a much higher proportional growth than the district average — nearly 5.5 times higher than EHDC’s overall rate

Regulation 6(1) of the 2017 EIA Regulations:

“A person who proposes to carry out development may request the relevant planning authority to state in writing their opinion as to whether the development is EIA development (a ‘screening opinion’).”

⚖️ Case law support:

🧾 R (on the application of Wingfield) v Canterbury City Council [2019] EWHC 1975 (Admin)

  • Confirmed that an EIA screening must apply to the actual development proposed by the applicant.
  • Cannot rely on a screening opinion for a different proposal — even on the same site.

🧾 R (Burridge) v Breckland DC [2013] – also confirms project-specific EIA obligations, especially when components are linked.

🧷 Simple conclusion you can rely on:

You cannot transfer or reuse a screening opinion from one developer to another, or from one application to another, even on the same land.

If EHDC allowed this — it’s a breach of the EIA Regulations 2017.

THE CURIOUS CASE OF UNLAWFUL RECYCLED SCREENING OPINION … No, Nicky — You Can’t Sell Expired Sausages You Found in the Neighbour’s Garden

Once more, Nick’s creative modus operandi was brought upon us, and yea, the balance was tilted. Creativity is a fine mindset — essential, even — if you’re a fashion designer. But if it’s your foundation in accountancy, you’d be done for it. Apply with caution — if you’re a public servant!

In a recent letter from Nick Upton, Development Manager at EHDC, we see either a profound misunderstanding of how the EIA1 Regulations apply — or something more deliberate. He writes:

“The government does not see EIA regulations as a barrier to growth and that they will only be triggered for a small proportion of very large-scale proposals that have potential impacts outside the area they are located in, such as power stations, major urban extensions, airports for example.”

This conveniently omits any reference to residential development and ignores how the significance of environmental effects must be judged relative to the settlement type — i.e. village versus town or city. It also skips over the requirement to consider cumulative impact, explicitly required by Schedule 3 of the 2017 EIA Regulations.

While it’s true the government doesn’t intend EIA to be a barrier to growth, it is also true — and far more relevant — that the government requires EIA screening by law. That part, Mr Upton does not mention.

Instead, he offers a line designed to mislead:

“The fact that a formal EIA is not required does not mean the applicant does not need to submit environmental information… This was the case with the Beechlands Road scheme.”

This is meant to imply that because “some environmental information” was submitted, no formal EIA screening was necessary — when in fact, the law is clear: the presence of environmental information does not override the mandatory requirement for a lawful, up-to-date EIA screening opinion.

It’s not just misleading. It’s legally irrelevant — and procedurally flawed.

Mr Upton carries on with his gospel:

“You mention that the developer has fragmented the site to avoid the mandatory Environmental Impact Assessment regulations (EIA). Whilst you’ve not provided any evidence of this, in any case, the EIA regulations do allow for a consideration of cumulative developments if and when any future proposal comes forward.”

That statement is deeply problematic — both legally and logically.

By suggesting that cumulative impact can be assessed “if and when any future proposal comes forward,” Mr Upton engages in a classic deferral fallacy. But Schedule 3, Paragraph 1(b) of the EIA Regulations 2017 is explicit:

“The cumulation with other existing and/or approved development.”

This clearly includes existing and reasonably foreseeable phases, especially:

Delaying cumulative assessment until “next time” defeats the entire purpose of EIA screening, which is to detect and prevent significant environmental harm before permission is granted.

Mr Upton also implies it is my job as a resident to prove the developer is salami-slicing — but that is not how the law works.

Under Schedule 3(1)(b) of the EIA Regulations 2017, and reinforced in case law (R (Burridge) v Breckland DC [2013]), it is the LPA’s legal duty to:

  • Identify potential site fragmentation, and
  • Assess cumulative impacts from related developments

It is not the role of a resident to prove this has occurred. The responsibility lies squarely with the decision-maker — in this case, EHDC.

And then the mind-blowing connection struck me:

Mr Nick Upton himself was the case officer who issued the EIA screening opinion for the original 2014 application — a proposal for 144 dwellings on 4 hectares of land by Foreman Homes. That development, in scale and intensity, was more appropriate for a town, not a rural village like Medstead, and clearly posed a risk of significant environmental harm.

And now? It just so happens that Mr Upton is also the supervising officer overseeing the Bargate Homes Phase 2 expansion — a continuation of large-scale development to the south of Medstead — and once again, no new EIA screening opinion has been issued.

Conveniently, he appears to have:

  • Ignored the legal requirement that EIA screening opinions are non-transferable between applicants
  • Failed to apply the updated 2017 EIA Regulations, which clearly state that EIA screening opinions are only valid for three years
  • Completely overlooked the obligation to consider cumulative impact, even as Medstead experienced a 48.14% population increase from 2011 to 2021
  • Dismissed the significance of the proposal simply because the current scheme is for 62 dwellings, compared to 144 in 2014 — as though scale alone determines significance, rather than context

To be clear: Medstead makes up just 1.76% of East Hampshire’s population, yet it absorbed 8.36% of all new housing in the district from 2011 to 2021. That level of disproportionate growth alone should have triggered an up-to-date, cumulative environmental screening.

⚠️ What is most outrageous?

Planning committee members are not legal officers — they rely on the professional advice of planning officers to ensure their decisions are lawful. And yet:

  • No reference to Schedule 3 criteria was provided
  • The committee was led to believe that the 2017 EIA Regulations have somehow reduced screening obligations
  • The absence of a valid screening opinion was never disclosed

This amounts to a misrepresentation of the legal position and likely misdirection of elected members on a matter of material legal consequence.

This constitutes a procedural error and presents a clear ground for Judicial Review, based on misdirection and unlawful avoidance of EIA screening duties.

Medstead saw a much higher proportional growth than the district average — nearly 5.5 times higher than EHDC’s overall rate
Regulation 9(2) of the EIA Regulations 2017
Regulation 6(1) of the 2017 EIA Regulations:
📘 Schedule 2, Category 10(b) – Urban Development Projects
  1. If you think of an EIA as a full medical workup before major surgery — detailed, evidence-based, and critical — then the EIA screening opinion is like triage: do the current symptoms or known risk factors (including past conditions) justify ordering tests — in this case, a full EIA? Local Planning Authorities (LPAs) are legally required to provide reasoning for every screening decision. But too often, LPAs treat the screening as a tick-box exercise. They rely on vague boilerplate phrases like “not likely to have significant effects,” skip cumulative assessment, or recycle old screening opinions from unrelated applications. Worst of all: they get away with it unless someone legally challenges them. And yes, EIA screening opinions can be legally challenged via Judicial Review. ↩︎

⚖️ Can Developers Be Held Accountable for Salami-Slicing?

✅ 1. Refusal or Retrospective Screening

If it becomes clear that a developer intentionally split a site to avoid triggering EIA:

  • The LPA can refuse subsequent applications on environmental grounds
  • The Secretary of State can direct that EIA is required under Regulation 5(7)

👉 This doesn’t punish the developer directly, but it prevents the avoidance from succeeding.

✅ 2. Judicial Review (JR) – Indirect Legal Exposure

While JR is aimed at the LPA, not the developer, it can still:

  • Invalidate planning permission granted based on flawed screening
  • Delay the developer’s project
  • Force a full EIA and resubmission, often with public backlash and added cost

👉 A developer who is seen to have manipulated the process can lose time, money, and reputation.

✅ 3. Environmental offences under broader law

In extreme cases, a developer could fall foul of:

  • The Environmental Protection Act 1990, if harm is caused and concealed
  • Misrepresentation in planning documents (can lead to enforcement action or judicial consequences)

⚠️ But this would usually require:

  • Intentional deceit (e.g. knowingly misleading the LPA)
  • Evidence of environmental harm or risk concealed by phasing

✅ 4. Challenge via Secretary of State (Call-in powers or EIA direction)

Under Regulation 5(7) and Section 77 of the Town and Country Planning Act 1990, the Secretary of State can:

  • Intervene and require an EIA for what appears to be a fragmented or disguised larger development
  • This can be triggered by public or councillor pressure

🧠 Summary:

Legal ToolWho It TargetsOutcome
Judicial ReviewLPA (indirectly affects developer)Invalidates permission
Reg. 5(7) EIA DirectionDeveloper/projectForces full EIA
Enforcement / refusalDeveloperBlocks or delays application
Secretary of State call-inBothSuspends and reopens application

📌 Final Thought:

While developers aren’t prosecuted criminally for salami-slicing, their schemes can be legally derailed if challenged correctly. What matters most is exposing the pattern — which your case does effectively