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Corporate makeover: new vehicles for delivering growth?
Weekend newspaper reports on the Government’s attempts to avoid economic Armageddon included that perennial favourite, planning reform. The Sunday Times reported: “Cummings and Jenrick are also backing a new fast-track system for developers of high-quality, well-designed buildings. And they will move to a zonal planning system where key decisions will be taken from local councils and handed to development corporations — though building on the green belt will not be permitted.” Like Back to the Future or an Audi Quattro, the reference to development corporations (DCs) cannot fail to draw one back to the 1980s. 3,600 hectares of derelict land were redeveloped by 13 urban development corporations (UDCs) established between 1981 and 1993 as flagships of Government regeneration policy[1]. In the main, these UDCs had some form of plan making, development management and land assembly powers, as well significant funds to support their implementation. For every £1 of public sector investment in these UDCs, some £3.45 was leveraged from the private sector[2] with 8.4 million m2 of commercial floor space, 44,000 new housing units, and over 253,000 jobs[3]. Alongside some enduring urban transformations[4], there was a more disputed social and economic legacy, alongside a debate over governance and local accountability. A new generation of UDCs emerged in 2004 (London Thames Gateway[5], Thurrock Thames Gateway and West Northamptonshire[6]) which ended their life in 2013 and 2014. Under the Localism Act 2011[7] three Mayoral Development Corporations were established: London Legacy (2012), Old Oak Common (2015), and South Tees (2017).  In 2015, a Development Corporation was established for the Ebbsfleet Garden City[8]. Development Corporations have been a touchstone of property-led regeneration activity for the past forty years, and they look likely to be part of the new planning agenda for economic recovery. It is dangerous to draw too much inference from sketchy media reports, but the Sunday Times piece does raise some questions about their future role and nature, and it generated a minor social media storm among some members of the planning fraternity. This blog looks at some considerations for this new generation of DCs with specific reference to planning for large-scale housing growth. Whats new? The role of Development Corporations in taking forward the Government’s growth agenda is not new. In 2018, the Government produced regulations[9] to enable the creation of locally-led new town development corporations (LLNTDs) instigated by (and under the oversight of) local authorities, rather than the Secretary of State, whose role would be to designate them. In October 2019, the Government consulted on the future of DCs[10] with the stated purpose being: “to seek views on whether this varied legal framework inhibits the operation of development corporations, and to invite ideas on how the legal framework might be reformed. We want to hear your views on whether, and how, legislative reforms might ensure that, where it is appropriate for a development corporation to be used, a fit-for-purpose model exists.” On 11th March 2020, the Budget ‘red book’ announced its intention to produce a Spatial Framework for the OxCam Arc and stated[11]: “The government is also going to examine and develop the case for up to four new Development Corporations in the OxCam Arc at Bedford, St Neots/Sandy, Cambourne and Cambridge, which includes plans to explore the case for a New Town at Cambridge, to accelerate new housing and infrastructure development.” Regeneration or Delivering Housing? In the 2019 Consultation, the Government identified two roles for development corporations: “delivering much-needed housing for the long term” and “leading, at pace, the critical regeneration that will help to boost development of areas that have not fully shared in the country’s recent economic growth”. To date, the dominant role of DCs has been regeneration, rather than in unlocking new settlements in greenfield locations. The West Northants DC (WNDC) was initially established in 2004 with a housing delivery focus, but it encountered difficulties, and after five years – and in the aftermath of the financial crisis - its focus shifted towards regeneration projects. A review of WNDC by the European Institute for Urban Affairs (EIUA) - part of Liverpool John Moores University - found: “By common consent it had a very difficult start, as the area simply wasn’t prepared for a massive amount of housing development in terms of infrastructure, planning policy and community support”[12] EIUA went on to draw wider lessons for the future role of UDCs[13], including the key observation that they were more suited to “tightly definable urban challenge of such complexity, specialised nature, scale or intensity that a special purpose vehicle of this type is necessary… [and that] other types of vehicle are likely to be more appropriate in planning and developing major new settlements and delivering comprehensive growth programmes.” In our research on Garden Communities, we identified that the only Development Corporation involved in delivering the programme is that at Ebbsfleet, established to help accelerate and enhance the implementation of a proposal where the principle of development had already been established, with planning permissions in place for most of the key strategic sites, and with a brownfield and regeneration focus. Designation or delivery? This takes us to the key questions for the next generation of Development Corporations. What might they be there to achieve? What obstacles are they trying to overcome? The wording of the Sunday Times article points to the Development Corporations sitting alongside a zonal planning system. At one level, having Development Corporations as a delivery vehicle – exercising control, coordinating activity, driving quality and focusing investment in an area already zoned for development - is not itself new; by and large, this type of role is accepted and understood. The bigger planning question is who selects the locations for growth - strategic zoning, if you like - and how large is the canvass for spatial choices to be made? There is no modern precedent for a Development Corporation successfully formulating a strategic or local plan that has to decide on the selection of broad locations for growth across or between settlements and districts. It is this challenge – coupled with the ability to demonstrate deliverability of these plans for long term growth - that poses the more immediate barrier for the trickier larger-scale projects, as numerous local authorities and developers will testify. Attempts to circumvent (or accelerate) the more traditional plan-led routes – for example, through the Eco Towns programme - were problematic. As then-Planning Minister Brandon Lewis commented[14] in 2014: "Despite a pledge of 10 new towns by the last government, the eco-towns programme built nothing but resentment. The initiative was a total shambles, with developers abandoning the process, application for judicial review, the timetable being extended over and over, and local opposition growing to the then government’s unsustainable and environmentally damaging proposals." The Budget announcement on 11th March 2020 pointed to future DCs operating in four defined locations within the OxCam Arc, but the extent to which these vehicles these would select the sites within these areas was not defined. The Government said it would “examine and develop” the case for the corporations and in doing so, for Cambridge, it would “explore the case for a New Town at Cambridge, to accelerate new housing and infrastructure development”. But how would it make this spatial strategy choice? As the time of writing, new local plans for three of the four identified areas in the Arc are in the early stages of preparation[15], and the Government has also announced – confirmed in Planning for the Future[16] – that the new DCs would be accompanied by a spatial framework that would: “give certainty to businesses and developers about where new housing and employment will be delivered until 2050 and support planning for the right infrastructure to meet social, environmental and economic needs.” It is the Government's approach to this spatial framework that is more interesting. How will it be prepared? Into how much detail will it go? What will be its status and relationship to Local Plans? What’s next? The media reports are not inconsistent with the Government simply working up its response to the 2019 Consultation on the potential for more effective use of DC powers (e.g. on land assembly, site planning, funding, coordination, and development management), in tandem with the enhanced use of zoning provisions (inherent in the approach of local development orders (LDOs), which were also referred to in Planning for the Future). Perhaps there is no need for excitement. But some have interpreted this to mean the Government is looking to accelerate a more radical reshaping of the planning system as part of the 'Great Recovery Bill'. (The risk of dissonance in instigating wholesale planning reform at the same time as seeking to stimulate development in the short term is a debate for another day).  Development Corporations shaping and delivering growth in regeneration areas and in specific locations allocated by local plans is one thing - but this will require rapid local authority plan making in order to make progress. It is quite another to have these vehicles use plan making powers (or LDOs, or perhaps an amended NSIP route) to ‘zone’ new locations - and by default - make fundamental strategic choices about the spatial distribution of development across or between districts. It would raise a series of questions, not least over the legal framework for plan making (e.g. over SEA) and consistency with the Government’s persistent support for localism and a plan-led system. It might be that DCs – or some other form of special purpose vehicle - can be created in advance of local plans – perhaps at the instigation of local planning authorities – to drive or support the promotion of large-scale schemes through those plans (perhaps pursuant to the OxCam Arc framework in that area), and address the questions over implementation[17] but this would still involve such Corporations working with the grain of plan making (in its current form, or recast in line with any Policy Exchange-type approach[18]) not as a replacement for it. They will also need the backing of long-term infrastructure funding to deal with the infrastructure challenges inherent in these schemes. Compared to their 1980s/1990s heyday, DCs have had relatively selective use in the 2000s. If Government reinvigorates them as a tool for spearheading regeneration alongside an economic recovery plan for existing towns and cities, it would be a case of back to the future. If they are to also drive forward large-scale housing growth in greenfield locations chosen by local plans, the Government will need to reflect on the lessons of WNDC and also drive forward local plan making. If they are to go further and be used to circumvent a sometimes sclerotic plan-making process they will need to put meat on the bones of the OxCam spatial framework (and think how strategic location decisions are going to be made elsewhere). But be in no doubt, Development Corporations are no panacea, and having them choose directly where development goes could make the controversy of Eco Towns look like a picnic.   [1] 1981: London Docklands and Merseyside; 1987: the Black Country, Cardiff Bay, Teesside, Trafford Park and Tyne & Wear; 1988: Central Manchester, Leeds and Sheffield in 1988; 1989: Bristol; 1992: Birmingham; 1993: Plymouth[2] DETR (1998) Urban Development Corporations: Performance and Good Practice, DETR[3] Summarised in this report by the Investment Property Forum. [4] Perhaps best exemplified by establishment of Canary Wharf as global financial centre on the Isle of Dogs, the Royal Albert Docks in Liverpool, and the (mostly) well considered urban developments achieved on the banks of the river Tyne.[5] Covering the Lower Lea Valley and London Riverside.[6] Covering Northampton, Daventry and Towcester[7]  And the subsequent Cities and Local Government Devolution Act 2016 which extended the powers to Combined Authorities[8] Ebbsfleet Development Corporation[9] New Towns Act 1981 (Oversight Authority) Regulations 2018[10] The consultation paper is here[11] See para 2.129 of the the Budget[12][13] Summarised on page 165 here[14] See Ministerial Statement:[15] For example, Bedford is about to begin the process of preparing an updated or replacement plan for Reg 19 submission by 2023; whilst the Greater Cambridge Local Plan began its plan making journey in 2020.  The Huntingdonshire Local Plan was adopte.d in 2019, and included the original 2010 eastern extension to St. Neots[16] Available here[17] Such as those that plagued the Garden Communities in Hart, Uttlesford and North Essex – as explored in my blog[18] Rethinking the Planning System for the 21st Century. Header image: Audi Quattro, © Andrew Bone


New settlements in local plans: Not everything in the garden is rosy
Recent Inspectors’ findings on local plans have shone a light on the challenges of allocating large-scale new settlements and Garden Communities (GCs). Most recent was North Essex where an experienced Inspector - Roger Clews - concluded two of the three proposed GCs should be deleted in order for the Shared Strategic (Section 1) Plan to proceed[1]. This followed the plans for neighbouring Uttlesford - withdrawn after the Inspectors found[2] multiple problems (including with two of its three GCs) - and Hart - adopted but only after its Shapley Heath GC was removed[3]. This has reignited the debate about whether the Local Plans system is appropriate for judging soundness on these inherently difficult, uncertain projects. Are Inspectors being over-zealous? Is the bar set too high? Are plan makers constrained in their ability to advance visionary, long-term strategic projects? In response to the North Essex findings, MHCLG was quoted[4] as saying: “We remain committed to supporting new garden communities and helping these schemes to get off the ground… [we] applaud the ambition of the North Essex authorities and will consider whether this plan raises any questions for how large sites are examined in the future". This blog explores the theme of deliverability arising from these recent plan examinations. It sits alongside the Lichfields Insight report on Garden Communities – How does your garden grow? – which is counterpoint to this blog’s focus on failure, in noting that many GCs have successfully been allocated. What is the relevant policy and guidance? First off, one should exercise care in making judgements about the adequacy of current policy based on these Inspectors’ conclusions: the North Essex, Uttlesford and Hart plans are/were being examined under the previous 2012 NPPF[5] whereas future Local Plans will be tested against the 2018/19 NPPF and associated guidance. The current suite of policy and guidance now includes: NPPF Para 72 which identifies the specific factors for how plan makers should identify locations for larger scale developments; Revision to the NPPF test of soundness at para 35 b) such that threshold for plans is for them to be “an appropriate” strategy, replacing “the most appropriate” in 2012; a subtle but important lowering of the bar to avoid a situation where the best is the enemy of the good; Guidance[6] that says the relevant test on strategic matters including new settlements is for there to be a “reasonable prospect these large scale developments can come forward” and that “strategic policy-making authorities are expected to make a realistic assessment about the prospect of sites being developed (and associated delivery rates)”. The guidance goes on to recognise, inter alia, that: a. “there may not be certainty and/or the funding secured for necessary strategic infrastructure at the time the plan is produced.” b. Developments may extend beyond the plan period; reviews and updates should be used to provide greater certainty about delivery of the agreed strategy and considering alternative strategies if necessary. So, new Local Plans will be considered against a policy backdrop that, perhaps, has a clearer acknowledgement of uncertainty, including on infrastructure. (I say perhaps, because similar messages were in the original NPPF definition of ‘developable’ and in a now withdrawn part of the PPG[7]). However, plan makers will still need to demonstrate a reasonable prospect of the development coming forward, and its place in the trajectory of the local plan (and the reliance of the plan on it) should be consistent with that. The up-front focus on viability - designed to reduce the 'wriggle room' on viability at application stage - is also a counterweight.  Delivery in the plan period Many local plans expect ambitious GC schemes to deliver rapidly and at pace. This raises the stakes. Deliverability can be judged more leniently if schemes are more cautiously phased towards the back-end of the plan (or is a reserve site), albeit this may raise questions about how needs earlier in the plan period are to be met[8]. Across the Government’s Garden Communities programme, the average contribution of such schemes to local plan housing requirements is 30%, but can be as high as two thirds[9], with expectations often for them to be on site very quickly, at high build-out rates. The reality for large site delivery is often that they take many years to come forward and have highly variable build out rates (as shown in Start to Finish) so it is up to site promoters and plan makers to produce a clear, evidenced delivery plan - bespoke to the circumstances of that GC - to explain why its delivery expectations are justified. If plan ambitions turn out not to be realistic, it would render the plan unable to meet its housing needs. In Uttlesford, the Plan was expecting housing delivery on its GCs as soon as 2023/24 which one scheme’s own promoter thought was not realistic[10]. In North Essex, two of the GCs were scheduled to begin as early as 2024. It is also necessary to gauge the impact on housing supply objectives if plans are to be adopted with GCs removed. In Uttlesford, the GCs were ‘hard-wired’ into the plan’s ability to meet needs; removing one of the GCs as the Inspectors recommended (and with significant work required on the other two to justify their ambitious trajectories) unravelled the whole plan strategy. But in Hart and North Essex, the existing pipeline of other housing sites meant the failed GCs were not fundamental in the same way[11] and the plan could proceed with modifications. Long term strategies beyond the plan period GCs typically build out beyond a plan period. Only 7,500 of the c.43,000 homes in the North Essex GCs were for the plan period and long-term strategic growth was cited as a key reason for selecting its spatial strategy. This principle was explicitly accepted by the Inspectors in both North Essex and Uttlesford. However, this is not a free pass. The first difficulty is in coming to some view about deliverability. The North Essex Inspector said: “the Plan could not be considered to be sound if I were to find that the proposed GCs were justified having regard to their ability to provide for strategic development over many decades to come, but reached no finding on whether or not they were deliverable beyond 2033.” (Para 28) Secondly, there is a question of proportion to future need and grappling with the wider implications. In Uttlesford the scale of the GCs beyond the plan period was so great relative to an as yet unknown long term housing need, the Inspectors were concerned it would ‘crowd out’ the potential for alternative patterns of development, for example expansion in towns and villages to support their vitality and viability[12].  Thirdly, one needs to test that long term strategy. In Hart, the Inspector’s concern was the new settlement being advanced as a long-term solution, but no alternatives to that option had been considered or properly tested in preparing the plan. Who does what? The approach to delivery In North Essex, the Inspector accepted the Plan’s “delivery model blind” approach; Local Development Vehicles had been incorporated (and Urban Development Corporations considered) to step in if the private sector could not deliver. The Inspector summed up the role of the Local Plan: “The role of the Plan is to set out policies and criteria to guide the further planning of the proposed GCs, and to provide part of the framework against which planning applications to develop the GCs would be assessed. Provided that there is evidence that the GC proposals are justified and are capable of being delivered, it is not necessary for the Plan to specify that any particular delivery model must be followed.” (Para 191) However, there is a link to viability. The Inspector noted that because the viability appraisals relied upon low land values (£24-26K per acre in two cases) a contested CPO process was likely, with potential for delay, threatening plan trajectory assumptions. The Hart Inspector did not report on the means of GC implementation, but his concerns were: “there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership … The Council’s Infrastructure Delivery Plan (IDP) does not include any consideration of the proposed new settlement … and the viability assessment has not directly considered a proposed new settlement in the AoS. Again, whilst there is some information from the site promoters in relation to such matters, it is not of any great substance.” (my emphasis) This was then compounded by undisputed evidence that a large area of land through the middle of the new settlement was owned by a landowner who was not willing to sell. Fragmented land ownership is not per se a showstopper, but the Inspector did not have the evidence in front of him to explain how this was expected to be resolved. Show me the money: paying for infrastructure There is a ‘chicken and egg’ difficulty in planning infrastructure for large-scale growth (it is more difficult to get funding unless your site is allocated[13], but more difficult to get an allocation without committed funding) and there is something in the complaint that public money for infrastructure is fragmented and irregular. Judging the reasonable prospect for development based on securing future funding many spending cycles away is a challenge. But is that the only issue? The case study of North Essex is instructive. Here, five significant infrastructure components were needed, some of which had funding committed (A12, the A120-A133 link road, and first route of the rapid transit system) and others which were reliant on the viability of the GCs. Problems arose from: A concern that “it would be entirely inappropriate to find that the proposed GC is deliverable if the available infrastructure would allow only a small fraction of it to be built” meaning that it “would be very different from the GC proposal in the plan” (Para 128). This point was directed at Colchester/Braintree (2,500 homes out of 21,000) rather than West of Braintree, where the evidence suggested at least 2,000 of the 10,000 dwellings could come forward in advance of the A120. The plan’s reliance on a “step change” in integrated and sustainable transport that would only be achieved if the RTS was delivered at a higher cost than the Plan had allowed[14]. The other scheme wide infrastructure costs were considered to have insufficient levels of contingency to reflect optimism bias. When combined with other problems in the scheme viability assessments[15] it raised sufficient doubt as to the reasonable prospects of the vision being secured. In Uttlesford the Inspectors concluded a lack of evidence: “significant gaps remain in the IDP for the cost of the provision of gas, water, waste, wifi/broadband and significant amounts of the social infrastructure items .... There are also considerable variations in estimated costs for ‘big ticket’ items, including transport”. The Inspectors found that the “broad brush” approach of the viability work – absent phasing or a contingency - compounded by lack of knowledge on key infrastructure requirements - demonstrated the “very marginal viability” of the GC. It was considered that delivery on this basis “could lead to an erosion of some of the key principles of Garden Communities.” The right homes in the right places Some of the costly infrastructure challenges identified are the consequence of seeking to achieve positive sustainability solutions in response to location-specific factors, which might be resolved through alternative spatial strategies. Beyond that, it is worth noting that North Uttlesford and Easton Park GCs in Uttlesford were found by the Inspectors to be “flawed” in terms of factors such as landscape and heritage impacts. Conclusion A proper read of the Inspectors’ conclusions on these three plans is a good reminder – if one were needed - that plan-making for large-scale development is hard. Is the soundness bar set too high? These recent GC failures certainly justify asking the question. I make the following observations (all with the benefit of hindsight not available to the plan makers): None of the GCs failed for a single reason: Inspectors found multiple problems they believed were not sufficiently well understood or addressed. A fair read is that the Inspectors were not fixated on seeking spurious detail or certainty, but were concerned that the high-level delivery assumptions did not sufficiently account for optimism bias or the obvious downside risks, for example, due to absence of attempts to estimate infrastructure costs or understand possible phasing. This did raise big questions over the reasonable prospect of the GCs happening in anything like the form proposed.  The Inspectors' conclusions – when read in full – strongly suggest that had the bar been lowered to allow the GC allocations, the most likely consequence would either have been: a. The GCs would have stalled and not delivered the housing expected. For some plans (not all) this would leave gaps in the housing trajectory, sometimes quite early, opening up the plan for speculative applications or resulting in a housing shortfall; or b. Alternatively, to proceed they would have had to sacrifice some of the Garden City principles and other qualities (such as affordable housing delivery) that formed the justification for selecting them in the first place, thereby undermining public confidence in the plan; or c. The public sector would have needed to significantly increase its own investment to subsidise housing delivery than earlier indications suggested, when alternative spatial options (perhaps different GC locations) – less burdensome on the public purse – might otherwise have been selected. This leaves three thoughts on where we go from here: Those relying on GCs to deliver (particularly within the plan period) should not under-estimate the requirement to coherently demonstrate a reasonable prospect the project can be delivered with robust but proportionate evidence on delivery, infrastructure, and viability that objectively tests the upside and downside risks and addresses the consequences. They also need to engage with the spatial strategy justification (for the plan period and beyond) and ensure it is properly tested against reasonable alternatives. The 2018 NPPF change to “an appropriate strategy” should help.  Do we need more flexible plans? Perhaps too many allocate land at the margins of what is needed, with rose-tinted views on deliverability. Should they acknowledge the risks of GCs, prudently allocate them as reserve or opportunity sites – suitable for development and supported for implementation – for when infrastructure and funding allows?[16] They could be complemented with other, more certain, allocations to ensure that needs were met in the meantime. (North Essex and Hart might reasonably say this was their approach, but the Inspector did nevertheless identify wider concerns over approach and justification that he thought could not be overcome). Or they rely on the GCs but with ‘Plan B’: alternative reserve sites that can come forward quickly to fill the gap if the new settlements fail to deliver. This focus on flexibility is identified by Anna Rose in her excellent blog[17] and would reflect the requirement at NPPF para 11 a) for plans to "be sufficiently flexible to adapt to rapid change". The more existential question - should plans be more about vision and less about deliverability? - is a blog in itself, but two preliminary thoughts[18]: a. We’ve been there before and it didn’t please everyone – a 2007 study for the RTPI et al on Effective Practice in Spatial Planning found “In the past, planning has faced criticism for its preoccupation with the formulation of a plan, and with insufficient attention being paid to delivery…. One of the defining features of the approach to spatial planning is that places are not only envisioned and shaped for the future but also delivered.” [19] b. ‘Delivery-blind’ local planning (in combination with a desire to meet needs expressed quantitatively) definitely requires much more flexibility and ultimately leads us down the route advocated by the Policy Exchange[20]: the ‘rationing’ of land is replaced by simply zoning any suitable land for development and dealing with delivery outside the local plan process. Some say that might be a solution for quicker, easier statutory plan making (although I wouldn’t bet on it) but it will move the delivery challenges inherent in GCs into a separate, perhaps less transparent arena.   [1] In his Post-Hearing Letter to the North Essex Authorities on 15th May 2020, available here. Tendring/Colchester Borders Garden Community was accepted, whilst the West of Braintree GC and Colchester / Braintree Borders GC were concluded not to be deliverable over the Plan period and long term.[2] The Uttlesford Inspectors’ letter of 10th January 2020 is here.[3] The Hart Inspector’s report dated 10th February 2020 is here:[4][5] Under the transition arrangements set out in para 214 of the NPPF 2018/19[6] In the PPG at ID: 61-059-20190315 and ID: 61-060-20190315[7] This now withdrawn part of the PPG is ID: 12-018-20140306[8] The Uttlesford Inspectors observe on this point that: “The proposed stepped trajectory which arises from the strategy’s reliance on the Garden Communities, would result in a worsening affordability problem as it would delay the provision of housing to meet the identified need in the district for a number of years. This is also a significant concern.” (Para 34)[9] See Figure 5 in How Does Your Garden Grow?[10] See Paras 24-29 of the Inspectors' findings. The Council anticipated preparing a new settlement DPD in the period between Local Plan adoption and start on site in 2024, but it has already seen slippage in the progress of DPD preparation.[11] The three GCs in North Essex resulted in an ‘over-allocation’ against need of 18%; removing two of them still left the Plan with a 5% buffer, and with Section 2 plan process available to bring forward further sites if needed. In Hart, the GC was not needed at all to meet need in the plan period.[12] At Paras 30-32 of the Inspector’s letter.[13] Although in North Essex, funding was secured, in advance, for Route 1 of the rapid transit system, the A12 realignment and A120-A133 link road[14] The Inspector concluded on the RTS: a) it under-estimated likely capital costs; b) some elements were excluded from viability appraisals; c) passenger revenue depended on an “aspirational” level of capital spending (for which there was no evidence) and two of the GCs proposed in the failed Uttlesford Plan that could no longer be relied upon; and d) there was no clear evidence that subsidy assumed for early phase RTS services was sufficient.[15] The viability issues at North Essex are worthy of whole separate blog, but the Inspector identified numerous problems with the various submitted appraisals including: over-inflated cash flow due to reliance on high unjustifiably high build out rates; under-estimating the minimum land price required; dependency on sales value inflation exceeding cost inflation, inadequate testing to reflect long term uncertainties; failure to phase infrastructure towards the beginning of the programme.[16] See, for example, the approach of Plan:MK with it is allocation of 5,000 dwellings at Milton Keynes East – not relied upon to meet the Plan’s housing requirement and where its release is specifically identified as being dependent on securing funding.[17] Available here. It suggests a blueprint for plans: “The vision covers the long-term goal, whereas the policies or interventions that seek to deliver are focused, pragmatic and designed to secure quality for the local area. The plan contains a range of sites, more than are needed, thereby allowing for flexibility within a framework of acceptable alternatives. Policies focus on what a local area needs, supported by demographic and environmental data with required outcomes.”[18] A point raised in Zack Simons’ blog on North Essex and soundness[19] Available here. I played a very minor role as part of the study team.[20] Rethinking the Planning System for the 21st Century.