Build, build, build?

In making an appeal against the refusal of planning permission for a new house outside the development boundary of a settlement in Hampshire (DCS Number 400-032-987) the appellants claimed support from a speech made last year by the prime minister. 

“My attention is drawn”, the inspector reported “to a speech made by the Prime Minister on 30 June 2020 described as the “Build Build Build” speech which the appellants contend should outweigh the local policy.” She considered, however, that the speech was strategic in nature, setting out the general direction of government policy across a broad spectrum of subjects. Amongst other things, she noted, it set out how it is intended that the country will recover economically from the consequences of the Covid 19 pandemic. She reasoned that its generic nature would therefore not lend itself to being directly applicable to individual development proposals. Moreover, she noted, since the speech was made the government has issued the revised Framework, and Paragraph 1 confirms that it is this document that sets out the government’s planning policies for England and how they should be applied. Paragraph 2 reiterates the statutory requirement that planning applications should be determined in accordance with the development plan unless material considerations indicate otherwise. 

The inspector acknowledged that other statements of government policy may be material but, given that the Framework is more recent and specific than the speech referred to, she determined that it carried greater weight in her determination. On this basis she found that the general direction outlined by the prime minister carried little weight and would not outweigh development plan policies, nor national policy in the Framework.

The inspector concluded that the proposal would conflict with the spatial strategy for the district and no compelling reasons had been shown to justify determining the appeal other than in accordance with the adopted development plan.

There is information concerning the status of the NPPF at section 4.0121 of DCP Online.