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Simon Ricketts

Sep 26, 2026

3:42
I will be back at the end for a little bit more waffle, but first, and after this jingle, we started with the MPPF, and Simon introducing us to the issues around evidenced unmet need.
4:15
quite a lot already happening in relation to emerging uncertainties in terms of the NPPF.
4:23
I think we all recognise it's such a clearer framework for us all to operate under, but inevitably everyone is now, as they're applying it to their existing projects, seeing where the uncertainties are.
4:41
I don't know whether we want to dive into one, which is that whole question of what evidenced unmet need means, which is critical to whether the massively pro-development presumption in policy S5 in relation to development out of settlements applies in relation to residential development because I think everyone agrees the wording of category J in relation to development where you can show an evidence unmet need is not particularly clear as to whether in relation to housing development you can only show evidenced unmet need by showing you haven't got a five-year housing land supply or you're less than 75 percent of the housing delivery test and it's been brought into sharp focus by a decision letter in relation to a scheme by nicholas king homes where The inspector accepted what the appellant was saying, which was evidence unmet need can be shown in other ways.
5:59
For example, if there's an unmet need for affordable housing in the area, it's a big point.
6:07
the inspector probably is right but i do think there's room for argument and to have a wider interpretation of evidence done met need is number one inconsistent with when you look at the criteria for grey belt it is specific to um the traditional understanding of unmet need And it gives a lot of wriggle room because where in the country is there not an unmet need for affordable housing? I'll stop
10:04
and it has been all the way through talking about the green belt you know actually the the golden rules are pushing the affordable housing side to give you more more points on your scale or whatever isn't it to tip that balance even further and and we've seen that over before the mppf was coming out as well people were doing that in terms of putting more affordable housing in uh yeah i don't know whether it was necessarily a mistake certainly different and it's not necessarily uh helpful to have two different definitions but it does make it a much more pro-development stance so even if it wasn't intentional it certainly actually had a or potentially having a significant impact but the clarity especially when you look at the appeal decision and you look at recent questions written answers sorry that have been given to um questions that have been tabled in in the house again there's a bit of ambiguity there and certainly not the broader system that you mentioned like in terms of that clarity coming through and
10:57
the other thing is i think we're not in a plan-led system at the moment given the the way in which you should give very limited weight to materially inconsistent policies in an existing plan or plan that hasn't been examined against a new MPPF.
11:27
It's a policy, yeah.
11:28
And the irrationality of the alleged irrationality of supporting, you know, promoting a policy which is directly contrary to, you know, the adopted policies in the adopted development plan without, you know, choosing to review the development plan.
11:44
It's not to say I...
11:46
You know, I don't...
11:48
I don't agree with that grander challenge, but I'd need to look just to make sure that the GLA have, you know, have expressed it that, yeah, we recognise, of course, the adopted development plan has the 35% threshold, but we are in sort of emergency times at the moment and so we are going to place great weight on a material consideration which is in this time of housing emergency.
12:15
It may be more practical to set the threshold at 20%.
12:19
As long as there's that theme to the guidance then I think a challenge is pretty difficult.

33 MINS LATER

45:03
they just

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