Do planning policy documents contain more words than the complete works of Shakespeare?

“National planning policy and central government guidance has become so bloated that it now contains more words than the complete works of Shakespeare, making it impenetrable to ordinary people”
Greg Clark, Planning Minister, Department for Communities and Local Government press release, 25 July, 2011
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The Government this week announced its intention to dramatically simplify the volume of planning policy and guidance to make it more accessible to ordinary people and to encourage sustainable growth.
The Department for Communities and Local Government (DCLG) released a press notice stating that national planning policy would be reduced from over 1,000 pages to 52, and that a consultation on simplifying guidance would follow.
Putting the length of current guidelines in perspective, Planning Minister Greg Clark claimed that the current volume of documents contained more words than in the complete works of Shakespeare. Was he right?
Analysis
The claim dates back to a speech given by Mr Clark to the Localis group on 18 November last year. In it he claimed that there were more than 150 circulars, good practice guides and policy statements – containing more words than either the Bible or Shakespeare's complete works.
Full Fact's own research found that the complete works of Shakespeare, including his Sonnets and poems, contained approximately 928,913 words, although this included titles, acknowledgements and stage directions.
One estimate, made by Marvin Spevack in his 'Harvard Concordance to Shakespeare', is purported to put the figure at around 884,647.
However, after contacting the DCLG regarding the claim, Full Fact learned that the department had no estimate of the word count in its own documents.
The DCLG were able to comment that there were currently 1,439 pages of statutory planning policy, along with around 5,761 pages of guidance regarding the policy. This, they said, was far more than the '900 pages' in the complete works of Shakespeare.
Further research suggests however that using pages rather than words is a very inaccurate measure of document length. The Oxford edition of the complete works contains 1,232 pages while the Royal Shakespeare Company's edition has around 2,552.
Moreover, page numbers were not the measurement used by Greg Clark in his repeated statements, nor in quotations of him used by BBC News, the Guardian and the Telegraph yesterday.
Full Fact did however look through the DCLG website and found around 144 different planning, circular and guidance documents, excluding archived content, but still no indication of total word count.
When asked to explain the difference between Mr. Clark's claims and the actual department statistics, the DCLG explained that the Minister had been using a 'simile' and was, in essence, highlighting the vastness of National Planning policy and hence the reasons for the planned streamlining.
Conclusion
The lack of evidence regarding Mr Clark's claims is problematic, and although the DCLG do provide page rather than word counts, these are subject to considerably more variation and should thus be treated with more caution. More pages do not necessarily mean more words.
Though this is a time-consuming claim to properly check, questions have to be asked as to why several publications repeated Mr. Clark's comments without looking into them. A straightforward call to the Department would have revealed that even they didn't have any figures to demonstrate the point.
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