Planning Minister Nick Boles’s call to increase the urbanised area of England is provocative and unnecessary, and casts a shadow over at least 25% of our undisturbed countryside, say countryside campaigners CPRE.

Deputy Prime Minister Nick Clegg has called for a new generation of Garden Cities and Suburbs, but presenting them as the only choice available is not the whole story.

Rural campaigners have welcomed the long awaited publication of the Government’s Rural Statement but are disappointed by the sidelining of environmental issues.

Neil Sinden, Director of Policy and Campaigns at CPRE, says: “It is encouraging to see the Statement makes clear that all of Government and not just the ‘rural department’ have responsibility for the countryside.

“We support and welcome Ministers’ commitment to improving opportunities for walking and cycling in the countryside and to making sure there is sufficient rural affordable housing. We would really like to see more genuine action in these areas.

“However, as with much of current Government thinking, the statement is limited by its assumption that economic development is unrelated to the natural environment.

“Only by putting the environment at the centre of measures to achieve social and economic progress will the Government help to support a sustainable future for rural areas.”

Specifically, CPRE is disappointed to see the Statement does not consider how measures such as moves by the Department for Communities and Local Government to liberalise permitted development rights on agricultural buildings could irreversibly damage rural landscapes and tranquillity.

Support for local food offers a great opportunity for the sustainable development of rural economies, but disappointingly is not covered by the Statement. CPRE research into local food webs estimated that the value of local food sales from independent food outlets is £2.7bn annually. Greater support for local food also offers a wealth of other benefits including more robust local shops and locally distinctive landscapes.

Neil Sinden concluded, “Some of the recent misinformed attacks on the planning system from the Treasury and elsewhere show that the Government has some way to go in understanding that a healthy economy and environment go hand in hand.

“The new team of Ministers at the DEFRA has a great opportunity to ensure that rural growth and development enhance the very things that make our countryside so special; it’s beautiful open landscapes, tranquillity and dark skies, and its distinctive villages.”

A new briefing and map published by the Campaign to Protect Rural England (CPRE) highlights major new threats to England’s Green Belts.

The threats include proposals for over 80,000 new houses, new roads, open cast coal mines, airport expansion, golf courses and industrial parks – amounting to the development of a new town greater than the size of Slough over the next twenty years [1].

The publication of the map and briefing paper comes two years after the Government’s pledge to ‘maintain protection of the Green Belt’.

Download: The Green Belt Threats map (http://bit.ly/TS77q4 or without text: http://bit.ly/Pb8ihc) and Green Belts briefing (http://bit.ly/NErJyW) which includes detailed local case study examples.

In July 2010 Secretary of State for Communities and Local Government, Eric Pickles, announced that he would abolish regional planning, so that local people could better protect Green Belts around towns and cities across the country [2]. However, CPRE has found that, two years on, the level of threat remains. 

New national planning policies require local authorities to allocate more than five years’ worth of building land for new housing [3]. In many cases it appears that Government Planning Inspectors are putting pressure on local authorities to allow building in the Green Belt to meet this requirement. Government plans to reduce further national planning guidance could lead to Ministers no longer scrutinising major proposals for development in the Green Belt [4].

Paul Miner, Senior Planning Officer for CPRE, says: “The Green Belt is the most popular planning policy in England and the envy of the world. It helps regenerate our cities and stops them sprawling into rural areas. As a result, no one is ever too far from true, green English countryside.

“In times of economic slowdown, politicians can sometimes be tempted by the false promise of an easy construction boom. But destroying the countryside is not the path to lasting economic prosperity.  Sustainable economic improvement can only come from the sort of urban regeneration that has already done much to rejuvenate many of our largest cities.”

Building on the Green Belt is often justified by claiming that there is a shortage of other land available for development, such as previously developed ‘brownfield’ land. However, Government figures show that the amount of brownfield land becoming available for re-development is far outstripping the rate at which it is being used and there is enough available for 1.5 million new homes [5].

It is vital that the Government steps in to ensure ‘smart growth’, which focuses investment and development within existing urban areas, rather than allowing the unnecessary loss of Green Belt land [6].

Local authorities should set housing targets consistent with local need, protecting the Green Belt and regenerating brownfield land, rather than relying on unrealistically high requirements once imposed by regional plans.

Above all, Ministers should stick to their commitments to protect the Green Belt, including by actively monitoring major planning applications in the Green Belt as well as the proportion of new housing on brownfield sites.

Paul Miner concluded: “Ministers have consistently maintained that they value the Green Belt and want to see it protected. Now is the time to put these words into action.” 

CPRE is today also publishing a new campaign guide which is aimed at helping local people to protect the Green Belt. The campaign guide explains the key aspects of the new national planning policy, cuts through the jargon of local plan reviews and developer proposals, and provides key campaigning tips [7].

CPRE is encouraging people to write to Eric Pickles and ask him to stand up for the Green Belt: http://bit.ly/NDoSKY

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Green Belt facts:

• England’s Green Belts covers 1,619,835 hectares (6254 square miles), a total of 12.4 per cent of England’s total landscape.
• Green Belts include: 250,000 hectares (ha) of our finest farmland; 89,000 ha of sites of special scientific interest (SSSIs); and 220,000 ha of broadleaf / mixed woodland.
• Green Belts contain 41% of the area covered by England’s Community Forests.
• The introduction of Green Belts was the culmination of years of campaigning by CPRE following our establishment in 1926. The first Green Belt was around London and was proposed in Patrick Abercrombie’s 1944 Greater London Plan, made possible by the 1947 Town and Country Planning Act, and finalised in 1958.
• Green Belts are a planning policy designation with five primary purposes: to stop urban sprawl; prevent ‘coalescence’ (or joining together) of settlements; safeguard the countryside from encroachment; protect the setting of historic towns; and encourage urban regeneration and the reuse of brownfield land.
• Most forms of development are classed as ‘inappropriate’ in the Green Belt. Furthermore, the NPPF ‘presumption in favour of sustainable development’ does not apply in Green Belt areas.
• In England there is sufficient brownfield land available and suitable for 1,494,070 new dwellings, and much more on top of this suitable for business or industrial development. In Northern regions (the North West, Yorkshire and the Humber and the North East) there is enough brownfield land for over 444,000 new homes. Even in the South East, where housing demand is highest, land supply outpaces demand with one quarter (26 per cent) of suitable brownfield plots going unused.

Notes to Editors
[1] This survey of Green Belt threats is not intended to be comprehensive. It includes a selection of significant cases notified by CPRE branches and members. We believe Government should provide a full national analysis and act accordingly. 
[2] See Department for Communities and Local Government press release, ‘Eric Pickles puts stop to flawed Regional Strategies today’, 6 July 2010.
[3] The National Planning Policy Framework, 27 March 2012: http://bit.ly/LJdHuI
[4] See Department for Communities and Local Government press release, ‘Next steps to improve the planning system and support sustainable development’, 3 July 2012.
[5] Campaign to Protect Rural England, ‘Building in a small island: Why we still need the brownfield first approach’, November 2011
[6] Smart growth is explained at www.smartgrowthuk.org/
[7] The new briefing is available from www.cpre.org.uk/resources/housing-and-planning/planning/item/download/2176
[8] CPRE has quotes from MPs supporting the Green Belt and/or protection of the countryside, and who represent the following areas where the Green Belt is under threat (details are available from the CPRE press office): Bath, Bromsgrove, Broxtowe (Nottinghamshire), Chester, Christchurch, Dewsbury, Hexham, Kenilworth, Leeds, Mole Valley (Surrey), Newcastle upon Tyne, Reigate, St Albans, Solihull, Warwick.

Rural campaigners warn Ministers that meddling with the Green Belt would be foolish.

The Campaign to Protect Rural England (CPRE) has reacted strongly to reports [1] that senior Ministers want to weaken the planning rules governing major infrastructure projects to allow building in the Green Belt.

Shaun Spiers, Chief Executive of CPRE, says: “Reports that senior Ministers are contemplating a new Bill to sweep away planning controls are deeply worrying.

“There have been three significant reforms of the planning system since the Coalition took office, and Ministers should give them time to take effect rather than embarking on yet another upheaval.

“As for the idea that Green Belt protection needs to be weakened to boost economic growth, the Government has made clear time and again that it will protect the Green Belt, and any attempt to weaken it will go down very badly with Government MPs. In fact, there is growing evidence of harmful new development being promoted within the Green Belt. The Green Belt needs to be strengthened, not weakened.”

Shaun Spiers continued: “The country does need many, many more new homes than we are currently building, but there is no evidence that the planning system is stopping us building them. We are not building enough new homes because individuals cannot get mortgages and public investment in new housing is inadequate.

“It is the job of the planning system to stop inappropriate development. We should remember the words of the former Cabinet Secretary, Gus O’Donnell, who spoke about the need to be clear about the purpose of planning reform: ‘If it is to boost GDP, then the answer is simple: concrete over the South East. But of course that’s not what we want and that’s because you would have to be an idiot to want to maximise GDP. It’s a highly flawed measure and I am pleased that we are at last starting to think more broadly about how as a society we measure success.’”

Notes to Editors
[1] First reported in the Daily Telegraph and now in the Daily Mail

Campaign to Protect Rural England (CPRE) President Sir Andrew Motion has congratulated Danny Boyle for his tribute to the countryside, but warned that the celebrated vision of our countryside is under threat.

Following a spectacular Olympic opening ceremony on Friday night – with the epic tribute to our unique and beautiful rural landscape, former poet Laureate and new President of CPRE, Sir Andrew Motion says:

“In his spectacular tribute to all that is great about the UK, Danny Boyle chose to lead with one of the nation’s greatest assets. We are the country of Shakespeare: most people would be happy to say that is England’s greatest gift to the wide world. But in fact there’s an even greater gift – which is our landscape. The quality of our countryside is world renowned, a draw for many tourists, and the source of great inspiration for our language, literature and poetry.

“We must not take this treasure for granted. Even now many of our most cherished landscapes are under threat from damaging development. For example, Cherkley Court, part of the route for the Olympic road cycle event in London’s Green Belt, is at risk of being diminished for the sake of an exclusive hotel and golf course.

“Just as we celebrate the NHS we should value our post-war planning legislation that has done so much to protect our rural areas and regenerate our towns and cities. Our countryside is a national treasure that requires continued support and care. Because it is our greatest achievement, it is also our greatest responsibility to look after it.”

End

Onshore wind mapping shows exponential growth in wind turbine planning applications leaving local communities struggling to safeguard valued landscapes [1].

A new report by the Campaign to Protect Rural England (CPRE) highlights the dramatic proliferation of onshore wind turbines.  In many cases these are damaging valued landscapes and intruding into some of the most tranquil areas of England. CPRE is calling for a locally accountable, strategically planned approach to onshore wind development.

Download a map showing wind farm locations superimposed with CPRE’s tranquillity map of England (http://bit.ly/K4g2OA) and wind farm locations with protected landscapes (http://bit.ly/I5dajN).

Shaun Spiers, CPRE Chief Executive, says: “There is no easy way to provide the country with the energy we need.  CPRE accepts onshore wind in the right places as part of the mix required to meet the UK’s carbon reduction targets, but we are seeing more and more giant turbines sited in inappropriate locations.  Communities feel increasingly powerless in the face of speculative applications from big, well-funded developers, and this risks undermining public support for the measures needed to tackle climate change. 

“The English countryside is one of this country’s great glories.  It will always change, of course, and it is right that the countryside should play its part in supplying the renewable energy the country needs.  But we must find a way of reconciling climate change mitigation and landscape protection.  Otherwise we will sacrifice the beauty and tranquillity of much-loved landscapes for at least a generation.” 

Shaun Spiers concludes: “In spite of localist rhetoric, the industrialisation of valued countryside is happening as a result of central government policies.  The Government must take responsibility and set out far more clearly a framework for meeting the country’s energy needs while protecting our matchless countryside.”     

The CPRE report: ‘Generating light on landscape impacts: How to accommodate onshore wind while protecting the countryside’, makes a number of proposals for action.  It refers to assurances given last year by former Secretary of State for Energy and Climate Change Chris Huhne that the Government would not ‘wantonly plant windfarms across the countryside at random’ or let the ‘market loose upon the countryside’. Yet many communities are now faced with what seems like an unending stream of applications [2].

In Cornwall and Durham, at opposite ends of the country, it is widely felt that the capacity of the landscape to accommodate wind turbines without unacceptable damage has been exceeded.  Cornwall currently has 94 operational turbines over 30 metres tall with a further 18 consented and 11 in planning.  County Durham has 60 operational turbines, 27 under construction, 19 consented and six in planning [3].

In other locations the number of onshore windfarm applications currently in the planning system, if built, could mean that the landscape capacity of their area will also be exceeded. Northamptonshire, for example, currently has 13 operational turbines over 30 metres high, and an additional 46 consented and 32 in planning.  Northumberland has 29 operational turbines over 30 metres high and an additional 24 under construction, 64 consented and one in planning [4].

Research indicates that some wind energy developers enter the planning process with a dismissive mindset towards public concerns, seeking to disparage arguments against new development as baseless and emotional rather than well-reasoned and legitimate [5]. In 2008 CPRE compiled a large body of evidence about the approach by wind energy developers which undermines the integrity of the planning system [6].

The Regional Spatial Strategies, revoked through the Localism Act 2011, often used landscape character assessments to help work out what areas were suitable for renewable energy.  These helped to outline a landscape-sensitive distribution of onshore wind across a region.  Following the abolition of regional planning CPRE is calling on the Government to develop a strategic, plan-led approach which recognises the importance of landscape capacity, including the cumulative impacts of onshore wind turbines.

CPRE calls on the Government to:

• provide more clarity about the total number of onshore wind turbines it expects to see built and where these might be located;
• develop a strategic plan-led approach which recognises landscape capacity, including cumulative impacts of onshore wind turbines;
• ensure local planning authorities seek to protect landscape character through their local plans and in planning decisions;
• instruct the Planning Inspectorate to give significant weight when making decisions on development proposals to any local plans which have attempted to identify appropriate and inappropriate areas for onshore wind development; and
• provide national obligations for the onshore wind industry to take legal and financial responsibility for decommissioning onshore wind turbines and restoring the landscape once they stop working or when they reach the end of their useful life.

End

Notes to Editors
[1] CPRE, Generating light on landscape impacts: How to accommodate onshore wind while protecting the countryside, 30 April 2012  http://www.cpre.org.uk/resources/energy-and-waste/climate-change-and-energy/item/2823-generating-light-on-landscape-impacts
[2] Secretary of State for DECC, Chris Huhne’s speech to CPRE entitled ‘Beauty, Tranquillity, and Power Stations?’, 2011
[3] See 2
[4] See 2
[5] University of Manchester et al, Beyond Nimbyism project summary report, 2009. Accessed from www.sed.manchester.ac.uk/research/beyond_nimbyism/deliverables/reports_Project_summary_Final.pdf.
[6] CPRE, ‘Goodwill payments: Do they benefit communities or bring planning into disrepute?’, 2008

The Campaign to Protect Rural England (CPRE) believes Ministers have made significant progress towards meeting the concerns raised by rural campaigners about the draft planning framework published last year, making some vital improvements that should achieve better planning outcomes.

We are pleased with the direction of travel on several of our key priorities, including the recognition of the value of undesignated countryside, the definition of sustainable development and the explicit acknowledgement that use of brownfield land is a core planning objective. Ultimately, however, the proof of the new policy framework will be how it works in practice. We and our supporters up and down the countryside will work with the Government, local authorities and communities to try to secure the best results for what Planning Minister Greg Clark rightly referred to today as ‘our matchless countryside’.

Our initial statement is available here: http://bit.ly/GU1Usb .  Looking at the National Planning Policy Framework (NPPF) in more detail, CPRE has broken applied a ‘traffic light’ assessment to the key issues - Green (improved/good), Amber (unchanged/caution) and Red (poor/area for concern):

KEY ISSUES

Green: The undesignated (ordinary) countryside
The draft NPPF made no reference to the intrinsic value of the more than 55% of English countryside not in a National Park, Green Belt, Site of Special Scientific Interest or other designated site, but nonetheless of huge value to millions of people who live in, visit and enjoy it. So we are delighted that Ministers have heeded our campaigning, and included as one of the core planning principles recognition of 'the intrinsic character and beauty of the countryside' which applies whether that countryside is specifically designated or not. This will not mean no development in the countryside, but it will help ensure that building on green fields is not an option of first resort.

Amber: Brownfield
We commend the Government for acknowledging explicitly that using previously developed (brownfield) land should be a core planning objective. Making sure that land is used effectively is essential if local authorities and developers are going to deliver genuinely sustainable development.

The wording in the NPPF falls short of the existing guidance, however, in that it does not require brownfield sites to always be developed before greenfield ones. We will therefore be monitoring very closely how this policy is put into place on the ground to ensure that greenfield is not being developed when alternative brownfield options are available.

Amber: Sustainable Development
The draft NPPF made no reference to the existing (2005) UK Sustainable Development Strategy or to the five guiding principles of that document. The final version rectifies this by including a box summarising the 2005 Strategy, and is stronger on achieving the environmental and social aspects of sustainable development at the same time as economic growth. There is a continued lack of clarity, however, as to what sustainable development actually means in practice, and no suggestion that environmental limits in the UK (as opposed to the global) context should be identified or respected.

The presumption in favour of sustainable development has been helpfully qualified, however, in comparison to the draft. There is no reference to a default ‘yes’ to development and applications should only be approved where they are either clearly in line with Local Plans or are demonstrably sustainable. It is also made clear that the presumption does not override policies protecting the Green Belt or other important areas of landscape.

Red: Economic Emphasis
While much of the alarming language in the draft, such as the 'default yes' to development, has been removed, the final NPPF contains some worrying wording on economic development. Paragraph 19 refers to the need for 'significant weight' to be placed on the need to support 'economic growth' and suggests that planning is an 'impediment' to such growth.  Our research shows there is little evidence to support such a contention and that planning brings huge, long term benefits to the economy.  Local planning authorities need to be able to refuse proposals for economic development in the wrong places and to steer it to appropriate locations.

OTHER ISSUES

Green: Light pollution and tranquillity
CPRE welcomes the inclusion of policies to enable local authorities to combat light pollution, by encouraging good design, planning policies and decisions to control lighting. We hope that more local authorities will now seek to limit the impact from artificial light on local amenity, intrinsically dark landscapes and the natural environment. CPRE also welcomes the first reference in national policy to the need to identify and protect areas of tranquillity for their value for recreation. We will work to ensure effective implementation of this policy to protect and enhance areas of tranquillity for their contribution to health and quality of life.

Green: Plan-led system
We warmly welcome the NPPF’s clear reiteration of the law that decisions on development must be taken in line with locally agreed policies unless other relevant issues indicate otherwise. We are pleased that where neighbourhood plans are drawn up in line with local policies, development will have to conform to the policies in those plans.

We welcome the Government’s positive response to calls to allow local authorities time to get their local plans up to date before the presumption in favour of sustainable development kicks in. It will nonetheless be a significant challenge for many resource-strapped authorities to get their plans right within the 12 month deadline.

Red: Housing
Government has continued with its misguided approach to requiring the planning system to make available a 5 year supply of “deliverable” housing land and adding additional “buffer” requirements (5 or 20 % now judged on house building performance of planning authorities). The Government needs to recognise that planning can’t actually deliver hew housing, only make sites available.

This overall approach to land supply is not new, but the additional buffer requirement is.  It could significantly increase pressure to develop easy, lower cost, greenfield and rural housing sites instead of, or in addition to, planned developments and brownfield regeneration.


End

Notes to Editors
[1] Department of Communities and Local Government, National Planning Policy Framework, 27 March 2012 http://www.communities.gov.uk/publications/planningandbuilding/nppf

The Campaign to Protect Rural England (CPRE) has welcomed the statement to Parliament by Planning Minister Greg Clark, but will now be examining the detail prior to commenting at greater length later today.

After an initial quick reading of the final NPPF, Shaun Spiers, Chief Executive of the Campaign to Protect Rural England (CPRE), says:

“We were very reassured that Greg Clark recognised the intrinsic value of the ordinary countryside 'whether specifically designated or not' and stated that the five principles of the UK Sustainable Development Strategy are included in the document. These were critical issues for CPRE. We are pleased the Minister appears to have listened to the strong public views, which mirrored our concerns.

“We now need to carry out a thorough analysis of the final document. While recognising the scale of the housing crisis, we remain very concerned to ensure that the Planning Framework does not place undue emphasis on short-term economic growth at the expense of other important long term, public interest objectives of planning, including the protection and enhancement of the environment.

“We are also concerned about the length of the transition period, which at 12 months will pose serious challenges to many local authorities. We hope these councils will be given adequate support to get their plans in place. This will be critical if local people are to have a real voice in planning decisions.”

End

Notes to Editors
[1] Department of Communities and Local Government, National Planning Policy Framework, 27 March 2012 http://www.communities.gov.uk/publications/planningandbuilding/nppf

The key document central to the Governments planning reforms, the National Planning Policy Framework (NPPF), will be published on Tuesday 27 March. The Framework will be a major influence on decisions over new development for years to come and is likely to have a profound effect on the future of our countryside, villages, towns and cities for years to come.  The Campaign to Protect Rural England sets out some critical questions we will be looking to the Government to address:

1) Ministers have been keen to state that protection for designated landscapes, like National Park or AONBs, will remain unchanged, but how will the NPPF affect protection of the ordinary countryside that makes up over half of England’s rural landscape?

The draft NPPF omitted existing national planning policies, set out in Planning Policy Statement 4, that recognise the importance of protecting the wider countryside for its intrinsic value or ‘for its own sake’. CPRE believes strongly that such policies should be included in the final NPPF. This would be in line with the Government’s June 2011 White Paper The Natural Choice: securing the value of nature, which refers to protection of the countryside as a whole, not just the ‘valued landscape’ mentioned in the draft NPPF. English countryside outside designated areas covers over half the country, including much of our natural environment and many historic landscapes. http://bit.ly/zNfWHe.

2) Critical to the final NPPF will be the definition of sustainable development used in the controversial proposal for a ‘default yes to development’. In particular, does the definition include the principles set out in the UK Sustainable Development Strategy (2005), as recommended by two Commons Select Committees?

Ministers have relied heavily on making references to a vague notion of ‘sustainable development’ in order to convince critics that the NPPF will not weaken environmental protection. Yet the draft NPPF failed to make any reference to the five key principles of sustainable development, which are set out in the current UK Sustainable Development Strategy (2005). Rather the draft only refers to the older, more high-level Brundtland definition which does not provide an adequate basis for planning decisions.

3) Ministers claim the protection for the Green Belt would remain strong in the new NPPF but a legal opinion obtained by the CPRE suggested it could be unintentionally weakened by proposed policies in the draft NPPF. Has the Government done anything to address these concerns?

A legal opinion issued in October 2011 by John Hobson Q.C., one of the country’s leading planning lawyers, raised concerns that Green Belt policy would be undermined by the sustainable development presumption together with the expectation that applications should be approved unless there are adverse impacts to policies in the NPPF as a whole. To prevent a weakening of protection given to Green Belt land CPRE wants to see the current presumption against inappropriate development in the Green Belt stated explicitly in the NPPF. Policies on nationally protected areas such as National Parks should also be consistent with established policy. http://bit.ly/ru6yGn

4) The draft NPPF appeared to propose removing the ‘brownfield first’ policy which requires housing developers to use previously developed sites before greenfield land. Has the Government taken account of cross-sector advice and made it an explicit requirement in the final NPPF for local planning authorities to prioritise the use brownfield land first and follow the principles of ‘smart growth’?

In January the RTPI, CPRE, British Property Federation, National Trust, Planning Officers Society, Civic Voice, Construction Industry Council and the National Farmers’ Union together submitted to Ministers an agreed wording on ‘brownfield first’ policy.

The final NPPF should include specific wording requiring previously developed land to be used for development, where available and suitable, before greenfield sites. Evidence shows there is sufficient suitable brownfield land for 1.5 million new homes.  The NPPF should also promote the benefits of ‘smart growth’ to make more efficient use of land, reduce the need to travel, promote a sense of community and make local services more viable.

5) What support will the Government give local authorities to produce local plans? Have the Local Government Association and professional planning bodies signed up to transitional arrangements which allow local planning authorities adequate time to get their plans in place?

The day the NPPF is launched all local plans could effectively be out of date and that the ‘default yes’ will result in a development ‘free for all’. CPRE fears it could lead to a near doubling of the current number of planning appeals against local refusals to the 32,000 mark last seen in the 1980s. The Government needs to clarify if transitional arrangements will be set out to prevent local plans from being undermined.

6) What do Ministers think the phrase ‘acceptable returns’ for developers really means, and do they think the NPPF does enough to ensure we get more genuinely affordable housing rather than profitable ‘executive housing’ beyond the reach of most of those in housing need?

The draft NPPF stated that the cost of any requirements applied to development should ensure that ‘acceptable returns’ are still available for the land owner and developer. ‘Acceptable returns’ has not been defined and CPRE has raised concerns that it would undermine negotiations on section 106 agreements requiring the delivery of affordable housing by developers. While the final NPPF should recognise the need for development and sites to be viable, it should not promote economic considerations above all others. The NPPF should also state more clearly the need for a robust housing needs assessments to underpin all local plans.