To help explain the latest Government reforms to the English planning system, a series of new guides and events are helping lead people through the planning labyrinth.
The new series of three pocket guides make it clear how people can influence the future of the area in which they live . They detail how people can contribute to both neighbourhood and local plans, and describe how to respond to planning applications.
Complementing these guides are a series of local events being run across the country by local branches of the Campaign to Protect Rural England (CPRE) and the National Association of Local Councils (NALC). The events are taking place between now and the end of March .
Nigel Pedlingham, Project Manager at CPRE says: “The first contact many people have with the planning system is when something they don’t like is proposed on their doorstep. But we want people to understand why they should get involved in the planning system before something like this happens. In this way engaging with planning can be a positive experience.
“With our guides and events, we are trying to help people understand how best to get involved. We want people to help shape their communities proactively and be a part of deciding what changes they want to see in their area. Following the recent planning reforms, the best way to do this is by contributing to their local and neighbourhood plans.”
Justin Griggs, Head of Policy and Development at NALC, says: “Planning is an important issue for local (parish and town) councils and the communities they serve. Planning directly affects the environment in which people live and for too long they have struggled to understand how to get involved in the system in order to make a difference. The new planning reforms give people and local councils a chance to have a real influence over what happens where they live.
“These three easy-to-read guides coupled with the interactive e-learning  are simple resources to help walk people through the established and newly emerging planning system.”
How to respond to planning applications: an 8-step guide  - is a 61 page A5 booklet that gives an easy to follow, step-by-step guide to responding to a local planning application. For many this will be the first time they come into contact with the planning system. This guide aims to make the process simple, straight forward, and help any submissions to have the largest and most effective impact.
Planning Explained  - is 69 page A5 booklet that gives an introduction to the planning system and explains why it is important if you want to help decide the future of your community. The guide focuses on the role of local plans, where the big decisions on planning for the future of communities and land are made. It includes an eight step guide on how to get involved and contribute to your local plan.
How to shape where you live: a guide to neighbourhood planning  – is a 61 page A5 booklet that focuses on the role of neighbourhood plans. It explains their purpose and gives a simple eight step guide on how to start drafting an effective neighbourhood plan.
Free local planning events:
The CPRE/NALC planning events will deliver essential information about the importance of engaging with the local planning system, how to influence local plans, and how to develop neighbourhood plans. These events are being organised by branches of CPRE and county associations of local councils.
A full list of the free local planning events and training sessions is available at http://bit.ly/zr4QOT
Free E-learning program
Short courses that examine the step-by-step processes outlined in the guides using real world scenarios. The courses are free and available to everyone at www.ntselearning.co.uk
Notes to Editors
 The guides and events have been produced, by the Campaign to Protect Rural England (CPRE) in partnership with the National Association of Local Councils (NALC). The guides have been prepared with the help of Land Use Consultants. They form part of CPRE/NALC’s delivery of the Department for Communities and Local Government’s (DCLG) ‘Supporting Communities and Neighbourhoods in Planning’ project. http://bit.ly/zVM9CT
 Full listings of the ‘Planning’ events can be found at: http://bit.ly/zr4QOT
 The e-learning resources are available at www.ntselearning.co.uk
 CPRE and NALC, ‘How to respond to planning applications: an 8-step guide,’ October 2011, http://bit.ly/zLExOz
 CPRE and NALC, ‘Planning Explained,’ December 2011, http://bit.ly/zJ1gdz
 CPRE and NALC, ‘How to shape where you live: a guide to neighbourhood planning,’ January 2012, http://bit.ly/zEBGpF
For cover images of the guides, please contact the CPRE press office. See the top of the release for details.
The Campaign to Protect Rural England (CPRE) today welcomed the call by a cross-party committee of MPs for ‘significant changes’ to improve the draft National Planning Policy Framework (NPPF) . These suggested changes reflect many of CPRE’s aspirations for the final policy .
Kate Houghton, Planning Officer at the CPRE, says: ‘This report shows a strong cross-party consensus that the role of planning is to treat economic, environmental and social needs equally, not to favour short term economic growth at any cost. The Government must now make substantial changes to its proposed planning policies if we are to get the efficient, locally oriented and environmentally sensitive system we believe Ministers want.’
In the report the MPs:
- call the document ‘unbalanced’ in favour of economic growth alone and call for the removal of a proposed default ‘yes’ to all new development;
- state that the Government’s proposed ‘presumption in favour of sustainable development’ could undermine local plans;
- call for a stronger definition of sustainable development, based on the UK’s Sustainable Development Strategy; and
- highlight the ‘inevitable risk’ of more countryside being lost in the absence of a clear policy of developing brownfield (previously developed) sites before greenfield.
The draft NPPF, consulted on during the summer, sparked major interest and controversy, with over 14,000 public responses. Despite this, Ministers have said they do not propose to hold a second consultation in 2012. The MPs see a strong case, however, for a further short consultation with planning practitioners.
The MPs also criticise the ‘unhelpfully vague’ wording of the draft document. The Government claimed that condensing over 1,000 pages of current policy to just 52 would provide simplicity and clarity. The MPs instead conclude that the draft NPPF ‘does not achieve clarity by its brevity.’
Kate Houghton concluded: ‘We all want to see a return to a healthy economy. The Government will not achieve this by putting the countryside at risk of poor quality development and undermining cities by allowing greenfields to be built on before brownfield land. The Committee's conclusions are considered and well-informed and we urge the Government to respond positively. Otherwise we risk returning to the unsustainable development of a generation ago, when an area of countryside three times the size of Stevenage was built on each year.’
Notes to Editors
 For more details about the House of Commons Communities and Local Government Select Committee and its reports go to www.parliament.uk/clg.
 What CPRE wants to see from the National Planning Policy Framework, September 2011. Available from www.cpre.org.uk.
In a landmark review of Britain’s high streets and town centres, Mary Portas has questioned the impact of the Government’s controversial planning reforms on the long-term viability of town centres, saying: “I am worried that the guidance has been softened to the point where far too much out-of-town development may be possible.” 
Later in her report, Portas goes on to say: “If anything, the presumption in favour of ‘sustainable development’ may make edge-of-town and out-of-town developments more likely.”
Graeme Willis, Senior Rural Policy Campaigner at the Campaign to Protect Rural England (CPRE), says: “We welcome this report, which gives the Government a perfect opportunity to make improvements to its proposed changes to planning policy.
“Portas makes it clear that it is not good enough to take a ‘laissez-faire’ approach to planning if we want to achieve the right kind of economic growth. This approach will lead to more out of town mega stores and supermarkets that suck the life out of town centres.
“CPRE’s research, which maps local food networks, has shown these large out of town and edge of town superstores often disrupt and destroy local supply networks and economies, undermining the distinctiveness that has made many of our town centres so vibrant and diverse. 
“This report adds to the overwhelming case for a fundamental revision of the Government’s planning reforms. We urge Ministers to seize the opportunity it presents.”
Notes to Editors
 Mary Portas, ‘The Portas Review,’ 13 December 2011, page 31.
 CPRE, Mapping Local Food Webs: http://www.cpre.org.uk/what-we-do/farming-and-food/local-foods
In a move that serves once again to highlight the damaging role the Department of Business is playing in undermining environmental and countryside protections, Vince Cable’s Department has published a plan to force the Environment Agency, Natural England and English Heritage to promote ‘sustainable development’ .
The plan would place even more importance on how ‘sustainable development’ is defined in the National Planning Policy Framework . The Government has so far refused to make this explicit, leaving many concerned that this will simply mean almost any kind of development.
The three Government agencies are often active in highlighting when proposed developments would be damaging, and in exceptional cases they lodge formal objections. Unless sufficient priority is given to the role of the agencies in protecting and enhancing the environment, this move could effectively emasculate these environmental watchdogs and do untold damage to England’s countryside and heritage.
Neil Sinden, Director of Policy at the Campaign to Protect Rural England, says: “Time and again we hear that the economic departments are really calling the shots over the Government’s planning reforms . So while this latest announcement is no surprise, it should be deeply worrying for all those who care about the environment and long term economic health.
“The Government appears determined to make every organisation a tool for promoting its ill-defined notion of ‘sustainable development’. Unless there are explicit environmental safeguards, it could enable developers to ride roughshod over the countryside and the views of local people.
“By making these agencies a tool for promoting development, their critical role as champions of our landscape, wildlife and heritage is undermined. They do not exist to promote development; they are there to make sure any proposed development does not destroy our national treasures and environmental support structures.”
Notes to Editors
 Department of Business, Innovation and Skills, Implementation of the Penfold Review, 30 November 2011
 Currently under review following a public consultation.
In advance of the autumn statement to be delivered by the Chancellor George Osborne on Tuesday, Ben Stafford, Head of Campaigns at the Campaign to Protect Rural England (CPRE), says:
“As the Chancellor prepares to give his autumn statement, we hope he’s learned from his recent mistakes and does not try to make the planning system his whipping boy again . Despite his previous claims, the Government has now acknowledged that the slowdown in house building is a consequence of the economic downturn  and not a result of sensible planning rules that have been in place for more than 60 years.
“New construction might deliver a short-term boost to some businesses, but this is not the same as delivering long term prosperity. Development needs to reinforce urban regeneration and not be at the expense of the countryside. For example, a return to building new roads in the name of job creation will lead to more traffic, moving bottlenecks along rather than solving them, often at an irrevocable cost to the local environment.
“Rural areas have considerable potential to contribute to sustainable economic development but this requires careful planning. We hope the Government will recognise this potential by enabling the sensitive provision of rural affordable housing and supporting farmers in producing the food we need while also protecting and enhancing the countryside.”
Notes to Editors
 Financial Times article by George Osborn, 4 September 2011, http://www.ft.com/cms/s/0/d14169b0-d598-11e0-9133-00144feab49a.html#axzz1f14rwRfn
 Department for Communities and Local Government, New strategy to deliver homes and strengthen the economy, 21 November 2011 http://www.communities.gov.uk/news/newsroom/2033731
New research shows that many England local authorities are highly critical of the Government’s proposed planning reforms.
In an analysis of a representative sample of 27 local authority responses to the public consultation on the draft National Planning Policy Framework (NPPF), the Campaign to Protect Rural England (CPRE) has found that right across England, and regardless of political party control, local authorities are very concerned about the proposed changes to national planning policy .
Their concerns include the definition of sustainable development, the lack of emphasis on reusing brownfield land and the need for appropriate transitional arrangements to ensure a smooth shift to any new system.
Of the 27 authorities sampled:
- 26 thought the definition of ‘sustainable development’ was inadequate.
- Three quarters felt the transitional arrangements for moving from the old system to the new one were insufficient.
- Only one of the nine authorities who commented on the issue thought ‘ordinary’ (un-designated) countryside would be adequately protected from development.
- Two thirds of authorities gave either no or qualified support to the Governments proposed changes to the use of brownfield land.
Kate Houghton, Planning Officer at CPRE, says: “It’s clear that many of the experts working at the coal face of local planning share similar concerns to CPRE about the draft NPPF. Anxiety over the definition of sustainable development and transitional arrangements are especially prominent. This confirms that a lack of clarity in these areas could severely undermine the planning system.
“Our analysis demonstrates that the Government cannot afford to push through their reforms without taking account of these widely held concerns. Changes need to be made to the planning system, but if we don’t get them right we risk causing long term damage to both our urban and rural landscapes.”
The planning reforms have been billed as one of the Government’s key tools for stimulating economic growth. CPRE does not believe that the current planning system acts as a barrier to growth, and many local councils have been critical of what they themselves believe is an over emphasis of economic aims in the draft planning proposals, at the expense of social and environmental factors.
Chancellor George Osborne’s local constituency council, Cheshire East said: “It is acknowledged that economic considerations have for too long been ignored and therefore merit much greater prominence. However the current wording risks over stating the economic case to the detriment of the social and environmental considerations .”
Councils also fear ambiguities in the NPPF could lead to more legal appeals. Decentralisation Minister Greg Clark’s local council Tunbridge Wells was damning in saying: “[Sustainable development] will not provide a suitable foundation for decision-making in an adversarial planning system unless it is defined in precise terms for that specific purpose. At present, the NPPF does not do this. It uses a number of different definitions .”
Rural councils in particular questioned how well the changes will protect the ordinary, undesignated countryside that makes up over half of England’s rural landscape. Minister for Housing and Planning, Grant Shapps’ local authority Welwyn Hatfield Borough Council’s response to the draft NPPF states: “Protection of the wider countryside has been weakened as there is no longer an explicit reference to the need to protect it for its own sake .”
South Cambridgeshire District Council, is also concerned: “The framework does not address the protection of the countryside for its own sake. Landscape, its character and qualities and what it can bring to sustainable development, is not mentioned at all .”
Rural councils are not the only ones to be worried. In their response, Leeds City Council states that: “The NPPF is not fit for purpose in tackling housing challenges and opportunities in Leeds and will lead to a significant pressure upon greenfield and Green Belt land, undermining priorities to promote regeneration in inner city/brownfield locations .”
Winchester City Council commented: “The phrase ‘land with the least environmental or amenity value’, does not carry the same understanding as ‘brownfield’ and is also ambiguous in that the development industry will readily argue various sites fall into this category .”
Kate Houghton concluded: “The Government needs to consider very carefully the 14,000 responses to the consultation on the draft NPPF that they have received. If the Government is serious about localism, it must listen to and act on the very real concerns raised by local councils.
“We hope that the final framework will offer clear policies which properly integrate economic, environmental and social objectives. Only this will allow planning to fulfil its important role in facilitating genuinely sustainable development.”
Notes to Editors
 27 local planning authorities out of a total of 324 London boroughs, metropolitan boroughs, districts and unitary authorities were sampled. Local authorities at this level are responsible for most planning decisions, except ones on major infrastructure. District authorities are not responsible for planning decisions on waste and minerals development. County councils have been excluded from the sample as they are only responsible for planning decisions on waste and minerals development.
 The Campaign to Protect Rural England analysis of local planning authority responses to the Draft National Planning Policy Framework was conducted by sampling three local authorities from each English region, one rural, one urban and one rural/urban. Selection of authorities was otherwise random and political affiliation found to be representative of England local authority control nationally. The full report, including our methodology, can be downloaded here: http://bit.ly/uXJeD7
 Cheshire East Council, Response by Cheshire East Council to the consultation draft on the National Planning Policy Framework, October 2011, p 90
 Tunbridge Wells Borough Council, Response to question 1b of the consultation on the draft National Planning Policy Framework, October 2011, p 3
 Welwyn Hatfield Borough Council, Response to question 15b of the consultation on the draft National Planning Policy Framework, October 2011, p 17
 South Cambridgeshire District Council, Response to question 15b of the consultation on the draft National Planning Policy Framework, October 2011, p 29
 Leeds City Council, Response to question 10b of the consultation on the draft National Planning Policy Framework, October 2011, p 28
 Winchester City Council, Response to draft National Planning Policy Framework, October 2011, p 4
The Campaign to Protect Rural England (CPRE) fights for a better future for the English countryside. We work locally and nationally to protect, shape and enhance a beautiful, thriving countryside for everyone to value and enjoy. Our members are united in their love for England’s landscapes and rural communities, and stand up for the countryside, so it can continue to sustain, enchant and inspire future generations. Founded in 1926, President: Bill Bryson, Patron: Her Majesty The Queen. www.cpre.org.uk
In response to the Government’s new housing strategy , Neil Sinden, Director of Policy and Campaigns for the Campaign to Protect Rural England, says:
“We welcome today’s announcement, which acknowledges that it is not the planning system that has been constraining house building, but a lack of finance. Now that the Government has recognised this fact, we hope it will feed into the review of their proposed planning reforms. This should result in reforms that allow the planning system to deliver both truly sustainable new housing, and better protections for the ordinary countryside that is currently under threat.
“This strategy is the first step in rethinking our approach to housing, and in particular considering how we can get more out of the existing stock as well as increasing the supply of affordable homes. CPRE awaits with interest further detail on the Government's proposals for 'locally planned large scale development'. This idea must not be allowed to turn into another eco-towns disaster, with the environment and communities set to lose out as central Government and developers force through projects in poorly thought out locations.
“The potential of the planning system to support local communities in identifying sites for sustainable housing development must be harnessed. This means treating reuse of previously-developed land, of which there is enough to deliver 1.5m new homes, as an absolute priority. Equally crucial in delivering a planning system fit for the 21st century is ensuring that new housing development includes integration with and improvement of existing sustainable transport networks, efficient use of resources, and delivering the best quality design possible.”
Notes to Editors
 Department for Communities and Local Government, New strategy to deliver homes and strengthen the economy, 21 November 2011 http://www.communities.gov.uk/news/newsroom/2033731
In a new report, ‘Local Enterprise Partnerships – Are they serving the local community? ,’ the Campaign to Protect Rural England (CPRE) warns that LEPs are failing to engage local people or consider the environmental impact of new developments. This could mean they become the antithesis of ‘localism’.
CPRE is concerned that the new partnerships lack accountability because they are solely business-led. Their purely economic focus undermines the Government’s claims that they are seeking to promote sustainable development.
The LEPs were set up by the Government to fill the gap left by the abolition of the Regional Development Agencies (RDAs).
But in the light of their remit and the make up of their boards, many of which exclude environmental, social or community expertise, the CPRE report calls into question their ability to drive forward truly green growth or their legitimacy to undertake a strategic planning role. There is concern about whether they will properly take into account climate change, the value of landscape, biodiversity, and clean air and water, especially given the economic focus in the draft National Planning Policy Framework (NPPF) .
This is exacerbated by the patchy information available to the public about their activities. Unlike RDAs, they are not covered by the Freedom of Information Act .
The report identifies examples of good practice within LEPs but it also raises concerns about their lobbying for environmentally damaging schemes such as proposals for an Enterprise Belt which threatens the Green Belt round Birmingham.
Gerald Kells, Regional Campaigns Co-ordinator, says: “When the Government abolished regional institutions the intention was to devolve power to local people. Local Enterprise Partnerships are in danger of turning into one-sided, business lobby groups which are divorced from wider public concerns. They will only carry strong community support if the full range of local interests, including social and environmental groups, are meaningfully engaged in their decision making process.
“We urge LEP boards to take a more enlightened approach and actively seek ways to positively engage with groups who want to make sure that growth helps us to meet our social and environmental goals.”
Notes to Editors
 The Campaign to Protect Rural England, ‘Local Enterprise Partnerships – Are they serving the local community?’, November 2011
 e.g. ‘The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth.’ Draft NPPF Para 19. DCLG, July 2011
 Further information at http://www.addtofoi.co.uk/
The Localism Act could do much to put local people in control on planning - but only if their hands are not tied by the new National Planning Policy Framework (NPPF).
The Localism Bill is expected to receive Royal Assent tomorrow but countryside champions, Campaign to Protect Rural England (CPRE), are warning that the legislation may fail to deliver the power shift it promises if it is undermined by proposed changes to national planning policies.
Adam Royle, Senior Parliamentary Officer for CPRE, says: “The neighbourhood planning powers in the Localism Act promise to deliver positive outcomes for communities, by giving them a structure in which to make planning decisions for themselves. But if draft national planning policies which say there should be a default yes to development are unchanged, local communities will have their hands tied.
“This could leave developers, rather than local communities, in the driving seat. We are ready to celebrate giving local people more say on which direction to take their community, but not if all roads lead to excessive, damaging or inappropriate development.”
During the Localism Act's passage through Parliament CPRE has argued for changes in three key areas:
- Existing legislation is clear that the purpose of planning is to achieve sustainable development - but the Government should define what it really means by this. The definition of sustainable development in the draft NPPF is insufficient and fails to recognise environmental limits.
- Where large-scale developments are approved that go against a locally-agreed plan, communities should have a right to appeal that decision. Government commitments to review appeal costs and to improve pre-application consultation need to deliver real progress.
- The New Homes Bonus and other financial incentives must not allow developers to buy and sell planning permissions. A badly worded clause in the Act could send the wrong message if its practical application is not clarified by the Government through guidance.
CPRE is optimistic about elements of the Localism Act, but the challenge for Government now is to redraft its proposed national planning policies to give the new legislation the best possible chance of success.
The area of brownfield land is growing faster than it is being used. Yet Government proposals risk neglecting large areas in our towns and cities which need regeneration and place the countryside at risk.
A new report published by the Campaign to Protect Rural England (CPRE) , Building in a Small Island, challenges claims that there is a shortage of brownfield land suitable for housing development .
The findings bring into question the Government’s proposed national planning policies that would no longer require developers to use previously developed land for any new development before greenfield sites are considered.
The research commissioned by CPRE found that - far from running out - the supply of brownfield land is dynamic and increasing. For every five suitable housing plots becoming available in England between 2001 and 2009, only three homes where built . Even in the South East where housing demand is highest, land supply outpaced demand with one quarter (26 per cent) of suitable brownfield plots going unused.
Neil Sinden, Director of Policy and Campaigns for CPRE, says: “The idea that we’re running out of brownfield land is a myth. Developing new housing on appropriate brownfield land first is the most environmentally, socially and economically sustainable option. It should be a central strand of the Government’s final National Planning Policy Framework. Land is a finite resource, particularly on this small, crowded island of ours, and we should recycle it whenever possible.”
The brownfield first approach was first introduced in 1995. The CPRE study found that over 143 square miles of brownfield land have been developed for housing since 1995 - safeguarding large areas of Green Belt and other countryside across England. If this development had taken place on greenfield land, an area seven times the size of Southampton, or over 52,647 football pitches, would have been lost to new development.
Neil Sinden continued: “It can't be right to dig up fields and hedgerows for housing when we have chain link fences around derelict sites blighting large areas in our towns and cities. We stand at a critical moment in the history of England’s built environment. CPRE recognises there is a need for more housing but making it easier for developers to build on more profitable greenfield sites while suitable brownfield sites require regeneration will not lead to sustainable economic growth.”
Focusing new housing development on brownfield sites in urban areas has had critical economic and social benefits. Ministers have argued that their proposed policy would be less environmentally damaging as it would safeguard some land currently classed as ‘brownfield’ but with high value for wildlife. Wildlife groups have responded jointly with CPRE to state that the solution to this issue is a tighter definition of brownfield, not the removal of a brownfield first approach .
Neil Sinden concluded: “Our research shows that there is plenty of brownfield land available and national planning policy should promote its use as part of a sustainable approach to development. We should continue to regenerate our urban areas, particularly by encouraging the provision of much needed affordable housing.”
Quotes in Support of the brownfield first approach:
CPRE has found widespread support for the brownfield first approach including:
- John Gummer, Former Secretary of State for the Environment;
- Liz Peace, Chief Executive of the British Property Federation;
- Lord Rogers of Riverside, Rogers Stirk Harbour and Partners, Chair of the Urban Task Force;
- Tom Bloxham MBE, Group Chairman and Founder, Urban Splash;
- Chris Brown, Chief Executive - Igloo Regeneration;
- Tony Burton, Director – Civic Voice and
- Martin Crookston, Strategic Planning Consultancy
- Alastair McCapra, Chief Executive, Landscape Institute
- Adrian Wilkes, Chair, the Environmental Industries Commission
Full quotes in support can be downloaded here: http://bit.ly/sYYfwG
Key findings from the report:
- In England there is sufficient brownfield land available and suitable for residential development for 1,494,070 new dwellings. This is equivalent to around 6 years’ supply at the building rates the government claims we need and 10 year supply at 2009 building rates. (2009 figures)
- There is land available for 452,110 new dwellings in the southern regions (London, South East, and the South West).
- The proposed changes to national planning policy could lead, under scenarios projected by the Government, to the amount of greenfield land being used for housing more than doubling (a 158 per cent increase).
- The highest levels of brownfield re-use for new housing in recent years was in 2007, when overall housing output was also at its highest.
- More previously developed land was available and suitable for housing in 2009 than in 2001.
- In England three homes were built for every five suitable plots available. (62 per cent or 942,410 new homes)
- In the South West almost all suitable plots that became available for housing were used. (98 per cent or 91,820 new homes)
- In the South East three homes were built for every four suitable plots available. (74 per cent or 169,109 new homes)
- In London only one in three plots suitable for housing were re-developed. (35 per cent or 166,178 new homes)
- In the East of England, nine homes were built for every 10 suitable plots. (87 per cent or 109,264 new homes)
- In the West Midlands, nine homes were built for every 10 suitable plots. (87 per cent or 90,169 new homes)
- In the East Midlands, four out of five suitable housing plots were re-developed. (80 per cent or 77,207 new homes)
- In Yorkshire and the Humber, well over four in five suitable housing plots were re-developed. (83 per cent or 85,896 new homes)
- In the North West, just under half of suitable housing plots were re-developed. (48 per cent or 119,074 new homes)
- In the North East, two out of three suitable housing plots were re-developed. (68 per cent or 36,120 new homes)
Notes to Editors
 Campaign to Protect Rural England, ‘Building in a small island: Why we still need Brownfields First’, November 2011
 Department of Communities and Local Government, NPPF Impact assessment, July 2011, page 49, paragraph 2
 See 1, page 25 Table 7
 For full details see Wildlife & Countryside Link’s response to the draft NPPF, available from www.wcl.org.uk/docs/Link_response_to_NPPF_consultation_171011.pdf