This report responds to one of the potentially most far reaching changes proposed in the Government’s consultation draft National Planning Policy Framework. It examines the proposals to cease giving clear priority nationally to development on brownfield sites (formally called ‘previously developed land’) before greenfield. It also considers the implications of the related recent policy changes made by the Government to drop the minimum housing density range which has until recently been recommended as national policy.
Following the close of the public consultation on the Government’s draft National Planning Policy Framework (NPPF) and an important Parliamentary debate on the Localism Bill, the Campaign to Protect Rural England (CPRE) today (Wednesday) warns that the fight to protect the ordinary countryside and the Green Belt, and to secure much needed urban regeneration, is far from over.
Neil Sinden, CPRE’s Director of Policy and Campaigns said: “Ministers set themselves a challenging task in reforming the planning system and they have our full support in their ambition to simplify the process and increase public engagement. It is perhaps inevitable that this was going to take time and that it was unlikely to be perfect on the first attempt.
“We’ve come a long way since the early days of summer when Ministers where accusing any critics of their planning reforms of being left wing, self-interested scaremongers. They have moved from dismissing legitimate public concerns to a position where it appears they are prepared to listen. We are pleased that concerns about the operation of the New Homes Bonus  and the unbalanced process of planning appeals  are beginning to be addressed. But we need substantial progress on these and other concerns, not just warm words.
“Now the public consultation on the NPPF is finished the real work begins. The Government must look at the huge amount of evidence submitted and re-draft its plans accordingly. CPRE is pressing for further consultation on a revised draft so that the final Framework delivers the planning system the nation needs.”
CPRE will continue to campaign for an improved planning system over the next weeks and months. Coming highlights include new research into the use of brownfield land, research into the economic impact of the planning system, and local public meetings.
CPRE’s formal and detailed response to the public consultation on the NPPF can be downloaded here: http://bit.ly/ogsd8B
Notes to Editors
 House of Lords debate, 17 Oct 2011, Localism Bill, Amendment 223CA (Clause 130), columns 122 – 132: http://www.publications.parliament.uk/pa/ld201011/ldhansrd/text/111017-0003.htm#1110188000252
 House of Lords debate, 17 Oct 2011, Localism Bill, Amendments 232ZA and 232ZB (Applicants Right of Appeal and Limited 3rd Party Right of Appeal), columns 139-140
In a succinct yet powerful Legal Opinion the Campaign to Protect Rural England’s Honorary Standing Counsel, John Hobson QC, has criticised the Government’s draft National Planning Policy Framework (NPPF) for weakening protection of the Green Belt and wider countryside .
Despite consistent reassurances from senior Government Ministers that protection for the Green Belt will remain unchanged, John Hobson states that in his professional legal opinion “this is a significant change which may weaken the protection that applies to Green Belts .” He continues: “if the government do indeed wish to carry forward the protection of the Green Belt to the same degree as at present, the express presumption against inappropriate development in the Green Belt should be reinstated .”
Neil Sinden, Director of Policy and Campaigns for CPRE, said: “Ministers seem genuinely committed to protecting the Green Belt but its becoming clear the NPPF is not up to the job. We hope that they will take note of this legal advice and make clear that there continues to be a presumption against inappropriate development in the Green Belt.”
The Legal Opinion also challenges Government claims that their proposed changes would lead to a cheaper, faster planning system. By failing to adequately define what is meant by ‘sustainable development,’ Ministers risk a system of planning by appeals. John Hobson states: “The NPPF does not provide a clear definition of what it means by sustainable development or indeed any clear statement of what are the sustainable development principles to which it refers… Consequently there is an ambiguity which permeates the NPPF, and which is likely to lead to uncertainty in its application, with a consequent increase in the number of appeals .”
He concludes: “I consider that although the NPPF is intended to provide a framework for the delivery of sustainable development, it does not set out with any clarity what are the ‘key sustainable development principles’ which are intended to govern planning decision-making. Moreover, the operation of this presumption is likely to weaken the plan-led approach to deciding whether or not to approve development. In certain respects, notably in relation to Green Belts and the wider countryside, the level of protection presently accorded to such areas may well be significantly weakened .”
Neil Sinden concluded: “It is startling how big the gap is between the interpretation of John Hobson – a widely respected and hugely experienced planning lawyer - and what the Government is expecting from its reforms. It is now abundantly clear that the current draft of the framework is flawed in many critical respects. It is encouraging that some developers also recognise that significant changes are required. We urge the Government to go back to the drawing board and issue a revised draft for further public consultation.
“CPRE recognises the need for more housing, and for a simplified and speedier planning system with more local involvement. But the proposed reforms as currently drafted will not achieve those aims, nor will they protect our cherished countryside. We need more than a clarification of language on a few points of detail. What we now need is a complete redraft.”
Notes to Editors
 John Hobson QC, legal opinion prepared for CPRE, 11 October 2011: http://bit.ly/pvVfCs
 see  Paragraph 8
 see  paragraph 10
 see  paragraph 6
 see  paragraph 13
Here in England, 81 per cent of us are urban citizens. By 2030, that figure will have risen to 92 per cent. In five centuries, we have switched from being an almost completely rural people to almost completely urban. The effect of urbanisation on the landscape has been transformative. In the long, post-glacial history of landscape evolution, the appearance of towns and cities has been very sudden, very recent. The history of green-field development in the UK is less a tale of gradual evolution, than of urban shock and awe.
In the hundred years between 1500 and 1600, the population of England doubled from 2 million to 4.1 million. And then the population doubled again. By 1800, the UK population had soared to 11 million, which is where the graph really takes off and becomes a hockey-stick curve. The census of 1911 recorded 42 million and we’re now at 62.3 million. A few years ago, England became the most densely populated major nation in Europe. In the world rankings of major countries by population density, England comes in at number three, after Bangladesh and South Korea.
The extra 60 million or so that have populated these lands since 1500 have made their presence most apparent in urban areas. The old notion of a ‘town’ has been swamped. New urban labels have had to be invented. We have travelled from market town to ‘megalopolis’ in a blink of history. The UK has been continually-inhabited for the last 12,000 years or so, but really breakneck urbanisation has been concentrated into the last 200 years. In the last century alone, the housing stock of Great Britain increased three-fold, from about 7 million to 22 million permanent dwellings.
Projections suggest that the population will continue to increase and peak at around 65 million in 2050, about 2.7 million above today’s total, before beginning a gradual decline. So we have to house a further 2.7 million people. To put it in its urban context, that is nearly three cities the size of Birmingham (992,000). In the next forty years.
Planning for the future
2050 is a truly historic turning point. The urban population of these islands has been growing for thousands of years. Forty years from now, or thereabouts, it will stop. We have to be very careful indeed what we do now; how we plan for these final forty years of rapid growth. In terms of population expansion and urban growth we’re not in the final straight; we’re in the final few strides. We have to provide for 2.7 million people; the addition of just over 4 per cent to our existing population. This is not a moment to make rushed - or rash - decisions, because what we plan now; what we build now, is going to end up being part of the final fabric of these islands.
How we provide homes, food, water, and transport and so on for three more Birminghams is of pressing importance. Fortunately, we’re not having to make a standing start. Planning permission already exists for 280,000 houses whose foundations have yet to be laid; there are around 750,000 ‘long-term empty’ houses, and it’s been estimated that brown-field sites have the capacity to absorb as many as 3 million houses.
Building on green field sites in the countryside - remote from jobs, services and public transport hubs - is no solution. It’s not a sustainable, or a resilient, option.
Our countryside is too precious to lose
The UK is currently 72 per cent self sufficient in staple foods like meat and fresh vegetables - down from 95 per cent in 1984. Fields, woodland, uncultivated land, the coastal strip - our countryside - are essential for crops, grazing, biodiversity, fresh water. And recreation. If you live in one of the most densely populated lands in the world, open space, green space, is inestimably valuable.
It’s not as if three Birminghams plonked in the UK countryside would destroy it all, but you only have to look at Ireland, or Spain, or Greece, to see what happens when planning restrictions are relaxed. It’s not that the place we call countryside completely disappears, but more that the sense of rurality - that combination of tranquillity, nature and built forms that have been introduced by humans working the land - becomes disfigured; degraded.
In England, 65 per cent of land lies outside cities, towns, green belts and protected parks. It’s this 65 per cent that developers have their eyes on. One of the reasons that the rural English landscape is still such a beautiful place is that it’s been protected by a fundamental planning principle, that long-term use of the land should take precedence over an owner’s right to profit. That is why - as Simon Jenkins put it in the Guardian recently, ‘there are no bungalows on the white cliffs of Dover and no wind farms on the Chilterns. It is why, when you look out over the Severn Valley, you do not see Bristol merged with Gloucester.’
Making the most of towns and cities
It’s time we revalued urban living as one of our most environmentally-friendly habits. Urbanisation is a positive trend; it minimises our impact on the planet. ‘Density,’ as the UN Population Fund put it recently, ‘is potentially useful.’ Public transport, shared housing, jobs and so on are more available in towns and cities than they are in villages. Urbanisation concentrates human impacts into confined areas, with lower per capita carbon footprints.
The three Birminghams have to be plugged into existing infrastructures wherever possible. That means increasing population densities in our existing cities and towns; it means making full use of brownfield sites. To give a rough idea of the scale of the challenge; housing 2.7 million people in new homes is equivalent to each of the UK’s 66 towns and cities with populations above 100,000 absorbing a further 10,000 people each, and each of the UK’s remaining 1,400 towns absorbing a further 1,500 each.
Many of you will belong to a generation that is going to witness the end of rapid urban growth. As the demographic brakes are applied, the form of our cities and towns will become less fluid, more crystalised. Urban footprints will stabilise, and we’ll enter a new era of long-term planning where the focus will be on function rather than expansion. An era of intelligent buildings, intelligent transportation; sustainability. An age where form and process matters more than growth. At its most simplistic, it’s a switch from planning for quantity, to planning for quality. And that is immensely exciting.
Fellow, Royal Geographical Society
Vice President, Campaign to Protect Rural England
Excerpts from a lecture to the Royal Geographical Society, 10 October 2011
Take action Ask your MP to press for the planning system to protect the countryside
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The Government is failing to deliver on its wildlife and landscape promises, according to a report compiled by 29 of the UK’s leading environmental groups.
The study highlights some of the most controversial environmental issues of the year – including the proposed reform of the planning system, a planned cull of badgers and the public debate on the future of UK forestry.
The Nature Check report, published by the umbrella body Wildlife and Countryside Link, assesses the Government’s progress on the 16 commitments it has made to the natural environment using a traffic light rating system.
Just two of the promises have been fully met, and have been given a green seal of approval. Seven have received an amber rating, meaning not enough progress has been made, and a further seven have been given the red card by environmental experts.
The report shows the Government’s commitments to wildlife overseas are being met – with green lights given for new legislation opposing ivory sales and commercial whaling. However with a new proposed planning system placing economic needs above environmental ones, confusion over the future of nationally owned forests, and a badly thought through plan for tackling bovine TB – it is the domestic issues that ministers are falling down on most.
Other failing policy areas include lack of controls to prevent inappropriate development in areas of flood risk and a failure to consider seabirds and other mobile species when creating the new network of Marine Conservation Zones around our coasts.
Neil Sinden, Policy and Campaigns Director for the Campaign to Protect Rural England, said: “The Government's aspires to be the greenest government ever, but it will not achieve this admirable ambition with a 'business as usual' approach to economic growth.
“The state of the economy is, of course, a major preoccupation for everyone, but there need be no conflict between growth and greenery. As the National Ecosystem Assessment demonstrated, a healthy natural environment is not only valuable for its own sake, it has great economic value. Strong environmental policies can underpin strong economic performance.
"At present the Government is falling well short of its aspirations. Planning reform gives it an early opportunity for improvement. It should introduce a radically revised National Planning Policy Framework with strong safeguards for nature and the landscape."
Martin Harper, RSPB Conservation Director, said: “With a combined membership of over 8 million concerned nature lovers, conservation groups have an obligation to speak out on behalf of our countryside and our wildlife. When the Government fails in its commitments to protect nature, we are here to make a noise about it.
“These are 16 policy areas where the Government has promised tough action, but that is not what we are seeing. In these financially straightened times politicians may be tempted to ignore the natural environment in favour of economic growth – but this kind of short-termist attitude won’t wash with a British public which expects the Government to protect the countryside and wildlife we all hold dear.
“This report should be a wake-up call to David Cameron and the Coalition Government. A healthy natural environment is not an aspirational luxury for times of plenty – it is vital for the future well being of our economy and our society.”
Paul Wilkinson, Head of Living Landscape for The Wildlife Trusts, said: “Government performance on the natural environment is a very mixed bag. We see leadership when it comes to economic recovery, but what about nature's recovery?
“The Wildlife Trusts were encouraged by the hugely ambitious vision in the Natural Environment White Paper but see no evidence that this is being driven forward across Government. We need strong leadership now, more than ever.
“There is a powerful evidence base which shows investing in nature is good for people, and the economy. We need Government to 'get it' and urgently. It must take decisive action to support nature's recovery.”
The 16 Government commitments rated by progress
- Green - We will oppose the resumption of commercial whaling
- Green - We will press for a ban on ivory sales
- Amber - We will introduce measures to protect wildlife and promote green spaces and wildlife corridors in order to halt the loss of habitats and restore biodiversity
- Amber - Make the case for significant reform of the CAP as part of the EU's negotiations for the period beyond 2013
- Amber - Publish a White Paper and legislate for reform of the water industry to ensure more efficient use of water, protect poorer households, enhance competition and improve conservation
- Amber - We will maintain the Green Belt, Sites of Special Scientific Interest (SSSIs) and other environmental protections, and create a new designation – similar to SSSIs – to protect green areas of particular importance to local communities
- Amber - Work to secure changes to the Common Fisheries Policy
- Amber - We will tackle the smuggling and illegal trade on wildlife through our new Border Police Force
- Amber - We will introduce measures to make the import or possession of illegal timber a criminal offence
- Red - We will radically reform the planning system to give neighbourhoods far more ability to determine the shape of the places in which their inhabitants live
- Red - We will take forward the findings of the Pitt Review to improve our flood defences, and prevent unnecessary building in areas of high flood risk
- Red - Consult on a new strategic approach to forestry in England
- Red - As part of a package of measures, we will introduce a carefully managed and science-led policy of badger control in areas with high and persistent levels of bovine tuberculosis
- Red - We will publish and present to Parliament a simple and consolidated national planning framework covering all forms of development and setting out national economic, environmental and social priorities
- Red - We will create a presumption in favour of sustainable development in the planning system
- Red - We will take forward the Marine and Coastal Access Act and ensure that its conservation measures are implemented effectively
Notes to editors
- Visit www.naturecheck.org.uk to read the full Nature Check report.
- Wildlife and Countryside Link is an umbrella body, whose purpose is to bring together voluntary organisations in the UK to protect and enhance wildlife, landscape and the marine environment, and to further the quiet enjoyment and appreciation of the countryside. We have 35 members who collectively employ over 10,000 full-time staff, have the help of 170,000 volunteers and the support of over 8 million people in the UK. Our members are united by their common interest in the conservation and enjoyment of the natural and historic environment.
- Nature Check is supported by the following 29 Link members:
- Amphibian and Reptile Conservation
- Badger Trust
- Bat Conservation Trust
- Butterfly Conservation
- British Mountaineering Council
- Buglife – The Invertebrate Conservation Trust
- Campaign for National Parks
- Campaign to Protect Rural England
- Council for British Archaeology
- Friends of the Earth England
- The Grasslands Trust
- Hawk and Owl Trust
- International Fund for Animal Welfare
- The Mammal Society
- Marine Conservation Society
- Open Spaces Society
- People’s Trust for Endangered Species
- Pond Conservation
- The Rivers Trust
- Royal Society for the Protection of Birds
- Salmon & Trout Association
- Shark Trust
- The Wildlife Trusts
- Whale and Dolphin Conservation Society
- Wildfowl & Wetlands Trust
- Woodland Trust
- WWF – UK
The document outlines legal advice given to CPRE on the Government's draft National Planning Policy Framework.
In the midst of a controversial national debate over the Government’s proposed changes to the planning system, Shaun Spiers, Chief Executive of the Campaign to Protect Rural England (CPRE), will today (Wednesday) address a conference of house builders .
He will acknowledge the scale of the country’s housing crisis: England needs many more new homes, particularly affordable homes. But he will also challenge the house building industry to commit to five principles that will help minimise local opposition to new housing.
The five principles are:
- A brownfield-first approach to identifying sites
- High design and building standards
- New homes with decent space standards
- Master planning for better places, not just planning for houses
- Industry support for a democratic planning system
Shaun Spiers, Chief Executive of CPRE says: “The Government’s proposals to weaken the planning system have understandably provoked a backlash from countryside campaigners like CPRE. But it should be possible to develop a system that allows for necessary development without unnecessarily damaging the countryside or the character of our towns and villages.
“I hope that we can move beyond the current state of barely suppressed hostility between developers and conservationists. For that to happen, organisations like CPRE will have to be demonstrate that we really are able to support housing developments, as well as oppose them. I recognise that it is not enough to support the idea of new housing in the abstract: we must demonstrate that we can support specific housing schemes.
“But house builders also need to raise their game. Following the five principles CPRE is proposing will go a long way to building trust with those who might otherwise oppose new developments.
“Ministers may think that they will achieve a boost to house building by weakening the planning system, but their proposals are more likely to result in costly and divisive planning battles across the country. If the country is to get the homes it needs, we need an emphasis on quality and on good planning – more planning, not less.”
CPRE’s five principles in full:
- A brownfield-first approach to identifying sites - All new projects should seek to use previously developed, or brownfield sites where they are available and sustainable. If greenfield sites are to be used, developers should demonstrate that a suitable equivalent brownfield site was not available.
- High design and building standards – Improving energy efficiency, accessibility and aesthetics should not be viewed as ‘gold-plating’ which undermines profitability. The industry should commit to quality as well as quantity.
- Space standards: size matters – Housing needs to use land efficiently but it also needs to be big enough to live in comfortably. The industry should engage constructively with the Royal Institute of British Architects’ (RIBA) HomeWise campaign and voluntarily publish the size of all new homes completed.
- Master planning for better places, not just houses – An emphasis should be placed on master planning, where local communities are engaged in shaping proposed developments and ensuring good quality local services and transport links.
- Stop knocking the planning system – The planning system is our best and only way to ensure development delivers what we want where we need it. House builders have admitted that it is financial circumstances and not the planning system that is currently slowing rates of new building. Rather then knocking planning, they should champion it.
Supporting housing facts:
- Enough previously-developed land exists to accommodate approximately 1.5m homes – much of this in the SE. 
- CABE’s housing audit, carried out between 2005 and 2007 rated 29% of new housing as ‘poor’, a further 53% was just ‘average’. 
- The average new build home is only 92 per cent of the recommended minimum floorspace. 
- New homes in the UK are the smallest in Western Europe 
- The average home in the UK is 85m2. The average new home in the UK is 76m2 
Notes to Editors
 Shaun Spiers will be speaking at the Housing Market Intelligence Conference: http://bit.ly/r5BPOj
Other speakers include: Imtiaz Farookhi, Chief Executive, NHBC; Jake Berry MP; Stewart Baseley, Executive Chairman, HBF; Steve Morgan Chairman, Redrow Homes; David Smith, Economics Editor, Sunday Times; John Stewart, Director of Economics, HBF; Caroline Flint MP, Shadow Secretary of State for Communities and Local Government; Professor Michael Ball, Professor of Urban and Property Economics Henley - University of Reading; Richard Donnell, Director of Research, Hometrack; David Cowans, Chief Executive, Places for People; Andrew Whitaker, Director of Planning, HBF
 HCA’s National Land Use Database survey for 2009
 CABE Housing Audit, 2005 – 2007
 RIBA – Case for space (2011)
The Government is being given the chance to “walk the walk” on planning reforms today in the Lords, charity campaigners have said.
Following a very public commitment to ensure that the new planning system will safeguard all that is best about the UK’s landscape, campaigners, including the National Trust, the Campaign to Protect Rural England (CPRE) and Friends of the Earth, are inviting the Government to accept an amendment to the Localism Bill that will define in law precisely what that protection will mean.
The Prime Minister, in a recent letter to green groups, said that he shared their belief in protecting “our beautiful countryside” but that he wanted local groups “to decide locally how sustainable development will be delivered” The proposed amendment would define what is meant by sustainable development to ensure that this is always clear.
The charities argue that without a more precise definition, vital protections for countryside and the natural environment could be lost.
The House of Commons Environmental Audit Select Committee will also be holding an oral evidence session today as part of an inquiry into the National Planning Policy Framework (NPPF), during with they will hear evidence from all areas of the debate, including the Home Builders Federation and British Property Federation. Members of the Greenest Planning Ever Coalition will also be giving evidence: CPRE, the National Trust, Friends of the Earth, and the Town and Country Planning Association (TCPA).
Commenting, Margaret Ounsley, head of public affairs at WWF-UK, said: “This is crunch time for the Government. The Prime Minister has expressed his wish to protect the countryside, and we believe that we will be giving him the tools to do so. If the Government resist this measure, one would have to wonder why.”
Neil Sinden, Policy and Campaigns Director for the Campaign to Protect Rural England, said: "After a summer of rural discontent over the proposed planning reforms, we are pleased to have had reassurances from a number of Ministers who have been saying how important the countryside is to them. These are welcome words that now need to be turned into firm legislation and policy. Amendments protecting the wider countryside ‘for its own sake’, rebalancing the appeals process, and calls for a clear definition of sustainable development, are all on the table. The time has come for Ministers to prove they are truly committed to protecting the countryside.”
Peter Nixon, Director of Conservation for the National Trust said: “It’s difficult to think of an area of government policy which is more important for leading us into a new, green economy than the planning system. To achieve the Government’s aspirations, it is vital that the definition of sustainable development is rewritten and can be effectively applied by decision makers, whether they are communities, developers, local authorities or the planning inspectorate.”
Friends of the Earth’s Executive Director Andy Atkins said: “The Lords must amend the Government’s planning proposals to ensure a legal definition of sustainable development – without it councils will struggle to prevent damaging building projects going ahead. We need a planning system that champions new green jobs and industries, delivers a low-carbon economy and safeguards our precious environment for the future.”
Hilary Allison, policy directory at the Woodland Trust said: "The Prime Minister must now follow through on his recent assurances to protect the countryside by ensuring the wording around the protection of irreplaceable habitats within this development-focused document is clarified, and the loophole threatening ancient woodland is closed."
Notes to editors
 The National Planning Policy Framework (NPPF) was published for consultation in July; the consultation closes on 17 October 2011: http://www.communities.gov.uk/planningandbuilding/planningsystem/planningpolicy/planningpolicyframework/
 Greenest Planning Ever Coalition members: Town and Country Planning Association (TCPA), the National Trust, the Council for the Protection of Rural England (CPRE), Friends of the Earth, RSPB, WWF-UK, Wildlife and Countryside Link, and the Woodland Trust.
New research published today (Saturday) by the Campaign to Protect Rural England (CPRE) shows that almost half of England’s local authorities (48 per cent) will be without a planning Core Strategy on 1 April 2012 when changes to the planning system are expected to take effect . This means that when the presumption in favour of sustainable development is rolled out, nearly half the country will be very vulnerable to unplanned, poor quality development.
The problem is further compounded by the fact that two out of three local authorities are facing cuts to their planning budgets, leaving many councils struggling to get plans in place in sufficient time to protect their local green spaces .
Shaun Spiers, Chief Executive for CPRE, says: “This silence of the plans risks a real horror story for England’s unprotected green spaces. When the reforms hit, any area without a local plan will be more or less up for grabs as opportunistic developers make use of the ‘default yes to development’, which will apply when no plan exists.
“All local authorities need to get their plans in place. But there also needs to be enough time and money available for them to do this and to consult with their local communities.
“We hope the Government will use this consultation period to listen to the widespread criticisms of their proposals in the draft NPPF. But they must also give councils enough time and resources to draw up quality local plans based on extensive consultation with local people.”
The proposed changes to the planning system mean that wherever local plans are “absent, silent, indeterminate or where relevant policies are out of date” councils will be required to approve any development as long as developers can claim the adverse impacts will not “significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole” . In CPRE’s view, the Framework “taken as a whole” provides little protection against sprawling, poor quality development in the countryside. Local authorities without an up to date plan in place will find it very hard to say to say ‘no’ to development.
The CPRE research found that almost half of local authorities are unlikely to have a core strategy in place by 1 April 2012. Almost a fifth (17 per cent) are still likely to be missing a year after the new guidance comes into force.
Notes to Editors
 Full data tables with individual local authority data can be downloaded below
 Paragraph 14 of the Draft National Planning Policy Framework. Published by the Department for Communities and Local Government, 25 July 2011. http://bit.ly/q899PW