3 The brevity and simplicity of the
What is the purpose of the NPPF?
14. In the NPPF's foreword, the Minister for Decentralisation
and Cities, Greg Clark, explains that the purpose of the NPPF
is to bring together policies from all existing national planning
policy documents into one succinct document:
People have been put off from getting involved
because planning policy itself has become so elaborate and forbiddingthe
preserve of specialists, rather than people in communities. This
National Planning Policy Framework changes that. By replacing
over a thousand pages of national policy with around fifty, written
simply and clearly, we are allowing people and communities back
The NPPF is a document that both guides the writing
of Local Plans, and is used as a substitute Local Plan when none
has been produced by a local authority.
Brevity and simplicity in any document are laudable aims, provided
they are not at the price of clarity, effectiveness and comprehensiveness,
and do not lead to confusing omissions. Planning policy must be
sufficient to guide both developers and decision-makers, and to
explain the issues and priorities that should influence decisions
on land use. This chapter explores whether the NPPF achieves these
15. Some organisations, most prominently developers,
welcomed the streamlining of planning policy.
John Rhodesa member of the Practitioners' Advisory Group
(PAG)highlighted the problems with the volume of the current
guidance on planning policy:
The sheer scale of planning policy has grown
relentlessly over the last 20 years. [Current planning policy]
is far too long to be accessible to the public or to convey a
clear and consistent message about what is genuinely important
in informing planning decisions.
He told us that the NPPF is written "in plain
English" and is therefore easier to understand than current
Adam Marshall of the British Chambers of Commerce (BCC) told us
A few [BCC] members have said to me that they
have already read the NPPF, which is a huge change from [
the nine volumes of planning guidance with which none of them
had even engaged.
Another of the four practitioners, Cllr Gary Porter,
representing the Local Government Association, agreed that the
NPPF is more accessible:
At the moment, local communities have planning
done to them and not done with them and for them. Hopefully we
will have a planning system that ordinary people can understand
rather than only people with planning degrees; perhaps then we
will get more engagement with the system. I am a great believer
that the existing system is too complicated.
Stuart Hylton of the Planning Officers Society, however,
commented that he was
not aware of many major developers who are sitting
there thinking, 'I'm not going to make that planning application
until such time as the Government simplifies its planning policy.'
I think there are other much more important factors that are driving
decisions about whether or not to take forward development.
16. Adrian Penfold told us that planning policy and
guidance had to change because of the consequences of the Localism
Act 2011, with the resulting reduction in Government prescription.
He went on to describe the confusion surrounding the NPPF document
and asked some rhetorical questions:
Is it a reduction in policy? Is it a simplification?
Is it just an exercise in précis? Or is there new policy?
I think all four are in there, and a bit more clarity about which
is which would be helpful.
17. The Royal Town Planning Institute (RTPI) also
identified a confusion about the status of the document: was it
a succinct guide to planning for the general public; a technical
policy document for practitioners; or a mixture of the two?
To address the question of the purpose of the NPPF, RTPI recommended
"a stronger narrative" about how the elements fit together
in the document, which "might assist us all in navigating
our way through the changes and ending up with a workable planning
system, with the minimum amount of transitionary turbulence."
RTPI pointed out that "the Government needs to be clear what
they want on the tin, and the contents of the tin need to match
18. When asked about the purpose and status of the
NPPF documentwhether it was a plain English guide to planning
policy, a precise technical document or a quasi-legal documentthe
The most important document is the Local Plan.
Decisions have to be taken with regard to that, legally under
section 38(6) of the 2004 Act. [
] It is important that the
national policies to be taken into account are written in an intelligible
way. It is, of course, also desirable that they should not be
ambiguous, so the drafting challenge to be clear is to capture
a language and a tone that is accessible and understandable, without
having the legalistic languagegiven that it is not statute
lawthat can exclude. That is our challenge. A lot of the
submissions that I have seen have commended the type of tone and
drafting of it and, of course, have specific suggestions that
I am all ears for.
How much planning guidance is
19. Cutting Edge Planning and Design drew what we
found to be a useful comparison between the draft NPPF and its
equivalent policy document in Wales:
The [NPPF] is punchy. [
] But punchiness
does not mean that the document is clear or fit for purpose. [...]
Planning Policy Wales shows that it is possible to reduce national
policy considerably (in their case to around 200 pages) without
losing its essence or clarityfollowing four iterations,
it has been widely praised and easy to use ([speaking] as a planning
practitioner). There are aspects of English national policy where
the editing pen has gone too fardeleting crucial national
It suggested that "[a] better crafted document
of 100-150 pages could have set the right balance between brevity
20. Many submissions argued that the brevity of the
NPPF meant it was lacking in important detail, and that this was
more likely to lead to greater uncertainty and delay.
We received a range of evidence that highlighted concerns with
the NPPF, including the removal of technical guidance. The Confederation
of UK Coal Producers pointed out that under the current arrangements
"guidance provides specific well-founded, technical advice,
which has come to be relied on, [and] its absence could create
an area of conflict that does not presently exist."
Whether or not the document is easy for the public to understand
is a very different question from whether a self-contained NPPF
is an adequate tool for planners to use and rely upon.
21. Hampshire County Council summarised concerns
that the NPPF had "over-simplified existing policy guidance
to such an extent that a great deal of important detail is lacking
in a great many areas."
While often supporting the aim of streamlining policy in the abstract,
many organisations drew our attention to specific policy areas
in which they considered the baby to have been thrown out with
the bathwater. Barratt
Developments plc, for example, stated that "the NPPF reduces
affordable housing guidance to a single bullet point and a definition
in the glossary. This appears insufficient for such an important
evidence expressed regret at the loss of detail in Planning Policy
Statements relating to a range of issues which included housing,
transport, open space and sport, renewable energy and the historic
22. This raises the issue of the status of the NPPF
in relation to other relevant national policy documents, such
as The Plan for Growth and the Natural Environment White Paper,
and whether the Framework is meant to stand alone as the sole
source of national policy on planning and development or whether
it is, in fact, one of a suite of such documents. Dr Hugh Ellis,
Chief Planner at the Town and Country Planning Association, wanted
a clearer statement of the relationship between the NPPF and National
How do NPSs relate to the NPPF? We are about
to publish a networks national policy statement that is not related
to an understanding of housing provision. That is extraordinary.
[...] The NPPF [should] set out clearly its relationships with
that national policy framework and also include some vision.
23. We welcome the fact that the Minister is receptive
to specific suggestions for improvements to the NPPF. We consider
that there needs to be a clear narrative at the start of the NPPF,
stating: where planning policy has stayed the same, but has been
simplified or summarised; where new policy has been introduced;
where current policy has been changed or removed; and the relationship
of the NPPF to other national policy documents, including National
Policy Statements and the Natural Environment White Paper. There
is no harm in increasing the length of the document moderately,
if that results in a more comprehensive and less ambiguous document.
Clarity and terminology
24. RTPI highlighted what it considered were inconsistencies
in the NPPF's terminology and suggested that "particular
effort must be given to ensuring that the wording of policies
was technically precise to avoid misinterpretations."
It cited the use of different adjectives used to describe the
word 'weight', in different and sometimes competing contexts:
'significant weight' applied to supporting economic
growth; 'great weight' to be given to protecting landscape and
scenic quality; 'substantial weight' to apply to green belt harm;
'considerable importance and weight' to apply to conserving heritage
assets. The NPPF gives no indication as to how different investors
or decision makers will be expected to balance these different
weights in individual cases. However, the rhetoric surrounding
the NPPF (e.g. that the alleged default 'no' response to applications
should become 'yes') is interpreted by some to imply that the
'significant weight' to be applied to supporting economic growth
is expected to outweigh the weights to be applied to other factors.
25. The Chartered Institution of Water and Environmental
Management cited specific inexact uses of words in the Framework:
In general, the NPPF tends to use words which
are unhelpful. A 'plan' is something which is quite definite,
clear and actionable. A 'strategy' is more of an aspiration and
a direction. Yet in this framework, it is quite clear to see that
the plan is considered to be a strategic document rather than
a planning document. There is a need for strategic priorities
but this should not be in a plan, what is needed is a 'local strategy'
in which a Local Plan provides actionable detail.
26. Others considered certain terms used in the document
to be ambiguous and poorly definedterms such as 'substantial
harm', 'viable', 'medium term', 'positive contribution', 'significantly
and demonstrably' and 'severe'.
Sir Simon Jenkins, Chair of the National Trust, summed up these
The Planning Framework is so vague you will have
one row after another. [It is] inconceivable that this document
is going to yield you faster, clearer and more certain planning.
It really will not. [...] The language is so vague as to be easily
actionable and the process itself has new tiers latched onto it.
It is the opposite of making it simple.
27. The fear of "planning by appeal" was
highlighted in evidence,
with Hampshire County Council writing that the bias towards economic
factors in the NPPF will
lead to more delay rather than a speedier system,
more confusion rather than greater clarity and, ultimately, a
by-passing of the plan-led system as more and more decisions are
determined through the appeal process.
London Councils highlighted that the ambiguity in
the NPPF's language would lead to different interpretations and
therefore inevitable, and costly appeals, "which in a time
of reduced resources, having to pay for planning appeals may threaten
the ability of local authorities to properly resource other important
Tony Burton, from Civic Voice, told us that, where there is no
Local Plan in place, the NPPF allows a developer to propose whatever
they want to do "and go to appeal, which is what the NPPF
28. The Government needs to study the different alternative
suggestions, and produce another draft that is more precise and
better defined; the NPPF may not be statue law, but its content
is still justiciable and it is important to get it right. The
Government should not treat the NPPF as if the number of pages
in it were more a mark of its quality than the utility, clarity
and consistency of the policies within it. Nor can all planning
policy necessarily be reduced to very simple terms.
29. Brevity and simplicity are to be applauded
in any document. However, we consider that the NPPF does not achieve
clarity by its brevity; critical wording has been lost and what
remains is often unhelpfully vague. If the NPPF is to be a document
that assists with practical decision-making, rather than a lawyers'
charter or an easy-to-read guide to the planning system, its drafting
must be more precise and consistent, and sufficiently detailed
to enable local authorities to write their own Local Plans. The
Government should carefully consider the alternative drafts, submitted
by many organisations as part of DCLG's consultation, in order
to produce a tighter, clearer document, and should not make a
fetish of how many pages it is. Examples of such words and phrases
needing tighter definitions in the NPPF include: 'significant
weight'; 'great weight'; 'substantial weight'; 'considerable weight';
'significant flexibility'; 'a high degree of certainty'; 'sustainable
economic growth'; 'absent'; 'silent'; 'indeterminate'; 'out-of-date';
'certificate of conformity', 'where practical'; and 'where reasonable'.
30. A key to dissipating the confusion that has surrounded
the draft NPPF is to what extent it provides guidance as well
as policy. The Minerals Products Association highlighted that
the different roles of guidance and policy have been interchanged
in the document:
It is not clear from the draft NPPF what function
policy and guidance respectively have in the planning system.
] By virtue of the title, the role of the NPPF is to set
out national planning policy, not to give guidance.
John Rhodes told us that the Practitioners' Advisory
Group thought that planning guidance was part of what they saw
as a problem in the planning process:
The planning system is bogged down by a great
deal of guidance that tends to suffer from the same problem; it
is very repetitive. For instance, we looked at PPS 12, which is
about preparing plans. It is a pretty good document, but the guidance
that sits behind it is the reason why seven years after the 2004
Act, we still do not have a network of up-to-date plans across
the country. The planning system is just too slow.
31. The accompanying Impact Assessment of
the NPPF states that there will be
a fundamental review of all the supporting documentation
(which comprise a further 6,000 pages across a further 160 documents)
to identify those areas where it is still appropriate for the
Government to issue good practice guidance: in the majority of
cases, we expect that any future good practice guidance would
be developed and owned by relevant external bodies, rather than
being specified centrally.
Several submissions highlighted the risks involved
in external bodies formulating additional guidance.
For example, Barratt Developments plc said that:
Even when some of the additional documentation
is produced it is uncertain if this 'good practice' would be official
government policy or just the wishes of a lobby group. This Company
considers it is essential that the Government should have ownership
of core documents irrespective of the body that initiated their
We support the view that the Government needs to
take ownership of key additional guidance that is produced on
aspects of planning policy, to avoid competing bodies producing
guidance to support their own aims, or contradictory guidance.
We note that while most organisations broadly supported the aim
of reducing the overall length of current policy, many of them
asked for the retention of specific policies in the areas of most
interest to them. This indicates that those familiar with, and
needing to use, policy on particular topics find a certain amount
of detail and guidance helpful.
32. When asked about additional planning guidance
being available to local authorities, the Minister described the
status of current and future guidance:
There is guidance available, for example, on
housing market assessments and things like that, and we will want
to consider that, but we must take one thing at a time. Let me
outline the choices. One downside of government guidance is that
it becomes quasi-legal if it comes to a court case or an appeal.
Even though it is meant, literally, to be guidance and quite a
benign thing to help you out, it can be cited, and you can be
accused of not having followed it; that happens not just in planning,
but in every walk of life. One does not want to empower communities
in one way and then disempower them by requiring them to follow
other documents as if they were legal documents. However, implicit
in that is my acceptance that, on various technical aspects, it
is reasonable to give some guidance. [
] One suggestion is
that we work with the professional bodies, for example, to promote
guidance on the more technical aspects. We have not taken any
decisions on that, but it is a helpful suggestion.
33. At least until new guidance is produced, the
continuing relevance and force of the body of current planning
guidance under the NPPF needs to be clarified and secured. We
recommend that once the NPPF is published, all guidance and advice
documents be reviewed by DCLGin consultation with local
authoritiesitem by item, so that the content of the documents
that local authorities find operationally and technically useful
can be retained for reference in some form, lest councils spend
valuable time reinventing numerous wheels. New guidance produced
by third parties or groups of practitioners should have government
ownership, to ensure consistency of approach.
34. An additional confusion is that the Government's
publicly-stated position that unsustainable development should
not be approved is not, in fact, precisely reflected in the draft
35. It is highlighted in the Government's Easier
to read summary - draft National Planning Policy Framework:
The presumption is a new policy designed to ensure
that the planning system as a whole focuses on opportunities.
The presumption means that where Local Plans are not up-to-date,
or not a clear basis for decisions, development should be allowed.
But the development should not be allowed if it would undermine
the key principles for sustainability in the Framework (such as
protecting the Green Belt and Areas of Outstanding Natural Beauty).
The presumption also means that where development is in line with
the Local Plan, it should be allowed without delay.
36. The draft NPPF simply states that development
should not be allowed if its adverse impact would "significantly
and demonstrably outweigh the benefits, when assessed against
the policies in this Framework taken as a whole".
37. The Government should focus on arriving at consistent
and succinct wording on this issue, clearly identified as such
and within the NPPF. The Government's documents relating to
the NPPF risk creating confusion. Any such ambiguities must be
resolved within the document itself, as supporting statements
made to explain or moderate its meaning are unlikely to remain
reference sources in the years ahead.
Policy topics not included in
38. The brevity of the draft NPPF compared to the
body of planning guidance it replaces caused anxiety for groups
who believed that as a result their areas of interest were no
longer adequately represented in national policy. Such groups
feared that absence from national policy would downgrade appreciation
of those planning topics, cause local planners to overlook particular
community assets, or introduce uncertainty about the weight such
assets should be accorded in planning or decision-making.
Tony Burton, Director of Civic Voice, explained the root of these
concerns, arguing that, in areas not covered by an up-to-date
plan, unless it can be shown that a proposed development will
cause "significant harm" to some asset, feature or amenity
which is explicitly acknowledged in the NPPF, "it is pretty
much a free-for-all."
Mr Burton spoke of the need, therefore, for "the safety net
of a reference in the NPPF."
39. A significant number of the submissions we received,
for example, drew attention to the lack of specific references
to culture and the arts in the draft NPPF.
The Theatres Trust regretted that PPS4's reference to the importance
of culture and other uses such as theatres and concert halls in
relation to the vitality of town centres was not replicated in
the draft NPPF, despite other PPS4 policies being incorporated.
Mhora Samuel, Chief Executive of the Trust, suggested that the
section of the Framework on sustainable communities, which refers
to open space, recreation and sport "could very easily incorporate
the words 'culture' and 'cultural uses' and therefore offer clarity
to local planners."
She argued that there was precedent for such an addition in a
Government amendment to the Localism Bill, which clarified that
assets of community value could be defined according to cultural,
recreational or sporting interests, under the broader category
of "social interests".
The definition of sustainable development set out in the 2005
UK Sustainable Development Strategy also referred to cultural
40. By replacing voluminous planning policy with
a much shorter document, and then establishing that this document
will be used to determine planning decisions in the absence of
a Local Plan or in the event that a Local Plan is silent on a
particular issue, the Government has given many interest groups
cause for concern. Unless their areas of interest and certain
well-established policies are referred to explicitly in the text
of the NPPF, they understandably feel that the new system puts
important community assets at the mercy of the presumption in
favour of sustainable development. We conclude that without
lengthening the Framework excessively it should be possible for
the Government to allay fears about a lack of detail and omissions
from the NPPF, by cross-referencing other documents and by adopting
a more inclusive definition of sustainable development. The revised
NPPF should also reassure local authorities that they are permitted
to take into account in their Local Plans issues that are not
explicitly referred to in the Framework.
41. While the general thrust of the Report is about
the wider planning issues, we received strong representations
on specific issues and we have concerns about some unintended
consequences arising from the wording used in the draft NPPF or
the omission of an issue from the document. For example, the definition
of affordable housing in the draft NPPF is different from that
contained in PPS3: rather than referring to a cost low enough
for households to afford, in the context of local incomes and
local house prices, it refers to housing where eligibility
is determined with regard to local incomes and house prices. Shelter
pointed out that this could result in a scenario where housing
is considered affordable if its eligibility is determined by income,
even if it is unaffordable to people of average or below average
incomes. In such
cases, it must be clear whether the Government intended to make
a change, or whether the draft Framework has simply imperfectly
reflected continuing policy. We do not support the change in
the definition of affordable housing represented by the wording
in the draft NPPF. We recommend that the current definition of
'affordable housing', contained in Planning Policy Statement 3,
be reiterated in the draft NPPF to avoid any confusion.
42. On the consequences of an omission, Civic Voice
pointed out that the word "amenity" does not appear
in the draft Framework, a term which could be a useful "catch-all"
for facilities or features of value to the community that are
not otherwise referred to in the NPPF.
The Theatres Trust similarly argued that "the presumption
will be in favour of those uses that are covered within the NPPF."
Several submissions addressed the treatment of sport and leisure
facilities in the draft NPPF.
The Football Association's principal concern was that the position
of Sport England as a statutory consultee on planning applications
which affect provision for sports be confirmed and referred to
in the NPPF; Robert Sullivan, the FA's Head of Public Affairs,
told us that they would like Sport England's role to be explicitly
mentioned to, in order "to reassure people in the sporting
communities that those protections can still be maintained."
As it stands, the FA argued that the reforms "place playing
fields and facilities at great risk, in favour of broader development
Sport England deprecated the loss of a requirement for replacement
sports facilities to be provided if they are lost to development,
even where a deficiency exists, provided the "the need for
and benefits of the development clearly outweigh the loss."
Mr Sullivan argued that this change of policy was unnecessary,
as the development industry was already accommodating of the need
to factor in like-for-like replacement of facilities where need
43. The NPPF should refer to the role of statutory
consultees as a safeguard for community amenities, such as playing
fields. We recommend also that the revised Framework should reinstate
the requirement for equivalent or improved replacement sports
facilities to be provided if they are lost to development, where
a deficiency would otherwise result. We consider that the
Government needs to examine whether there are unintended consequences
arising from the wording used in the draft NPPF or the omission
of an issue from the document. The Government should review
the NPPF as a whole, to check that there are no other relevant,
specific issues that are either omitted or adversely affected
by the changes in the Framework.
44. Some witnesses thought that a spatial element
would contradict local decision making in the NPPF. Professor
Paul Cheshire argued that "it is profoundly to misunderstand
how the space economy works to think that land use planning should
or can redress the problems of less prosperous regions."
The British Chambers of Commerce and the CBI were concerned that
"injecting some sort of top-down spatial element" would
undermine the Government's localist intentions.
Dr. Marshall, from the BCC, told us that "you could have
a hierarchy of development principles across geographical areas
and it is the centralist position that predominates. That would
constrain local decision making much more than just about anything
he went on to say that "I have some sympathy with those who
say that planning that goes above local authority level but below
national level can get lost."
45. Several organisations expressed regret in their
written submissions that the Government had decided not to incorporate
a spatial element into the draft NPPF.
Some pointed out that The Plan for Growth had identified
geographical imbalance as one of the major economic problems facing
the country, with growth concentrated in the South East and other
parts of the country increasingly reliant on public sector employment.
From this perspective, the lack of a spatial dimension to the
NPPF seemed "a missed opportunity", and unlikely to
support the commitment to share prosperity across the UK.
RTPI commented that the Framework offers no guide to locating
new infrastructure in relation to new areas of growth.
Stephen Joseph of the Campaign for Better Transport argued that
England would be exceptional in not seeking to integrate major
new transport infrastructure with spatial planning, and that this
would undermine, for example, the regeneration potential of High
46. The Institution of Civil Engineers (ICE) stated
that the document "seems largely 'placeless'."
ICE noted in particular that the words 'city' and 'cities' did
not appear in the draft NPPF. There are other special cases which
are not acknowledged, such as the particular circumstances in
National Parks, where specialised government policy applies.
Dr Hugh Ellis of the Town and Country Planning Association (TCPA)
told us that "this document is not written with any spatial
awareness" and explained why he felt this approach was flawed:
[There] are five or six powerful reasons why
you need a spatial approach in England. Ironically, economics
is one of them; infrastructure provision is another; climate change;
food security; and energy security are others. [... All] I would
like the NPPF to do is to have one paragraph that just understands
that space is different in England. If you write a policy in the
NPPF about six years' supply of housing in one place, it has perverse
outcomes in low demand areas. There must be some recognition that
London is an extraordinary place in the life of our nation. There
must be some understanding of the place of Liverpool or other
cities in the North that require a clear future. You have to give
investment certainty to those places. If the output is no investment
certainty, you almost talk yourself out of the North of England
if you are not careful. [
] How will we deal with displaced
demand without that kind of spatial approach? The nation needs
47. There is evidence of concern that the draft
NPPF is largely "placeless". While we recognise that
it was never the intention of the Government to issue the draft
NPPF as a 'spatial' plan, we consider that its impact and effectiveness
would be improved if the possibility of differential impacts of
its policies on different parts of the country were to be recognised
in the Framework and that, where a local authority seeks to recognise
local variations, the NPPF encourages local authorities to ensure
that there is a robust evidence base in place to justify these
variations, and thus, that it serves the Government's stated intention
to re-balance the national economy.
22 Draft NPPF, p 2 Back
Draft NPPF, para 26 Back
Ev w67 [Taylor Wimpey UK Ltd]; Ev w158 [County Councils Network];
Ev w187 [The Federation of Master Builders]; Ev w247; Qq 2, 8 Back
Ev 84 Back
Q 34 Back
Q 2 Back
Q 134 Back
As above Back
Q 275 Back
Q 275; see also Ev w152 [The UK Environmental Law Association] Back
Ev 152 Back
Q 275 Back
Q 282 Back
Q 320 Back
Ev w11 Back
Ev w12 Back
For example: Ev w130 [The Renewable Energy Association]; Ev w91
[West Berkshire Council]; Ev w42 [Hampshire County Council]; Ev
91 [West Berkshire Council]; Ev 113 [Planning Officers Society];
Ev w58 [Mineral Products Association]; Ev 139 [CPRE]; Ev w61 [Woodland
Trust]; Ev w133 [Confederation of UK Coal Producers]; Ev w134
[Sport England]; Ev w142 Business in Sport and Leisure]; Ev w146
[West Midlands Planning and Transportation Sub Committee]; Ev
w153 [UK Environmental law Association]; Ev 147 [Shelter] Back
Ev w134; see also Ev w126 [ARUP] Back
Ev w42 Back
Ev w46, Ev w93 Back
Ev w49 Back
Ev w66 [The Institute for Archaeologists]; Ev w82 [Highbury Group
on Housing Delivery]; Ev w87 [Historic Houses Association]; Ev
w131 [Renewable Energy Association]; Ev w254 [Renewable UK] Back
Q 60 Back
Ev 152 Back
Ev 152-53 Back
Ev 162 Back
Ev w87 [Historic Houses Association]; Ev w296 [London Councils] Back
Qq 110, 113 Back
Ev 93 [TCPA]; Ev 141 [CPRE]; Ev w100 [Living Streets]; Ev w295
[London Councils]; Q 139 [Stuart Hylton]; Q 260 [Stephen Joseph];
Q 196 [Tony Burton] Back
Ev w43 Back
Ev w296 Back
Q 196 Back
Ev w49 Back
Q 8 Back
NPPF Impact Assessment, p 9 Back
Ev w49 [Barratt Development plc]; Ev 102 [British Property Federation];
Ev w77 [House Builders Association and the Planning and Development
Association]; Ev w121 [Banbury Civic Society]; Ev w233 [Country
Land and Business Association] Back
Ev w49 Back
Ev w233 Back
Q 341 Back
Draft NPPF, Easier to read summary, p 4 Back
Draft NPPF, para 14 Back
Ev 124 Back
Q 196 Back
Q 202 Back
Ev w81 [The Little Theatre Guild of Great Britain]; Ev w95 [Voluntary
Arts]; Ev w97 [The Kings Theatre Trust]; Ev w103 [The Partnership
for Urban South Hampshire Quality Place Delivery Panel]; Ev w117
[ixia]; Ev w118 [Alan Butland]; Ev w157 [The National Federation
of Artists' Studio Providers]; Ev w177 [English Heritage]; Ev
w221 [Liverpool and Merseyside Theatres Trust]; Ev w258 [Institute
of Historic Building Conservation]; Ev w145 [Michael Holden];
Ev w292 [The Design Council]; Ev w321 [The Heritage Alliance] Back
Q 181; DCLG, Planning Policy Statement 4: planning for sustainable
economic growth, 2009, para 7.4 Back
Q 188 Back
Q 187 Back
Q 198 Back
Qq 229, 237 Back
Ev 124, 125 Back
Ev 125 Back
Ev w136 [Sport England]; Ev w115 [The Sport and Recreation Alliance];
Ev w142 [Business in Sport and Leisure]; and Ev w175 [Fields in
Qq 197, 215, 218 Back
Ev 121, 123 Back
Ev w135; Draft NPPF, para 129 Back
Q 221 Back
Q 61 Back
Q 37 Back
As above Back
Q 40 Back
See, for example, Ev w128; Ev w132. Back
The Plan for Growth, para 1.4 Back
Ev w149; Q 247 Back
Ev 152 Back
Q 246 Back
Ev w214 Back
Ev w340 Back
Q 53 Back
Q 60 Back