Dear Secretary of State,

I am concerned that proposals for Planning Policy Statement 6: Planning for Town Centres (PPS6) are a missed opportunity to support local shops and diverse town centres. I am particularly concerned about the proposal to remove the need test and replace it with a weaker 'impact test'.

The need test is a vital tool for local authorities to control out-of-town development. In a survey of local authority planning officers conducted by Friends of the Earth last year, 96 per cent of officers said they believed that the need test is important and 81 per cent believed that the absence of a need test would make it harder to focus new development in town centres. Instead of simply removing a key test, the need test must be integrated into a more robust set of policies to make the 'town centre first' policy more effective, to place a stronger emphasis on more sustainable patterns of development and to encourage genuine retail diversity.

Please introduce a stronger policy for town centres that retains the need test and includes a presumption against out-of-town development and a tougher test for diversity to ensure that planning policy delivers sustainable development and a real choice of where to shop.

Yours sincerely,

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