necessary. However the Town and Country Planning Act 1990 section 226, which allows compulsory purchase to "facilitate the carrying out of development, re-development or improvement" for the area's economic, social, or environmental well being, must be confirmed by the Secretary of State, and similarly the Local Government Act 1972 section 121 requires the council seek approval from the government Minister. Leasehold purchase The most general power originally appeared in the Leasehold Reform Act 1967. Under that Act, the Leasehold Reform Act 1987, and the Leasehold Reform, Housing and Urban Development Act 1992, private individuals who are leaseholders have the power in certain circumstances to compel their landlord to extend a lease or to sell the freehold at a valuation. Recompense, under compulsory purchase, is not necessarily a monetary payment of open market value (see James v United Kingdom [1986]), but in most cases a sum equivalent to a valuation made as if between a willing seller and a willing purchaser will fall due to the previous owner. Utility companies Utility companies have statutory powers to, for example, erect electrical substations or lay sewers or water pipes on or through someone else's land. These powers are counterbalanced by corresponding rights for landowners to compel utility companies to remove cables, pipes or sewers in other circumstances (see for example section 185 of the Water Industry Act 1991). Compulsory purchase only applies to the extent that it is necessary for the purchaser's purposes. Thus, for example, a water authority does not need to buy the freehold in land in order to run a sewer through it. An easement will normally suffice, so in such cases the water authority may only acquire an easement through the use of compulsory purchase. Procedure In most cases a Compulsory Purchase Order (CPO) is made by the purchasing authority or the Secretary of State. The CPO must unambiguously identify the land affected and set out the owners, where these are known. The order is then served on all owners and tenants with a tenancy with more than a month to run, or affixed to the land if some owners or tenants cannot be traced. A period of at least 21 days is allowed for objections. If there is a valid objection that is not withdrawn, an inquiry chaired by an inspector will take place. The inspector reports to the Secretary of State. If the Secretary of State confirms