| Lichfield Local Plan Sustainability Appraisal | |
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Representation: Although the current consultation is stated to be in relation to an updated Sustainability Appraisal which accompanies the Plan, the Civic Society wishes to comment principally on its wider implications and its relationship to the proposed Submission Local Plan Strategy. The updated Sustainability Appraisal concentrates its efforts in a very detailed and mechanical manner in "measuring "matters against objectives and targets. It does not look at long term strategic and sustainability issues facing the District, which is also true of the Local Plan Strategy itself. The late introduction of a small number of additional, "so-called", alternative development strategies, as now assessed in the updated Sustainability Appraisal, is not seen as completing a comprehensive or rounded consideration and in depth examination of genuine alternative strategies. The current approach to the Appraisal and the Plan will always show that the existing larger settlements in the District, in possessing the larger number and wider range of services and facilities, are the most sustainable. This in turn results mechanically in these settlements being accepted as the locations where the great majority of new development is to be placed. It is not considered this is an appropriate approach to long term strategic planning; for at certain times policy must change direction and look to a different solution. To continue to increase the size of the larger settlements interminably is, in a sense, "non-planning", or at best trend planning. It does not follow that larger settlements are, by definition, "more sustainable". At present, this is the route being followed for Lichfield District. An approach should be adopted which properly looks at the long term in a comprehensive and strategic manner, and includes an assessment of potential and achievable sustainability of these scenarios at their completion and at milestones as they are being delivered. In terms of Lichfield District this should involve a vision looking 30 or 40 years ahead, and accepting that bringing forward one or more new or enlarged growth points away from the established areas of Lichfield City and Burntwood would have many on-going benefits and would also achieve a new and more balanced sustainability rating in the longer term, as follows:
In more detail these proposals would involve policy changes in certain areas but elsewhere would be a continuation of current and emerging policy. At Fradley areas of brownfield land with planning approval for employment use are being proposed as a significant part of the Fradley SDA. An extension to this area to include the area of Fradley West, as recently put forward, would be a rational extension to the SDA area. These areas should be seen as initial phases of the long term approach. Subsequently, areas to the east of Fradley and Alrewas, beyond the A38, would become later phases of the development (i.e. Brookhay Villages). Such a settlement strategy would support the existing housing development at Fradley, with additional services provision, and would benefit from the large scale employment opportunities existing and emerging at Fradley Business Park. The scale of the emerging development proposed would enable very significant improvements to be made to the A38 and associated highways infrastructure and new rail passenger services, stations and infrastructure should also be seen as a fundamental provision for the scale of development envisaged. Rail services between Lichfield (and the Cross City line) and Burton, Derby and the North should be seen as a major long term benefit to the area. In relation to this particular proposal for the Fradley area, it should be further noted that at earlier stages of the Plan preparation process the Council ignored the overwhelming support of respondents to the new/extended settlement option; and that this approach was former County Structure Plan policy and District planning policy which was subsequently abandoned without any rational justification. Furthermore, the WMRSS Phase 2 Review Panel in their Report in 2009, having considered submissions concerning the matter endorsed in a recommendation a comprehensive investigation of the option: this has never been undertaken by The District Council. No reason has been given as to why this potential option has not been tested. The approach proposed to concentrate future development in the District at a new/extended settlement would also ensure the continuing pressures to erode the Green Belt and ADR to the south of the City could be effectively addressed, and the "openness" that exists between the City and the West Midlands conurbation would be safeguarded. Implicit in this approach is the abandonment of the Lichfield South SDA proposal, as well as ideas for removing further areas from Green Belt adjoining Lichfield City (e.g. Cricket Lane) and Burntwood as has been recently put forward. Similarly, the development proposals for East of Lichfield / Streethay (SDA) should also be abandoned, as unnecessary under this new approach, and also to prevent coalescence between the City and existing and proposed Fradley development areas to the north. It is additionally considered that the development of the so-called New Village, near Curborough, would also be inappropriate, leading to coalescence with the City, and should be abandoned. A further reason for this relates to the need to maintain an open area through which the route of HS2 and the proposed extensions to Manchester and the North can pass. The proposals already put forward by the Council in the Local Plan Strategy for additional development on the edges of Rugeley and Tamworth, and within various Key Villages, would not be affected by these suggested proposals and would be anticipated to be retained in the Strategy. The Civic Society have long sought to support an effective long term vision and approach to the future development of the District, and consider the solution, as summarised above, achieves this by creating the framework for a more sustainable pattern of development for the future. The solution proposed above for the future long term development of the District would assist in addressing cross boundary issues between Lichfield and East Staffordshire Districts, which is not achieved in the current Council Submission documents, by focussing clearly on this corridor. Meaningful liaison and co-operation between the two planning authorities, the Highways Agency and Network Rail and other relevant parties could ensure achievement of the delivery of housing and employment and necessary infrastructure to serve the area in a balanced and rational manner, and the Local Plan Strategy and Sustainability Appraisal should be amended to accommodate this approach. Another key aspect of the mismatch between the Local Plan and the Sustainability Appraisal is the impact of the Duty to Co-operate and the extent to which this has been fully complied with. It is not clear that this has been resolved in relation to the neighbouring metropolitan Councils of the West Midlands and other public bodies. Although only available since October 2012 the Birmingham City Plan 2031 consultation has proposals for development in the Green Belt adjoining Lichfield District. The City in a letter to the District Council dated 10 September 2012 claim that there may be a requirement for housing development outside their boundary to meet City needs. They also assert that housing provision outside their boundary is consistent with the previous RSS whereas the emerging RSS policies were to encourage a level of provision of new dwellings and jobs in the Major Urban Areas that would reduce the out migration trends. The City's proposals raise issues that need to be addressed and fully evaluated in the Sustainability Appraisal along with the transport and highways aspects of these cross border issues. Conclusion The evaluation of options for housing has not in our view properly addressed the range of realistic long term development options and hence the role that development north of Lichfield could play in providing a sustainable development solution. These deficiencies are not addressed in the updated Sustainability Appraisal, where potentially sustainable options put forward during public consultation have not been assessed in the same depth as the preferred options. The RSS Panel recommendation for a comprehensive study, detailed in the answer to the next question, has not been undertaken, nor reasons for its omission from analysis put forward. There is also a need to resolve that the Duty to Co-operate duties have feed back into the Local Plan and Sustainability Appraisal. The following issues were raised earlier in the Local Plan preparation process: 1. The Society's evidence to the Regional Spatial Strategy Panel Examination in 2009 resulted in a Panel recommendation on housing provision in Policy SS12 Lichfield Development Strategy that said:- " To the north-east of Lichfield in the general area of Streethay / Fradley a comprehensive study should be undertaken of the most sustainable way to meet long-term development needs, be that through an urban extension, a new linked settlement or a combination of such forms. If of sufficient scale such development might extend beyond the plan period." (Source: West Midlands Regional Spatial Strategy Phase Two Revision Report of the Panel: September 2009 page 235). 2. In our February 2011 comments on the Core Strategy consultation we did state: "It is noted that the recommendation of the WMRSS Phase 2 Revision EiP Panel to undertake 'a comprehensive study of the most sustainable way to meet long-term development needs' to the north-east of Lichfield has NOT been undertaken." 3. Our response to the Local Plan submission version July 2012 on the housing aspects said there was a question whether the initial Sustainability Appraisal report meet the legal requirements as detailed in the Lichfield Alliance submission. We support the comments of the Lichfield Alliance on the updated Sustainability Appraisal. The decisions on the strategic approach on the choice of housing site locations is a crucial aspect of Local Plan policies which is of great importance to the people of Lichfield and the members of the Lichfield Civic Society. John Thompson |
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