Response to WMRSS Phase 3 Revision

West Midlands Regional Assembly
Regional Partnership Centre
Albert House
Quay Place
92-93 Edward Street
B1 2RA

Response to WMRSS Phase 3 Revision - Lichfield Civic Society

Dear Sir or Madam,

This response has been prepared and is submitted by Lichfield Civic Society. The Society's principal concern in relation to the Phase 3 Consultation relates to Policy QE5, Protection and Enhancement of the Historic Environment. We are, therefore, responding to Question ENV6, both by completing the relevant section of the Response Form and providing additional comment to supplement this within the remainder of this letter.

It is the view of the Society that very little change is necessary to the existing RSS Policy QE5. The Key Issues paragraphs of the Options Consultation document (page 64) express very clearly the importance of protecting and enhancing the historic environment in the following sentences:-

"The historic environment offers regeneration, leisure and tourism, and educational opportunities, and is also vital to the valued and distinctive character and identity of the Region's urban and rural areas. However, there is the potential that this irreplaceable resource may come under pressure particularly in areas designated for significant housing growth."

In the Society's opinion this should continue to be the general basis of the approach and justification for the content of Policy QE5, subject to the proviso that its policy content includes reference to the smaller historic towns and that the previous references to "market towns and cathedral cities" are retained.

The Society have a concern that the list of issues (a)-(j) included in the Consultation document is too lengthy and requires to be more focussed and simplified. The Policy should continue to concentrate in particular on the existing Policy QE5 A, B (i), (ii) and (iii) and C rather than over-extending and diluting its content, as appears possible from the long list of issues.

In response to the list:-

(e) appears fundamental

'appears fundamental' refers to the importance of "the undesignated historic environment resource", but no reference is made explicitly to the importance of the existing, already designated resource. This particular emphasis is imbalanced and inappropriate, particularly in current circumstances.

(h) is of concern in that it omits reference to smaller historic settlements, such as market towns and cathedral cities, which can be under unacceptable levels of development pressure for change, and only refers to the Major Urban Areas and Settlements of Significant Development. The local distinctiveness and sense of place of these smaller areas need to be protected and enhanced if this Policy is to be effective and address the issues in a satisfactory manner, since by their very nature and character they are potentially the most vulnerable areas.

In conclusion and to follow up on the Key Issues paragraphs referred to earlier, the Society consider the Policy should continue and be retained generally in its present form, as suggested above. This is vital, in the Society's opinion, to ensure the historic environment in its contribution to local distinctiveness and sense of place is a priority which is emphasised explicitly for market towns and cathedral cities, as it is in the current Policy QE5. This particular reference should not be deleted or diluted in any revision to the Policy.

Finally, it is considered that at most only very minor updating to the Policy is required, since the principles invoked in that Policy are still entirely appropriate. Many of the issues referred to (a)-(j) are simply explanation, examples or justification in support of the broad thrust of Policy already existing. It seems to the Society, therefore, entirely unnecessary to re-draft or replace this Policy.

I look forward to your acknowledgement of this response and to the Society continuing to be involved in the RSS Phase 3 Revision process. In the meantime, should you have any queries in relation to this response, please do not hesitate to contact me.

Yours faithfully,

John Thompson,
17th July 2009