Q5. Do you consider that the Local Plan Strategy is effective? - No

Core Policy 7 seeks to attract high value jobs in business, education and research, those supporting a low carbon economy and other key growth sector employment to sustainable locations, primarily in Lichfield and Burntwood. Para 9.2 states that the main aim is to focus on attracting high value employment into the District. No explanation is offered as to how this principal aim is to be achieved. Planning legislation does not set out a definition, nor Use Class for "high value employment". Consequently, it is not possible for the Local Planning Authority to allocate land for such an ill defined use and hence control rigorously what employment is established on site. This is a matter for market forces. Consequently, the Council can only encourage developers and prospective "high value" companies to locate in the District through other inducements, whether financial, environmental or social, over which it can have only a limited measure of influence. No information has been provided to set out how the Council will seek to implement this policy, elements of which are beyond the scope of the Local Plan Strategy. Effective implementation of such an aspiration demands either control over the land thus allocated or a formal legal agreement with the owner of the land over its precise future use. It is the submission of the Civic Society that this admitted "main aim" is unlikely to succeed, dependent as it is on market forces beyond the control of the District Council.

Additionally, the Policy states that any applicant seeking planning permission for a "high value" employment facility will have to demonstrate how they will maximise opportunities for local people and develop skills in the District. Does this imply that any applicant who cannot do so (even if "high value" jobs are involved) would be refused permission? Is permission only granted if a certain proportion of the jobs are for local people? How is "local" defined? Does this mean that only residents of Lichfield District can apply? It is our submission that such a policy is unworkable. Given the likelihood of a continuing depressed economic situation for a number of years, it would not be practicable nor politically acceptable, to refuse permission for new jobs because they did not provide high value employment. Such a policy is therefore unsustainable.

Q7. Please set out what change(s) you consider necessary to address your representations.

Core Policy 7 on page 59/60: amend the existing paragraph with the following words where the revised wording is in capitals

Within the District, high value jobs in business, education and research, those supporting a low carbon economy and other key growth sectors will be encouraged in sustainable locations, primarily in Lichfield and Burntwood. These jobs will retain and enhance local skills: and developers will BE ENCOURAGED TO work with local economic partnerships in PROMOTING opportunities for employing local people and SUPPORTING THE DEVELOPMENT OF skills in the District.

Q8. Did you raise this issue earlier in the plan preparation process? - Yes

In a letter to the District Council on 26th February 2010 the Civic Society raised doubts over the ability of the Council to implement a selective policy on high value employment through planning legislation.

John Thompson
Chairman,
Lichfield Civic Society.
September, 2012