We understand the Lichfield Alliance is submitting a representation on this whole aspect, which the Civic Society support in principle, and we will not repeat those issues here.

Q2. Do you consider that the Local Plan Strategy meets the legal and procedural requirements? - No

The Council has introduced a new policy commitment regarding release of Green Belt beyond the plan period that was not in the draft Core Strategy.

The text in the draft was:-

The role of the Green Belt is recognised, and in particular that of Major Developed Sites within the Green Belt; with their continuing strategic function to be assessed through the Allocations of Land DPD.

The Local Plan Strategy now says:-

The important role of the Green Belt will be recognised and protected, with the majority of new development being channelled towards the most sustainable urban areas of Lichfield and Burntwood, which are inset within the Green Belt.

Detailed changes to the Green Belt boundary around the edge of Lichfield City urban area to meet longer-term development needs beyond 2028 will be considered through the Local Plan Allocations document.

Minor changes to Green Belt boundaries may be appropriate for all settlements within the Green Belt, with the precise boundaries of these changes being determined through the Local Plan Allocations document or through a Neighbourhood Plan.

The specific concern is the policy concerning detailed changes to meet longer term needs beyond the plan period will only apply to the edge of Lichfield City. Given the issue of review of identifying longer term needs in the NPPF was in the now superseded PPG 2: Green Belt the Council should have included this strategically important issue in the draft Core Strategy or at an earlier stage in the process. Producing a Green Belt review at a very late stage in the process (July 2012) and not giving any opportunity for public involvement or consultation on that document and then to incorporate aspects of it into the published Strategy document is fundamentally wrong.

The Core Policy 1 explanation in paragraph 4.15 on page 25 states:- A Green Belt review forms part of the evidence base which will underpin policy options identified in the preparation of the Local Plan Allocations document. The NPPF requires the consideration of whether the Green Belt boundary will remain appropriate to meet the District's needs beyond 2028. The evidence suggests there will be a range of options to meet longer term needs but that these might need to include considering longer term growth for the City as it is the strategic centre for the District and its most sustainable settlement.

The statement "might need" does not justify the formal Core Policy qualification that any change is expressly confined to the "edge of Lichfield City" thereby formally excluding consideration of any other locations in the District whether in or outside the Green Belt.

Not only has there been no public consultation whatsoever on this important change for reasons set out below we do not consider that the review document is sound nor does it justify the specific policy now being challenged.

Q3. Do you consider that the Local Plan Strategy is positively prepared? - No

We consider the change mentioned in Q2a to focus possible longer term changes to the Green Belt on the edge of the City as demonstrated by the Council's own explanation of it is not based upon an objective assessment of the evidence base.

Q4. Do you consider that the Local Plan Strategy is justified? - No

The various references to Green Belt policy are unclear and contradictory, e.g. in Core Policy 1, The Spatial Strategy. Additionally, a critically important element of policy proposing changing Green Belt boundaries to accommodate development beyond the plan period has been introduced in the July 2012 document without any prior public consultation or consideration, creating a fundamentally unacceptable situation which must be seen as unsound. Furthermore in relation to this matter, the Council suggest in the document that all details relating to these future changes in Green Belt boundaries is to be addressed by a future Local Plan Allocations Document. There is an expectation contained in this approach to bring about potentially very significant changes in future to the Green Belt and the Spatial Strategy, based upon one or two fairly vague statements within Policy Core Policy 1, and a very recent Green Belt Review paper placed on the Council web-site. This element of the proposed Policy and the approach is also considered to be unsound practice.

These points will be elaborated in the following paragraphs:

Although Core Policy 1 proposes that Green Belt land be protected from development, as do saved policies from the Local Plan, the same Policy then also proposes the principle of changing Green Belt boundaries to accommodate development beyond the plan period around the edge of Lichfield City (i.e. from 2028). Additionally the Policy proposes minor changes of Green Belt boundaries for the same purpose at Burntwood and various key rural settlements and villages. The Policy also proposes that these changes will each be detailed in a future Local Plan Allocations Document. The content and approach to this element of the Policy is considered unsound for the following reasons.

These policies have not appeared in any previous Local Plan or LDF Core Strategy consultation document. Thus, there has been no opportunity for consideration of this issue to date by interested parties or consultees. The proposal and its implications are fundamental planning issues, and failure to include any consideration in earlier consultation, along with a lack of justification, lack of any evaluation of the consequences and the issues involved and of potential alternatives available to address in an appropriate manner the handling of "development beyond the plan period" are significant defects in the approach.

Furthermore, the proposal made to include the details of the Green Belt boundary changes in a future Local Plan Allocations Document is procedurally flawed. It will be too late in the plan-making process for interested parties to have meaningful involvement in very important matters once the present stage is completed. Such an approach undermines the status of Green Belt policy. The Local Plan Strategy stage is the place for full consideration of this matter, but in much greater depth than at presently put forward. For this same reason, there should have been consultation earlier on such significant matters.

The basis of the scale of needs for development beyond the plan period requires consideration and this has not yet been established. (In fact, it has not yet been finalised for the current plan period.) This indication is necessary prior to testing and deciding broad locational policy directions and alternatives, and these steps are required before any decision to change Green Belt boundaries is made. The West Midlands Regional Spatial Strategy (2008) and the Phase 2 Revision EiP Panel Report includes two issues of continuing relevance in consideration of this matter. Firstly, the RSS expresses strong support for "urban renaissance", particularly within the West Midlands conurbation (the Major Urban Areas). If the conurbation authorities are to fulfil these ambitions for "renaissance", with a resulting significant reduction in population movement out of the conurbation to shire district areas such as Lichfield, development pressures on the District will reduce considerably by the end of the plan period and beyond. Secondly, the Phase 2 Revision EiP Panel Report (2009), following their detailed consideration of the issues affecting Lichfield District, recommended (R8.21) :-

"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."

A full and comprehensive study has not been undertaken by the District Council and the real potential of following a different planning strategy and supporting and creating a New/Extended Settlement at Fradley has not been taken up. The former Staffordshire and Stoke on Trent Structure Plan (2001) and, to a lesser extent the Lichfield Local Plan (1998), contained proposals for Fradley to become a major housing growth point in a location beyond the Green Belt, with significant amounts of previously developed (brownfield land) and possessing extensive employment potential, and capable of taking development pressures from Lichfield City in a strategically planned and sustainable manner.

This Fradley based strategy could be utilised to provide a viable and realistic alternative location for development for the longer term and obviate the need for further encroachment into Green Belt around Lichfield City and other settlements. The approach as proposed at present by the Council will continue to erode established Green Belt and close the open gap between the conurbation and Lichfield and greatly increase the potential for coalescence of the built up areas, as well as undermining the movement towards "urban renaissance".

The Green Belt Review paper recently placed on the Council web-site as part of the evidence base for the Local Plan to justify the approach being proposed is cursory and the evidence provided within Section 10 is partial. Two examples of this failure are (i) the assessment of development needs ignores sub-regional and regional strategies and potential input from neighbouring authorities under the duty to cooperate requirement, and is simply a trend-based approach relying on trend forecasts with continuing large scale in-migration into the district. This is contrary to the needs established and accepted regionally for "urban renaissance", and (ii) the approach ignores all potential alternative locations in the District which are outside or beyond the Green Belt, and, as there are potential opportunities for development to be accommodated in such locations, this justification is considered unsound.

Until the need for development has been properly established, no clear strategic approach can be satisfactorily formulated to address longer term development needs. The basis of this approach should take full account of all relevant circumstances, including external factors such as cross-boundary issues. This would need to involve cooperation with the conurbation authorities, and particularly those immediately adjoining authorities of Birmingham and Walsall, in order to support "urban renaissance". To accord with the RSS, this would lead to a significant reduction in population movement into Lichfield from the conurbation authorities. Once that work is completed and a level of future development needs for the District established, the alternative strategies for locating it can be investigated and the implications of these considered in the round. The basis of this should be the approach advocated, and referred to earlier, in the RSS Phase 2 Revision EiP Panel Report , and which, in terms of investigating alternative locations for development to minimise loss of Green Belt, is reinforced by the NPPF (paragraph 84).

In the event there were to be further growth and development pressures placed upon the District beyond 2028, and, as stated above, this is not established at this stage, locations other than within current Green Belt should be considered for development. Such an approach would reinforce "permanence" of Green Belt and support the long established and clearly defined purposes of Green Belt. On its southern and western urban edges Lichfield City has already reached appropriate and defensible boundaries. It is, therefore, now timely to examine all alternative strategies for the long term development of the District, rather than simply "rolling back" the Green Belt around the edge of the City. There are various alternatives available which require serious consideration, including the northern edge of Lichfield City, the Fradley area, as referred to earlier, and the edges of Rugeley and Tamworth.

Until the assessment of development needs in the longer term has been undertaken and the alternative locations comprehensively evaluated, and rigorous public consultation completed, the present Green Belt should continue to be given full protection by the District Council in line with the NPPF, paragraph 83.

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

The proposed strategy undermines the "permanence" of the Green belt without adequate or comprehensive justification, as described in response to earlier questions.

Q6. Do you consider that the Local Plan Strategy is consistent with the National Planning Policy Framework? - No

The proposals have not taken into account regional and sub-regional issues in considering development needs through a failure to fully engage with other local authorities in accordance with "the duty to cooperate".

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

Any proposals for the release of Green Belt beyond the current plan period should be based upon sound evidence and be the subject of full public consultation before any decisions are made.

To regularise the situation replace the wording in Core Policy 1:-

Detailed changes to the Green Belt boundary around the edge of Lichfield City urban area to meet longer-term development needs beyond 2028 will be considered through the Local Plan Allocations document.

with the following or words to a similar effect:-

Only upon the conclusion of (i) a comprehensive assessment of development needs beyond the plan period (ii) an evaluation of all reasonable alternative locations within settlements and beyond the outer edge of the Green Belt and (iii) full public consultation will changes be considered to the Green Belt boundary to meet longer-term development needs beyond 2028.

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

In a letter from the Lichfield Civic Society dated 26th February 2011 on the draft Core Strategy we sought a stronger commitment from the Council towards protection of the Green Belt in the following terms:-

"1.3 The Council has made an important and welcome move to substantially reduce the areas of Green Belt proposed for housing development. It would be a major step forward if the Council were to commit itself to no loss of Green Belt in the emerging Core Strategy. As we understand it this would only affect two sites i.e. the South of Lichfield Strategic Development Location and land in the Council's ownership between the A5 and the M6 toll adjoining Chasewater. The long-standing commitment of the District Council to retention of the Green Belt is highly commendable and ought to be continued. This would best be achieved by amending the Core Policy 1: The Spatial Strategy which refers to "The role of the Green Belt is recognised" to a firm unqualified commitment of the Council to retention of all Green Belt in the current plan period."

The revised text does go some way towards our submission although it is seriously weakened by the longer term release issue described above.

Q10. If you wish to participate at the examination in public, please outline why you consider this to be necessary.

Retention of the Green Belt is important for the character of the District and the setting of the City and we do not wish this to be compromised by inappropriate or unnecessary release of Green Belt status. The Society strongly supports the NPPF policy for keeping land permanently open to prevent urban sprawl. This applies equally to the longer term and given the inappropriately narrow focus of longer term review we would wish to participate in the examination in public unless the Council concede that they accept the change we have proposed.

John Thompson
Chairman,
Lichfield Civic Society.
September, 2012