Research by and the submission of the Lichfield Alliance indicates that this duty has not been fully discharged in relation to both neighbouring local authorities and those in the wider West Midlands Conurbation on housing issues and migration in particular. Given the avowed aim of the West Midlands local authorities to pursue a policy of "urban renaissance" and hence limit out migration, cooperation as to the implications of such a policy on Lichfield District is central to any policy development. We consider this to be a key issue that needs resolving.

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

In addition to the reasons in Q1a there is the question whether the Sustainability Appraisal report meets the legal requirements as detailed in the Lichfield Alliance.

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

We support the issues raised by the Lichfield Alliance on this matter. In particular, development requirements, as set out in the proposed Strategy have not been objectively assessed because the basis upon which the assessment of options took place was unsound. In particular, assumptions about in migration do not reflect the policies of the assumed "exporting" local authorities.

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

In addition to the concerns raised by the Lichfield Alliance we set out following reasons.

The Civic Society has consistently in recent years been concerned about the prospect of large scale additional housing in the District and a disproportionate proportion of the District's needs being allocated to the City. The consequences and impact of the Darwin Park (Walsall Road) new housing development allocated in the 1998 Local Plan for 650 homes but given permission for over 1,100 properties has in relation to transport infra-structure and pressure on local services has been significant and heightened our concerns about further large scale housing in the City. We submitted in December 2008 to the West Midlands Regional Spatial Strategy review a paper and gave evidence in support at the Examination in August 2009. Our case that consideration should be given to a strategy for growth north of Lichfield at Fradley was accepted by the Panel and included in the final report. Our submission and an extract of the Panel report relating to Lichfield are reproduced below.

The basis of the scale of needs for development 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".

In our submission on the draft Core Strategy in February 2011 we reviewed the housing forecast projections and concluded that a figure of 6,000 remained the most appropriate for the District. Since then a jointly commissioned work of Nathaniel Lichfield & Partners to evaluate 'Future Population, Household Projections and Housing Needs has added to the evidence base. The District Council have used that as the basis for the target in the Strategy.

We remain convinced the target is too high. There appears to be insufficient consideration of "regional" and "sub-regional" issues to facilitate the RSS policies on "urban renaissance" which should be leading to less provision for outward movement from conurbation authorities into shire districts like Lichfield. The decline in housing completions in the District during the last few years further supports the argument. There has been a large shortfall in housing completions over the last 4 years (to March 2012) of 800+ compared with annual rate needed to achieve 8,700 (i.e. 435 per annum). In the 4 years only 892 were delivered (annual average of 223) or close to half the rate required to achieve the target. In the earlier period, from 2006-2010, an average of only 312 units was completed, which falls well short of the Plan's proposed 435 per annum. The downward trend justify an argument for a target closer to 6,000 than 8,700.

We are aware of the work done by the Lichfield Alliance and the submissions it is making. We support those submissions. We believe that those submissions raise important challenges to the statistical methodology, underlying assumptions about migration, recovery of the economy, deliverability and viability. These issues and the extent to which the Council has fully met the Duty to Co-operate and Sustainability Appraisal obligations raise important questions about the processes and conclusions reached by the Council.

We also consider that the Council in exercising its decision making on housing targets should have given greater weight to the exceptionally high volume of concerns expressed by the public in the responses to the draft Core Strategy about the then 8,000 housing target being too high. Housing numbers used by the Council how reliable are they? There is no discussion or policy statement about the use of phasing to control densities within developments to prevent the Darwin Park approach of allowing high densities in the initial phases thus enabling on the remaining areas substantially more additional housing to be built over and above the allocated and approved planning consent number. The Darwin Park experience throws considerable doubt upon the reliability of numbers used by the Council for site allocations. On Darwin Park the Council deliberately took no steps to control the numbers resulting in an increase of 72% being built compared with the Local Plan allocation. Such an enormous difference in the projections of housing numbers and allocation on sites and the actually number delivered raises questions as to whether the existing range of numbers particularly on the Strategic Development Allocations are understated. Darwin Park was allocated in the Lichfield Local Plan for 650 houses. The number approved is 1,122 which is an increase of 72.6% over the site allocation. If an increased figure of say 70% is applied to the Strategic Development Allocations then the higher figure total for these sites of 3,700 increases to 6,290. Even if only 25% were applied, it represents an increase of over 925 dwellings. That additional number is sufficient to enable several of the contentious Strategic Development Allocations to be dropped. The Council gave evidence at the Lichfield Local Plan Public Inquiry in 1998 that the area allocated for housing for the Darwin Park site was not excessive and when later asked to use powers to control the density of phases within the development declined to do so. This inevitably leads to serious concerns that the range of figures now being put forward cannot be relied upon and could well be substantially exceeded. It is important to recall that the permission for Darwin Park was given before PPG3 was modified and there was therefore no power to require or obligation to permit higher densities than originally approved.

The Core Strategy ought to clearly indicate that the site specific allocations are a maximum that will be permitted and include a policy commitment that powers will be used to control densities on the phases of development to ensure the overall allocations on individual sites are not exceeded. The Lichfield Civic Society submission in December 2008 to West Midlands Regional Spatial Strategy Phase Two Revision on Policy CF3 Level and Distribution of New Housing Development "The Society are concerned at the number of houses (8,000) proposed for Lichfield District in this Policy. At the same time it is noted that within the additional housing growth scenarios contained in the Nathaniel Lichfield Partnership (NLP) Study Report there are no proposals to amend this figure within any of the alternatives.

The Society's concern relates to the impact of the high cumulative level of housing proposed, particularly bearing in mind the number of housing units (2320) already built in the immediately preceding period (2001-2005), and the environmental character and limited size and capacity of the settlements within the District to absorb continuing high rates of housing development. The cumulative total for the 25-year period (2001-2026), if this 8,000 figure were to be accepted, would be approaching 11,000 which equates almost exactly with the Option Two figure of 11,000 put forward in the Spatial Options Document and objected to by the Society. The basis of the Society's objection remains consistent, and will be expanded in the remainder of this representation.

The situation in Lichfield District has now reached the point where such high housing numbers are neither practicable nor deliverable without creating great harm to the character and environment of the District. There are only two modest sized "urban" settlements in the District, namely Lichfield City and Burntwood, and they have reached the point where further significant housing expansion would be unacceptable. Over half the area of the District is within designated Green Belt, and this includes both settlements of Lichfield City and Burntwood. Over the last 5 years or so housing development and redevelopment has been at an exceptionally fast rate because of a set of unique circumstances which now no longer exist and, therefore, a more "normal" rate should be accepted. Edge of town greenfield releases following the adoption of the Local Plan, with large increases in densities on these sites, and intensification of development within existing settlements, principally providing additional housing on former employment land and other areas of land, has now diminished urban capacity for future development to a very great extent. Urban extensions to Lichfield City and Burntwood would furthermore undermine the function of the Green Belt. At the same time the housing/employment balance of the two main settlements has deteriorated further, with a loss of local employment and the increase in housing, with a commensurate increase in out-commuting to find employment. With the decrease in suitable "infill" capacity, and if the housing proposals remain at 8,000 houses, the environment and character of the settlements will be severely affected through further intensification and "town-cramming".

The other alternative would be for further greenfield sites on the outer edge of the settlements, and this would also place further pressures on the physical and social infrastructure (not least social and community facilities, highways and drainage) and impact adversely on the character and environment, particularly of Lichfield City. It is the view of the Society that the housing need figure of 6,000 (RSS Housing Background Paper Final Version (Amended) (Jan 2008, WMRA) is a more appropriate and justified basis for the housing proposal figure for Lichfield District than the current proposal, and the Policy should be amended accordingly. Bearing in mind the unique reasons for the most recent development rates and the environment and historic character of the District, particularly the City, as referred to earlier, this figure based on need is realistic and balanced. This figure of 6,000, whilst requiring annual provision of 300 houses for the Plan period, which remains a not insubstantial figure, should be achievable across the District subject to the following proviso. However, for the various reasons outlined earlier in this representation concerning the environment, historic character and lack of urban capacity in the main settlements, this figure will require a significant proportion of the allocation to be made other than in Lichfield City, Burntwood or the smaller key settlements. It has long been the policy view of the Society that the most appropriate and effective strategy for addressing housing growth in the District would be to promote Fradley as a significant growth point.

The idea of a "new / extended settlement" at Fradley emerged in previous development planning documents, including the Staffordshire Structure Plan and the Lichfield District Plan, and this proposal should again be pursued by including supporting reference in the Approved RSS. Please note, however, the Fradley proposal is different in location to the Curborough proposal, being in a location more effectively separated from the edge of Lichfield City, but also very close to the substantial existing and developing employment area at Fradley. At present the existing level of housing development at Fradley is inadequate to sustain and support a full range of community services and the approach proposed here would help to overcome this situation. Additionally, Fradley lies beyond the outer edge of the Green Belt, and, therefore, further significant development would not impact on Green Belt policy.

Infrastructure and Phasing

There are two other points of concern to the Society and these relate to more detailed matters of implementation of housing development:
(a) provision of infrastructure, and
(b) phasing of development.

(a) Provision of Infrastructure

Policy SR2 Creating Sustainable Settlements refers at D, E, F and G in particular to the requirements for a wide range of infrastructure being provided and available as part of any development. This is necessary and vital if sustainable communities and settlements where people wish to live are to be successful. It is, therefore, imperative that at the local level this principle is followed, i.e. the prior, or properly in phase, provision of all necessary physical and social infrastructure before housing development takes place. This is of particular concern to the Society because recent experience at Lichfield in relation to the Walsall road development has been the failure of provision facilities, including community facilities and recreation and open space provision to be made in a timely and appropriate manner. The requirement to provide infrastructure and facilities through legally binding Planning Obligations and Agreements under Section 106 accompanying the relevant planning consents should be emphasised in the RSS when approved.

(b) Phasing of Development

Although policy is included in the submitted WMRSS Phase 2 Two Revision to deal with Phasing, i.e. Policy CF4 - Phasing of new development and Policy CF10 - Managing housing land supply, the Society is concerned at previous experience in Lichfield District. Once the Local Plan had been adopted the majority of housing allocations were implemented and phasing through the plan period appeared absent. In future the Policy should ensure that, when an LDF is adopted, effective control mechanisms are in place to ensure rates of grant of planning permissions and, therefore, build, are spread throughout the plan period. The RSS should emphasise this approach more strongly."

An extract from Regional Spatial Strategy Report of the Panel of the West Midlands Regional Spatial Strategy Phase Two Revision regarding Lichfield in September 2009:-

"2.74 The position at Lichfield is more complex in so far as the most recently approved Staffordshire and Stoke Structure Plan endorsed a new settlement proposal on Fradley Airfield to the North East of the City of Lichfield and this proposal still has significant local support from Lichfield Civic Society as the most appropriate means of meeting the long-term development needs of the locality. The proposals from the Curborough Consortium that were current at the time of the EiP are not the same as those previously endorsed at Fradley but relate to land mainly to the west of the airfield, i.e. to the north-west of the City rather than to the north-east adjacent to the A38 and rail line between Lichfield and Burton on Trent as previously considered. A further complication is proposals put forward for an urban extension at Streethay at the north-east corner of the City adjoining Lichfield Trent Valley rail station. Our conclusion in Chapter 8 and recommendation R3.1 for changes to Policy CF3:Table 1 would mean that there would be a proper context in which to consider the optimum urban form for long-term development to the north of the Lichfield, be that an urban extension, a new settlement or a combination thereof appropriately linked to the strategic transport network. We see no reason for the RSS to pre-empt decisions that can properly be taken in the context of the Core Strategy DPD with the higher ceiling we propose and the rider that development could extend beyond the plan period enabling proper long-term consideration. Consequently even in the Lichfield locality we see no reason for the RSS explicitly to endorse or deny a new settlement solution. However, on the basis that with our recommended changes the RSS would be open to new settlement proposals should they emerge as sustainable options through the LDD process, we would expect the behaviour of WMRA over RSS conformity to maintain a similarly open mind."

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

Can the Strategy be delivered in the Plan period? In particular, can the housing element be delivered? The Society believes that whilst delivery may be achievable, unfortunately it would be at the cost of weakening attempts by the West Midlands authorities to slow the rate of out migration, of creating more sustainable communities and reclaiming brownfield sites. The Strategy represents an undermining of the carefully developed urban renaissance strategy of the West Midlands local authorities.

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

The National Policy Framework seeks to ensure that local authority strategies have due regard to the needs of other authorities and hence complement each other, whilst being sustainable. The Council Strategy runs counter to National Policy by undermining local authorities' adopted policies in the West Midlands conurbation, which seek to retain a greater element of their residents together with new household formation, in their local area. There is no evidence that the Council has undertaken detailed discussions with these local authorities and assessed the information provided. In addition, assessment of housing development options in the District appears to have been based on an analysis of sites submitted by interested parties (i.e. developer led). At no time was a comprehensive assessment made of the strategic options (i.e. peripheral expansion versus a new settlement option at Fradley). That is, alternative options were not objectively assessed.

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

A significant reduction in the current target of 8,700 to circa 6,000. We believe this can be achieved by moderating the scale of allowance for out migration from the conurbation authorities.

A policy statement that the release of allocated will be dependent upon robust requirements for the provision of infra-structure. A commitment to review of the housing targets dependent upon the rate of development and to phase the release of sites.

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

The concerns regarding housing targets, reliability of site capacity assumptions and more effective control over phasing were raised in a letter from the Lichfield Civic Society dated 26th February 2011 on the draft Core Strategy. As indicated in this representation we have also raised housing targets and reducing pressures on the Green Belt by development in Fradley through the RSS process.

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

The housing targets and the implications for release of land for the Strategic Development Allocations and permanence of the Green Belt are some of the most contentious issues in the Strategy.

Our charitable objects include promoting high standards of planning and architecture in the District and we would wish to participate in an examination of this topic and the associated issues.

John Thompson
Chairman,
Lichfield Civic Society.
September, 2012