Draft Statement of Community Involvement

Spatial Policy & Delivery Team
Development Plans
Lichfield District Council
District Council House
Frog Lane
WS13 6YZ

Comments on draft Statement of Community Involvement

Dear Sir/Madam,

We have considered the draft consultation document and make the following comments:

1. Introduction

The draft is an updated and simplified version of the current Statement of Community Involvement (SCI) that was formally adopted in April 2006. It has reduced from 52 pages to 38. The main changes and omissions are that it no longer includes:

  1. a summary of the processes related to the adoption of a Local Plan;
  2. a section on how the Council intends to improve the service;
  3. a list of bodies who are the statutory and non-statutory consultees.

One of the opening statements is:

"1.5 The SCI recognises the valuable contribution of community involvement in the planning process and that by engaging with our customers we can help deliver better quality development which meets their needs and those of future generations. In addition, our customers will be better informed and this may reduce the number of enquiries generated."

2. Consultation on major housing developments granted outline permission

There is a particularly significant omission which is inconsistent with that statement in paragraph 1.5 relating to the following paragraph which is in the current SCI:

"On major housing developments where outline permission is granted the Council will encourage the establishment of appropriate consultation and liaison arrangements with developers and representatives from resident's associations/neighbours. This will enable ongoing consultation and communication on issues such as detailed proposals, changes in phasing, delays in implementation of infrastructure, community facilities etc." (Paragraph 8.20 - Consultation on major housing developments granted outline permission)

This paragraph was added in following representations of the Leomansley Area Residents Association (LARA) to the original consultation draft and was recommended by the Inspector who examined the document and approved it for adoption. The LARA representation arose from experiences on the Walsall Road/Darwin Park development. Problems over delivery of infra-structure, development phasing, provision of play areas and equipment, delays in highway and sewer adoption, adoption of public open space, lack of street lighting etc. which were adversely affecting new occupiers of houses within the site and local residents which led to LARA holding meetings with the developer's staff and architect. These proved productive and subsequently District Council officers and then local members District and County were involved. County highway and public transport officers were also involved on particular issues. Our view is that the commitment to "help deliver better quality development which meets their needs and those of future generations" should include encouraging developers to set up consultation and liaison arrangements with representatives from resident's associations/neighbours. If the developer manages the development and provision of infrastructure well, then the need for these arrangements to operate to resolve problems and communicate what is changes are planned will diminish.

Our view is that the policy commitment in paragraph 8.20 should continue to be part of the SCI to encourage developers of major sites, such as the SDAs, to establish appropriate consultation and liaison arrangements. This commitment could be incorporated in the section of section 6 with the sub-heading "How do we involve our customers after a decision is taken on a planning application?" The forum for these arrangements could be agreed on a case by case basis with the developer. Previously it has suited those involved for meetings with residents' representatives and Council members to held after planning officer progress meetings with the developer so as to minimise the time required from those involved.

3. Neighbour consultation

There are several references in part 6 on major and minor applications that the Council will "Write to all neighbours who adjoin the site of the proposal." The current SCI says "Write to all neighbours who are likely to be affected by the proposal." On the Council's website, under 'Planning Guildance', Step 3 says "We will write to nearby residents and/or put up notices around your development site." Given the different descriptions used for neighbour consultation the question is what are the Council's policy guidelines used in practice. There has been a case where a development of 70 plus houses where the neighbours of properties on the opposite side of the road were not notified although they are affected by the proposal. Is the revised wording intended to resolve this issue? There is a need to clarify and make public whether the criteria being used is whether it 'adjoins' or if it is 'likely to be affected by'. This could be achieved by publishing the guidelines being used on the Council's website and including a reference to them in the SCI.

For major and minor developments, it states "Consult with statutory and non-statutory consultees online". As a non-statutory consultee we do not get routinely consulted on all developments so is this statement correct? Incidentally, we are not seeking to be notified of all developments.

Yours faithfully,

John Thompson
Lichfield Civic Society,
March 10th, 2016