Comments on Draft Developer Contributions SPD

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

Dear Sir/Madam,

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

a. the system is unduly complex and the overlap between the two systems of Community Infrastructure Levy and section 106 contributions is unclear, is not transparent and is not likely to be understood by local communities, despite claims to the contrary;

b. overall there is concern that the contributions being sought by Staffordshire County Council to education provision appear excessive in relation to other important elements of infrastructure, and that a more satisfactory balance is required; and

c. where is concern about the likely scale of the infrastructure funding gap in Lichfield District and whether the development proposals of the Local Plan can proceed in these circumstances where funding of supporting infrastructure is inadequate. The recent modification of CIL rates on SDAs recommended by the Examiner makes the funding gap even greater.

Yours faithfully

John Thompson
Lichfield Civic Society,
March 18th, 2016