Development Plans
Lichfield District Council
District Council House
Frog Lane
Lichfield.
WS13 6YZ

Community Infrastructure Levy Regulation 123 list
Comments of Lichfield Civic Society

Dear Sir/Madam,

General observations

Although the document states at the outset that the intention of the CIL List is to "avoid duplication with S.106 contributions, etc.", the details relating to many of the items of infrastructure present both CIL and S.106 as sources for funding. This seems to be neither helpful nor "avoiding duplication".

The List is extensive (and expensive) and is only likely to be funded in part by developers, particularly when the total requirements for contribution to the CIL fund for any site are aggregated. This, in turn, raises the question as to whether a development should proceed, or be granted planning permission, without the necessary basic infrastructure and associated funding in place.

The funding situation for essential infrastructure seems to be ineffective in securing adequate funding partly because of:-

1. The way the legislation is structured,
2. The nominal amount of CIL that the SDA sites will contribute and
3. Weaknesses or anomalies in policies adopted by the Council that relieve developers of costs.

This results in the costs falling upon the public purse or essential infrastructure not being provided. With these weaknesses developers may well find it easy to avoid or limit their overall contribution to addressing the needs. Two examples where policies and funding is inadequate are the Southern Bypass and health facilities as mentioned below.

Transport and Lichfield Southern Bypass

Regarding the detailed items in the List, the Lichfield Southern Bypass has three sources of funding quoted (i.e. future developers, existing S.106 monies and "possible Local Growth Fund". This is but one vital item of infrastructure in the District where uncertainty exists as to funding, although the same point could be made on many other items on the List.

On the Lichfield Southern Bypass, the IDP is unclear, or of doubtful content, where it states that the South Lichfield SDA does not require completion of the Bypass. This may well be the current policy (unfortunately) of LDC and SCC for what was the initial element (the so- called St John's site), but once the developments at Cricket Lane and Deanslade are included, the requirement for prior completion is fundamental. This matter should be addressed in policy terms.

Health facilities

Page 10 of the regulation 123 consultation document states:-

"Other Infrastructure - Health facilities"

"Infrastructure to be funded in whole or in part by CIL funds may be used where evidence is provided that there is no local capacity and expansion of services is required to support growth across the district".

"Other Infrastructure - Notes"

S106 agreements will be required for the Strategic Development Allocations (SDAs) to secure the provision of health care as identified in the Local Plan Strategy concept statements."

In the adopted Local Plan, apart from Fradley, none of the Strategic Development Allocations (SDAs) sites in Burntwood, East of Rugeley, Lichfield or Streethay have any reference to health care provision.

Concerning Fradley in Policy 'Frad2: Fradley Services & Facilities' it is stated in paragraph 17.10:-

"Existing Fradley residents access health care facilities in either Alrewas or Lichfield, some of which are at capacity. A new health care facility will therefore be required alongside any new residential development at Fradley. A location close to the existing neighbourhood centre (Stirling Centre) is favoured due to convenience and ability to allow the community to combine trips. There are opportunities within the Stirling Centre for a small facility. However, land will be safeguarded within development proposals to facilitate the construction of a new purpose-built health centre to meet local need."

However, when you look at the Concept statement of the SDA allocation under Concept Rationale E.2 paragraph 6, it states:-

Improve the scope of services available at the existing Stirling Centre. Opportunities for library provision and health facilities will be encouraged, as well as a range of A1 and A3 uses.

So, there is significant inconsistency between being "required" as a Local Plan Policy and being "encouraged" in the Concept Statement.

Concerning Health Centres and doctor's surgeries the latest version of the August 2015 version of the Infrastructure Delivery Plan includes the following comments:-

  • The PCT identified the need for new/additional provision in Burntwood, there is currently commitment to deliver one new health centre. The IDP will be updated when further information becomes available;

  • In terms of Fradley, the PCT advised that there is currently no provision within Fradley itself, with residents using facilities at Alrewas and Lichfield. There is some limited additional capacity at Lichfield. In the longer term, however the District Council would wish to see some services delivered in the village itself, either in a bespoke unit (in 2010 the PCT indicated that a 2 GP surgery would cost in the region of 350,000) or as outreach provision;

  • In terms of the key rural settlements, there may be future capacity issues at Fazeley, but this will need to be clarified at the Land Allocations stage of the Local Plan.

Our view is that the need for additional capacity in Lichfield is likely to arise following completion of the SDA's and other allocated or windfall sites in the City and Streethay. The low level of CIL contributions of the SDA sites towards delivery of infrastructure indicates that Lichfield City will in due course be in the same position as Burntwood with a real and belated recognition of the need for additional health provision. Little, if any, monies for health facilities will be available from CIL because of all the other categories of funding needs identified in the IDP and regulation 123 list. The omission of reference to health facilities in the Burntwood SDA Local Plan allocation appears to be an unfortunate oversight.

The established need in Burntwood and the excessively long period that it has been unresolved indicates the Council should be addressing this and the looming Lichfield situation as a priority.

Yours faithfully,

John Thompson
Chairman,
Lichfield Civic Society,
9th November, 2016