The Staffordshire Structure Plan - 1986 to 2002

The Regional Director,
Department of the Environment,
Five Ways Tower,
Frederick Road,
B15 1SJ

Dear Sir,

Comments on the Staffordshire County Council Structure Plan 1986-2002 (Written Statement)

Lichfield Civic Society firmly believes that the City of Lichfield possesses a unique importance in the life of the County, the nation and indeed the world at large. The recent award from the European Community to local schemes sets a seal on this importance, centred as they are on the Cathedral and its presentation.

No less important is the context within such an outstanding structure is viewed. Lichfield is still a tightly defined entity, bounded by the A38 to the east, farmland to the north and Green Belt agricultural land to the west and south. The western approach is particularly dramatic when seen from the Walsall Road descent; fields reach almost to the heart of the City, especially when linked with land at Pipe Green, Leomansley, that reaches across to Beacon Park right to the historic core.

The Society believes that the asymmetric development of Lichfield is a crucial factor in its undoubted attraction and a prime element in its claims to uniqueness is that the historic core is not surrounded by a sea of houses. In the last 20 years development to the north and east have accentuated this imbalance excessively - in particular the Boley Park estate has created an overloading that imperils the character of the historic core of the City, quantitatively by its reduction when compared to the total mass of urban development and qualitatively by the intrusion of excessive traffic and intensity of popular use at this core.

This is already evident and will only be accentuated by the large scale developments to the west and south that are an inevitable outcome of the Structure Plan.

It is the Society's belief that such is the importance of Lichfield that it needs an appropriate (if general) policy that will protect it from opportunist development (perhaps under Section 5 'Environment Policies'), that asserts the status quo and that limits development to windfall and infill sites. It is felt that all future large scale development of Lichfield, wherever situated, will be ultimately completely destructive to its sense of place, its scale and to the intimacy that is currently found so attractive to its residents, potential residents, tourists and visitors alike. These characteristics should be actively protected by responsible and sensitive structure planning.

The Society feels that this is not the case with the Plan as it stands, rather that it opens the door to development that can only damage the character and quality of life of the City.

The Structure Plan is fundamentally flawed by being pre-emptive of alternative solutions, both generally and specifically. Firstly it is inconsistent as structure planning by being too explicit. For example, 72(d) lays down targets for office development and housing that can only be realistically satisfied by development of a specific site, i.e. the Walsall Road/Chesterfield Road area. This location can be arrived at by a process of elimination - the A38 is boundary to the east, the north is to be protected by an 'Area of Restraint' (73(a)), the south by a Green Belt barrier to the West Midlands Conurbation (69(b)). This being so, the Lichfield District Council is effectively denied any alternative siting of such development elsewhere in the district and this negates the essential freedom and flexibility of a District Council to formulate a Local Plan.

Housing needs must be catered for District-wide and options be left open in this context. Policy 72(d) pre-empts a dispassionate evaluation of need and removes viable alternatives to the global distribution of this office and housing development elsewhere in the District.

Policy 68 interacts with 72(d) removing from the Local Plan a choice of decanting the Lichfield western development into surrounding villages, or more suitably, to an entirely new village in a greenfield site. The Local Plan is therefore effectively hedged about to take one form only - that directly dictated by the Structure Plan.

Policy 68 also displays the Structure Plan's lack of even-handedness by the criteria it lays down for rural development. If these were to be applied to the Lichfield western area Interim Green Belt due for development, then Policy 72(d) would be disbarred ipso facto on its use of high grade agricultural land alone, regardless of the need to conserve a unique city. The Local Plan is thus prevented from exploring the possibilities of recent D.O.E. proposals in the paper "Housing in Rural Areas: Village Housing and New Villages" which could satisfy housing need, Green Belt protection and the interests of historic Lichfield with a single solution. As it is, the Structure Plan in Policy 72(d) runs against itself in Policy 78 and 79 and will lead to the destruction of local character and habitat rather than its conservation. The site is, after all, still an agricultural area and should be treated as such.

The pre-emption of the Local Plan is equally displayed in the Transportation section. It is hard to believe that Lichfield Southern By-pass has been included other than to make a traffic provision to service the western development and not to relieve existing traffic pressures. Previous studies rejected the notion of heavy vehicles making excessive use of St. John Street as a link to the Walsall Road - the Draft Structure Plan omits a Lichfield Southern By-pass. The Structure Plan introduces this notion in policy 54(a) but when seen in conjunction with the inevitable siting of office and housing in policy 72(d) it will be seen as integral to that policy rather than as a by-pass per se. In reality both these policies are profoundly intertwined - this is not demonstrated in the Structure Plan. Any southern by-pass must take into consideration its conjunction with the Tamworth Road (A51) at some point. This conjunction is unlikely to satisfy policy 48(c) due to the absence of an appropriate developer to offset he costs and this could remain incomplete. If so, the whole of the Lichfield Southern By-pass will function solely as a service road to the development, with unpredictable filter effects on existing highways and outlets.

Policy 58 makes no distinction between housing 'need' and housing 'demand'. Lichfield has a 'honeypot' effect that stimulates demand from the conurbations which is self justifying but soon self-defeating, acting as an engine for undesirable changes and over-development at the historic core. Housing should be restricted to internal need, generated within the existing population using infill and windfall sites instead of acting as a magnet to the demands emanating from the conurbations. There is an argument that to restrict demand development in Southern Staffordshire could turn demand back into the conurbation centres - there is no imperative on the Structure Plan to satisfy external demand at the expense of local need.

Policy 59 would appear to negate completely the whole of policy 72(d) and 54(a) (where it concerns Lichfield). The proposals will require maximum major services and facilities. This large scale development will be unrelated to the aims of urban regeneration; smaller scale alternatives could be available if they were made a component within a positive rural development policy instead of the Structure Plan predefining and constricting the Local Plan.

Policy 72(d) would seem to contradict policy 119 - an historic cricket field will be developed for housing without the assurance that a comparable facility can be conveniently sited elsewhere.

The Structure Plan therefore is deficient in a number of important ways. It lays down no policy regarding historic towns, their environment and surroundings. It pre-empts true and open alternatives for development of housing and offices in the Local Plan The procedures of presentation via the Draft Plan were suspect, being inexplicably vague on a number of important points rather than adhering to general principles, thus removing from objectors the right "to secure a real involvement of members of the public in the planning process by giving them an opportunity to make their views known and to have them considered at a stage before the authority have become committed to any specific solution of the planning problems of their area" (Structure Plans: The Examination in public, Department of the Environment - Section 1.15). This cannot truly be said of matters related to Lichfield.

These factors, seen in conjunction with the presentation sequence of the Lichfield Local Plan and the Written Statement, have pre-empted effective informed comment from the Lichfield Civic Society and in consequence we ask that the Staffordshire Structure Plan goes to Inquiry.

Yours faithfully,

Alan Thompson
Lichfield Civic Society
February 1989