Introduction

1. Lichfield Civic Society is principally concerned, as one would expect, with the manner in which the Plan impinges on the future of the City and its hinterland. It recognizes, however, that this future is inextricably related to that of much of South Staffordshire and in particular the remainder of Lichfield District, Tamworth and Burton-on-Trent. The Society's approach to the review of the Structure Plan is not a parochial one in that there is clearly a complementary relationship in terms of housing, employment, transportation, shopping, entertainment and tourism between the principal centres. It will consider therefore the contents of the Review in this wider context.

2. The starting point for the Civic Society's observations is its comments on the County Council's Discussion Paper and background document "Towards A New Strategy" which were sent to the Council on 30th October 1995. In those comments, the Society expressed its concern about future growth in the City and advocated the idea of a new settlement as a means of minimizing the incremental expansion of the existing towns and villages. It suggested that further investigation of Fradley as a suitable location should take place as part of the Review. The Society also drew attention to the need to remedy the absence of specific policies to safeguard the historic character of the City and the villages, houses and gardens within the County. Other issues raised were those relating to the scale of housing provision, the need to provide affordable homes and smaller units of accommodation, the environmental capacity of the District and the adequacy of the transportation network with particular reference to the A38 and the Cross-City railway line as well as the potential of the Lichfield-Walsall rail line.

3. The Civic Society is pleased that all these matters have been addressed in the current Review document It would be presumptuous to infer that the Society's earlier comments might have had some bearing on fashioning the shape of the Review but it is to be welcomed that its contribution appears to have been taken seriously.

The Plan Document - The Uncertainties

4. The Review document is clearly written, organised and presented. The analysis of the strategy and the individual policies is reasonably thorough and understandable. The report is refreshingly honest about the environmental impact of the strategy and the proposals ("Environmental Appraisal" section) and about the uncertainties relating to the extent to which the plan is able to fulfil its objectives bearing in mind the availability - or rather lack - of public finance, the dependence on unpredictable private sector investment and the "hit and miss" outcomes of the bidding process for European and lottery funds etc. These uncertainties are compounded by the lack of clear decisions on housing, transportation and waste disposal strategies which are the realms of Government and other agencies and therefore outside the control of the County Council. The Civic Society acknowledges these difficulties and the constraints which they impose on the Council in producing its Structure Plan and in that respect it attracts the Society's sympathy. It has less sympathy with the proposals to appoint consultants at this late stage to carry out further studies of the major proposals for housing and employment at Rugeley and Tamworth. Such studies should have been undertaken before the publication of the Review and their results incorporated into it. At the moment, it is difficult to make any comprehensive assessment and environmental appraisal of these major proposals.

5. Notwithstanding these reservations, the Civic Society broadly supports the Strategy. Its anxieties stem to a large extent from what the Plan is unable to say about those matters, as indicated above, which might engender confidence in the ability to implement effectively the policies and proposals to secure its worthy aims. The ability to put in place mechanisms to ensure an adequate provision of low cost and social housing is a prime example of this. Will the unfulfilled demand for such housing remain a legacy of the Plan?

The Strategy - Meeting the Housing Need

6. The Civic Society welcomes the basic principles of the Plan which are sustainability, balanced growth of jobs and houses to reduce commuting, the protection and enhancement of the environment and the protection of the green belt "as far as possible". It is acknowledged that there may well be conflicts in the pursuit of these principles such as reconciling the concept of sustainability with the maintenance of the green belt in its present form. The Society also supports the concept of corridor development based on the sequential test of seeking to develop land in settlements of diminishing size from the major urban areas, through free standing small towns and to the larger villages before looking towards incursion onto greenfield sites on any scale. The emphasis on maximising the use of brownfield sites is endorsed but the Society is sceptical about attempting to set targets - 50 per cent or 60 per cent - for the development of such sites. These targets may give rise to misleading expectations in the light of the realities of the difficulties of the release of land from owners, of the costs of reclamation, of generating demand for the use of these sites and also of the scale of their existence in locations where they would most readily attract investment. The Civic Society agrees with the conclusions in the Review that in South Staffordshire most of the development will have to take place on greenfield sites, bringing in its train a significant effect on the rural landscape.

7. This impact on the environment invariably raises the question "Do we need all these houses?" In its observations of October 1995, the Society stated that "The Structure Plan Review" will be expected to provide a full and clearly understandable justification of the level of housing provision. In a way such justification is easy to make in that the requirements of Regional Planning Guidance RPG11 can be invoked. The Civic Society however, has had the benefit of considering the County Council's "Draft Housing Technical Paper - December 1997". This is an extremely helpful and thorough document. There does not appear to be any reason to dispute its conclusions. No doubt it is possible to argue about some of the assumptions e.g. migration levels, but at the end of the day those arguments are unlikely to materially alter the scale and pattern of the need which is at its highest level in South West and South East Staffordshire. What is interesting in the Working Paper (Table 6: Comparison of Projected Housing Need and Draft Structure Plan Housing Proposals) is that the Review is making a conscious decision to shift the balance of provision to the north of the County, where that provision exceeds the projected housing need away from the south, notably south east Staffordshire, where the number of houses proposed is significantly less than the projected housing need. There is no clear explanation of this decision. Presumably its origins are on the one hand in the need to give confidence and momentum to a revitalized Stoke-on-Trent area and on the other in the need to recognise the limitations of the environmental and infrastructure capacity of the south of the County. This will no doubt be a source of some debate at a forthcoming Examination in Public. It would appear to be in the interests of the Society to support the Council's stance.

8. The Society, as referred to above, is concerned about the issue of the need for and provision of affordable, especially social housing. On this matter the Draft Housing Technical Paper (paras. 2.16 - 2.21) makes sombre reading. The intention of the Review within the broad parameters of Policy H1 is to leave it "to the District Councils as both local planning and housing authorities to determine the requirements for new social and affordable housing provision in their areas, relevant to local circumstances". This seems to be a sensible, practical conclusion. Some District Councils area already carrying out their own surveys. In Lichfield District consultants have recently estimated that at least 1,150 affordable houses are needed over the next five years to cope with anticipated demand. This may be aggravated by an influx of people moving from outside the area, notably the West Midlands. In para. 7.38 of the Review it is stated "It has been estimated that nearly 70% of the social housing requirement in the region arises in the metropolitan districts. Such a requirement takes up nearly all of the housing provision in the conurbation. However, the PRIORITY in the West Midlands Conurbation is to build market housing to assist in urban regeneration measures. Therefore, part of the migration from the metropolitan area is assumed to be taken up by affordable and social housing overspill". The Civic Society poses the questions "Why does the urban regeneration have to be based on, presumably expensive, market housing?" "Is the priority one of promoting prestige and economic prosperity at the cost of meeting social obligations?" "Has this priority been challenged when its implications are far reaching for authorities outside the conurbation?"

The Civic Society is reminded of the comments of the Director of Planning to the District Council in his report "Review of Regional Planning Guidance Housing Provision - Report of the West Midlands Forum Steering Group" dated 12 November 1996". "There is the social question of the soundness of a policy which will require migration from the conurbation of those types of households which are most in need of support and their possible dispersal from the existing sources of that support in particular social and community networks within the conurbation". It is inevitable that there will be those migrating from the conurbation who will require affordable housing but has sufficient been done in their places of origin to minimize the outflow? Will their destinations at Fradley or Tamworth, at some distance from those places of origin, enhance their social, economic and community isolation? This is a worrying aspect of the Review although it is acceded that within the constraints of PPG11 there seems to be little more that can be done to ameliorate those worries.

The Distribution of Growth

9. The Civic Society notes from Table 2 "Summary of Housing Provision by Local Authority Area in the Review" that the total provision for dwellings 1996-2011 is 7,600 in Lichfield District. The number of dwellings committed is 2,838 leaving a balance of 4,762 for which sites have to be found. Of this balance, it is expected that 1,250 will be found. Of this balance, it is expected that 1,250 will be found through windfall sites. Much of the remainder is proposed to be provided at Fradley (2,000) and west of Tamworth (1,000). There is a further site, not included within the provision for Lichfield District, for 1,000 dwellings at Rugeley which has not been attributed to any District.

10. There is provision in Lichfield District for 230 ha of employment land in the plan period, of which 180 ha is already committed, the remaining 50 ha to be located provisionally to the west of Tamworth.

11. LICHFIELD. The Civic Society welcomes the acknowledgement that the circumstances of Lichfield warrant special consideration and that physical and environmental constraints limit its development capacity. The Society's concerns about the further growth of the City are set out in its observations of October 1995. It is assumed that there will be no significant allocations of land for housing proposed other than those contained in the Lichfield Local Plan for the period to 2001 together with the additional post 2001 development at Walsall Road (250 dwellings) and land at Berryfields Farm which has been removed from the Green Belt and has the status of an Area of Development Restraint (400 dwellings). The latter location is controversial and a final decision on its future has to be made as part of the review of the Local Plan but the Society despite its own reservations, is convinced that it will be developed in the future. The proposals for Lichfield in the Review are therefore fully supported.

12. FRADLEY. The Civic Society recognises that but for its special character, Lichfield would be a natural and attractive location for further housing and employment growth. A decision to limit development in the City means that an alternate location or locations would have to be found to accommodate that growth which might otherwise have gone to Lichfield. The proposal to establish a new settlement at Fradley has the endorsement of the Civic Society. That this should be so is not without misgivings because it is inevitable that the village and its surroundings will be transformed and much of the rural character of the area disturbed. Nevertheless, Fradley is a logical location for major development in the District. It is on the outer edge of the Green Belt; it contains a large committed employment site; it is adjacent to a major road corridor, the A38, and there is a potential for a passenger rail link to Burton and Lichfield.

13. Any reservations which the Civic Society has about the proposals relate to the reconciliation of the further development at Fradley with the concept of sustainability. Paragraph 4.34 of the Review admits that small to medium-sized new settlements do not represent "a wholly sustainable form of development".

Fradley with a further 2,000 dwellings in the Plan Period and an additional 1,000 beyond 2011 falls within that category. There is an acknowledgement that many services and facilities would still have to be provided in Lichfield. This will inevitably generate significant traffic movements to and from Lichfield and beyond and this will place great pressure on the local road network. Proposals to carry out improvements to the A38 in accordance with Policy T11(b) may well conflict with the Policy T1(a) to reduce the need to travel by non-sustainable modes. It is crucial therefore that the development of the public transport infrastructure between Fradley and Lichfield and further afield should take place hand in hand with the growth of the new settlement and should not await a particular population threshold. Urgent attention should be given to re-introducing passenger rail services on the Burton-Lichfield line with further connections to Walsall, Dudley and Stourbridge.

14. Progress towards a much more substantial measure of self sufficiency and less dependence on Lichfield will require high levels of investment in such facilities as shops, offices, schools, community centres etc. They will not be cheap but provision needs to be made for them at an early planning stage even if that simply means reserving land for them in the future. It is imperative that Fradley should not suffer the same fate as Burntwood area in the 50's, 60's and 70's when it absorbed a large number of houses without the essential support facilities, an omission which has had to be remedied with difficulty over the last decade. There is a need for a "Development Package" for Fradley but what should be its horizon? The fundamental issue is whether or not the scale of development proposed at Fradley is actually large enough to attract the necessary investment to enable it at any time to achieve a substantial measure of self-sufficiency. The larger it is, the greater the chance of success. The visionary time scale needs to be extended to acknowledge that once established Fradley will continue to grow and that eventuality must be planned for now.

15. TAMWORTH. The Civic Society has no objections to the provision of 1,000 houses and 50 ha of employment land at Tamworth. It is not sure how the 50 ha was arrived at but presumably the figure represents a critical mass providing a site of sufficient size to accommodate a range of business types and sizes. Although it is noted that the employment allocation is principally designed to serve the new housing (6.15) it is almost certain to have a much wider significance.

16. The Civic Society notes the reasons for the selection of a site on the west side of Tamworth (7.23) but would like to have more information on the boundaries of the land involved and how it performs compared to alternative locations.

17. RUGELEY. The Civic Society has no objections to the provision of a further 1,000 dwellings at Rugeley. The concern is that, given the serious constraints confronting the provision of a major development site to the south west and north east of the town (page 54), failure to identify a suitable site in that area would mean that alternative locations for housing would have to be found. This could well have implications for the rest of Lichfield District. It would also be interesting to know what will be the effect on the A51 of major housing and employment schemes at both Rugeley and Tamworth.

18. RURAL SETTLEMENTS. The Civic Society welcomes the provisions of Policy H9 Rural Settlements. It is extremely important that villages should be maintained as healthy and viable communities, keeping their shops and, where possible, schools. In the past, restrictive planning policies may have had a reverse effect. The Society acknowledges that priority should be given to local housing needs but to limit any development exclusively to this category of occupier may well inhibit the achievement of the aims of the policy to maintain and generate new life into the community. Similarly, confining development to within existing village boundaries - especially if those boundaries are drawn very tightly - may prevent the development for small schemes of otherwise suitable sites adjacent to the boundary.

19. TRANSPORT & ACCESSIBILITY. The Civic Society fully supports the policies in this section of the Plan. It has comments to make on two policies:-

i) T15 Major Highway Proposals. The Civic Society would wish to see Lichfield Southern By-pass, currently under review, confirmed as a scheme to proceed during the early part of the Plan Period. Although there is local opposition to the proposal, the by-pass will bring both traffic and environmental benefits to the south and centre of the City.

ii) T16 Car Parking. The Society endorses the contents of Policy T16 but considers that it would be unrealistic and unreasonable to widely impose a regional car parking policy which sets parking levels and charges. It may have advantages for competing large centres but, in the case of smaller towns, local authorities should have sufficient flexibility to provide and manage their car parking to reflect local circumstances such as the economic viability of the centre, the level of provision of alternative modes of transport etc., within the overall context of seeking a reduction in the demand for travel by car.

20. NATURAL & CULTURAL ASSETS. The Civic Society supports the policies and proposals set out in this section of the Plan, especially Policies NC 10-15. It particularly endorses NC15 with its presumption in favour of retaining and enhancing "open spaces and views through, into and out of the areas which contribute to their special character or interest". This is pertinent to Lichfield where the open spaces are so important yet vulnerable to pressures for development, especially car parking.

21. RECREATION, LEISURE & CULTURE. While supporting Policy R7 Canal Facilities, the Society is disappointed at the absence of a policy safeguarding the routes of disused canals as recreation and wildlife corridors and positively encouraging wherever possible the restoration of those canals to the status of navigable waterways.

22. WASTE DISPOSAL. The Civic Society, although not objecting to the relevant policies in the Plan, is nevertheless concerned that the chapter on waste disposal is somewhat lacking in substance. This is an important strategic activity. It consumes large areas of land and involves significant levels of cross boundary movements. It is evident that, despite what is achieved by incineration, recycling etc., there remains an overwhelming dependence on land fill. The Plan should provide some information on the life expectancy of the current disposal sites and on future commitments. Will there be sufficient capacity to meet the needs generated throughout the Plan Period? If not, are there any proposals in mind to remedy the deficiency? This is an issue of particular interest to the Civic Society because, in the recent past, it has had occasion to object to an "overland" tip proposed in the vicinity of Fradley. It appreciates that the Environment Agency has now assumed a large measure of responsibility for waste disposal and that there is in existence a Draft Waste Management Plan prepared by the County Council, but the Society considers that the more widely publicised and read Structure Plan should provide a more expansive statement on the current and anticipated situations in advance of the Waste Local Plan which the Council is obliged to prepare. It also raises the question as to whether or not Policy WM5 provides an adequate context for that Local Plan.

Conclusions

23. It will be apparent from the foregoing that the strategy, policies and proposals contained in the Review command a substantial measure of support from the Civic Society. It particularly welcomes the stance taken by the County Council to safeguard the historic and environmental character of Lichfield City. It also endorses the proposals for a new settlement at Fradley, provided that the necessary infrastructure is put in place hand in hand with the development growth. It also considers that the County Council should look well beyond 2011 and decide, in so far as it is able to do so, what the long term suture of the settlement should be and fashion its plans accordingly.

24. The Civic Society is concerned about the uncertainties in the Plan, principally those relating to the proposals for the west of Tamworth and Rugeley. It would expect that those uncertainties would be resolved by the time that the Revised Plan is placed on deposit in the Spring. The other anxieties are about the extent to which the Review can be implemented to fulfil the achievement of its aims and objectives. It is disturbing that the success or otherwise of the Plan will have to depend to such a large extent on decisions made by other agencies over which the Council can exercise little control.

Mike Tole and Roger Hockney,
Lichfield Civic Society,
January 1998