Lichfield District Council (LDC): Green Belt Review Method Statement – June 2019

Representation from Burntwood Action Group (BAG)

Paragraph references and quotations from the consultation document are italicised

1.14 …….. The existing Green Belt evidence within the district is considered to provide robust and tested evidence for the purposes of the Local Plan Allocations which will form the second part of the Lichfield District Local Plan once adopted. It is not the purpose of this future Green Belt review to replicate that work, rather to build upon it and provide a comprehensive review for future ‘plan-making’ within Lichfield District.

Due to the 2013 Supplement and subsequent Green Belt Supplements not recognising Lichfield and Burntwood as large built up areas BAG has always maintained that they are seriously flawed documents. BAG asserts that these documents are deliberately prejudiced towards not recognising the importance of much of Burntwood’s Green Belt in preventing urban sprawl.

The decision to only consider the West Midlands Conurbation as a large built up area and the choice of specific assessment questions, resulted in the 2013 Supplement producing ridiculous, nonsensical assessments, such as the one below, of a parcel of land on the northern edge of Burntwood.

LDC claims that the 2013 Supplement to the Green Belt Review was examined as part of the examination of the Local Plan Strategy and the 2017 Supplement was examined as part of the examination of the Local Plan Allocations. However, both of these Supplements were published immediately prior to the public consultations on the Local Plan and were not subject to separate public consultation. BAG asserts that, if the Inspectors did in fact examine these documents, it must have been no more than a cursory glance.

LDC’s consultant Arup has obviously identified the lack of credibility in LDC’s previous definition of Large built up areas and Lichfield City and Burntwood now head the list of ‘Large built up areas’ in this consultation document. This effectively nullifies the credibility of all previous Green Belt Reviews from 2013 and BAG insists that LDC must remove these documents from its Evidence Base and ensure that the new Green Belt Review is indeed “robust, comprehensive and independent.”

2.6 This Green Belt review draws on the existing work carried out within Lichfield District and the GBSLEP. It draws on good practice from other authorities including those within the GBHMA who have recently completed Green Belt reviews for their administrative areas (Appendix C). The method seeks to provide a comprehensive and objective assessment of the Green Belt within Lichfield District.

With the exception of the highlighted text, BAG welcomes this statement. The 2013 Supplement contained numerous subjective, prejudiced and sometimes inaccurate comments and BAG looks forward to more objective assessments, informed by site visits.

2.27 However, at Burntwood the largest scale of housing development proposed through the 1998 Local Plan was the redevelopment of St. Matthew’s Hospital, a former psychiatric hospital to the north-eastern edge of Burntwood which had become redundant at that time. Whilst the hospital site was proposed for housing development the area was not proposed to be removed from the Green Belt but rather was covered by a site specific policy for ‘major developed sites’ within the Green Belt.

2.30 The Local Plan Strategy (LPS) was adopted in 2015 and included consideration of Green Belt boundaries within the District. ………………. the St Matthews area (see above) be removed from the Green Belt with the boundaries to be defined through the allocations document.

2.31 The Local Plan Allocations document (ADPD) was prepared between 2016 and 2019 with the examination in public taking place in September 2018. The ADPD did not propose any changes to Green Belt boundaries with the exception of the removal of the St Matthews estate from the Green Belt. The detailed boundary for this change was drawn tightly around the existing built area of the estate. The ADPD is scheduled for adoption, subject to the decision of Council, in July 2019.

The St Matthews Estate has existed for 20 years as a major development within the Green Belt and BAG plus many St Matthews residents have questioned the need to remove it from the Green Belt. The reason given in the Local Plan Strategy: “Integration of this area with the town would be beneficial in allowing the St. Matthews estate to function as part of the larger urban area.” is a meaningless statement as residents of the estate have been treated no differently to other Burntwood residents. In fact, many moved from other parts of Burntwood to be further from the centre of the urban area. When questioned by BAG, LDC Officers gave the reason that it would make it easier for St Matthews residents to gain planning permission for changes to their properties. This was not true as many of those residents have extended their properties with no problems in gaining planning permission. It is patently obvious that the only purpose to be served by removing the estate from the Green Belt is to fracture the Green Belt boundary and make it easier for LDC Officers to justify the removal of adjoining land from the Green Belt. BAG urges LDC, through the Review of the Local Plan, to reconsider and reverse the decision to remove the St Matthews Estate from the Green Belt.

Existing Green Belt Evidence
2.40 As outlined earlier within this method statement a significant body of evidence has already been collected in relation to the Green Belt in support of the LPS and ADPD. This evidence has been tested at examination and is considered to represent good practice in undertaking Green Belt Reviews (Appendix C), specifically within the context of Lichfield District.

Obviously LDC’s consultant, Arup does not consider it good practice to avoid treating Lichfield and Burntwood as ‘large built up areas.’ BAG is very suspicious of LDC’s assertion that “This evidence has been tested at examination.”

2.54 The existing evidence prepared to support the LPS and ADPD processes has been subject to independent examination and as such constitutes a robust assessment of the Green Belt within Lichfield both strategically and of the individual parcels identified within the supplementary report.

The more times LDC repeats this point, the more suspicious BAG becomes.
2.74 It is important to define the terms within each purpose of the Green Belt. Specifically, within the first purpose it is important to define what is meant by ‘sprawl’ and ‘large-built up areas’ for the purposes of the assessment. Arup recommended that specific definitions be included, those that will be used are as follows:

• Sprawl: To spread out over a large area in an untidy or irregular way (Oxford dictionary). Specific consideration is that the large built-up area could become physically joined to other areas by an outward spread, with no open separation between settlements.
• Large built-up areas: The settlements of Lichfield City, Burntwood and the cities, towns and settlements comprising the West Midlands conurbation around which the inner boundary of the Green Belt is drawn (these include Birmingham, Sutton Coldfield, Walsall, Aldridge. Brownhills). The inclusion of Lichfield and Burntwood within this definition recognises the need to consider the outward sprawl of the largest settlements within the District into the Green Belt, along with the need to prevent the sprawl of the conurbation.

BAG welcomes the inclusion of Lichfield City and Burntwood in the list of ‘Large built -up areas’ but notes that the second sentence in the definition of sprawl is now redundant. The physical joining to other built up areas is covered by purpose b) To prevent neighbouring towns merging into one another.

2.80 & 2.81 the definition of ‘historic town’,

Despite Burntwood and Hammerwich having documented histories back to the twelfth century and being recorded as hamlets in the 16th century (A History of the County of Stafford: Volume 14, Lichfield, ed. M W Greenslade (London, 1990)) LDC fails to recognise them as historic settlements. This, along with the previous definition of a ‘large built up area’ endorses BAG’s opinion that LDC is attempting to understate the importance of Burntwood and Hammerwich and their Green Belt.
Burntwood should definitely be included in the list of historic towns and Hammerwich should be listed as a historic village.

2.91 OVERALL ASSESSMENT final paragraph
Applying professional judgement: it is recognised that the overall assessment is not intended to be a number balancing exercise and a certain level of professional judgement should be applied to all of the above rules and particularly where one of the purposes is assessed as ‘important.’ It is recommended that the overall aim and purpose of the Green Belt as set out in paragraph 133 is considered when making this professional judgement.

BAG urges LDC to make sure that Arup oversees the application of ‘professional judgement’ to make sure that it is not prejudiced against certain parcels of land , as was the case with the 2013 Supplement.

BAG welcomes the proposed involvement of Arup in reviewing the parcel assessments and final evidence base document prior to publication.

2.99 – 2.101 Site visits
BAG welcomes the importance which LDC now gives to site visits and Arup’s involvement “to ensure that a consistent approach has been taken and that the document represents a robust and appropriate study which can be relied upon as part of the Council’s evidence base.”

Appendix A: Example parcel/area assessment form
Table 1: Parcel/area assessment form

Despite the change in the definition of a large built-up area, the specific questions in the Assessment form (above) are identical to those in the 2013 Supplement, which only considered the West Midlands conurbation as a large built-up area. The only question which should be asked is Question 3:
Would development of the parcel/ area represent an outward extension of a* large built-up area? (*changed by BAG).

BAG also questions the consideration given to rounding off. The fact that the release of a parcel of land from the Green Belt would result in a more rounded shape of a settlement should be irrelevant. The value of a particular parcel of land should be judged on its own merits, not on the shape of the settlement which would be created. A parcel of land which spreads from the outer edge of a settlement deep into the settlement could be vital in maintaining views of and access to the countryside. Openness is a very subjective concept.

Extract from: Existing or potential contribution to positive functions of the Green Belt – retaining and enhancing the beneficial use.

Add a third question: Are there views of attractive open countryside across the parcel?

Appendix C: Green Belt Review good practice review
Again, LDC is claiming that “Documents represent the most recent evidence in relation to Green Belt within Lichfield District. All have been tested at examination in public for the Local Plan Strategy and Local Plan Allocations documents. These evidence documents provide an important baseline for the future Green Belt Review.”

BAG repeats its assertion that not including Lichfield City and Burntwood as ‘large built-up areas’ in previous Green Belt reviews and Supplements invalidates those documents and they should be removed from the evidence base. They do not provide a satisfactory “baseline for the future Green Belt Review.”

Posted by David Rathband in Burntwood Action Group, 0 comments


Those of you have been following our posts in the last week will know that the green land around Burntwood and Hammerwich is under serious threat from developers who are pressing our councils to grant them permission to build significant numbers of new houses, which will further compromise the shortfall in services and facilities in this area.
You can show your support for our fight to save the Green Belt by buying a ‘ Save Our Green Belt’ sign from BAG and displaying it outside of your property. By showing your support you will be letting developers and council officials know that local residents are opposed to building of any more new houses without first seeing a huge improvement in the local infrastructure.
Our Green Belt signs (which are about the size of house for sale sign) cost a nominal £7.50 and can be collected from Tony Goodman at 5, Duke Road, Chase Terrace, or Vic Chamberlain at 35 Farewell Lane, Burntwood, or alternatively they can be collected from BAG representatives outside of the Co-operative store at Swan Island on the morning of Saturday 9th & Sunday10th March.
Please help us to save our Green Belt.

Posted by David Rathband in Burntwood Action Group, 0 comments


Lichfield District Council is consulting on its Local Plan Review (Preferred Options & Policy Directions). This consultation ends on the 18th of March at 5pm.
Following this consultation, the Local Plan will be revised and will run until 2036.
Currently Lichfield District Council’s policy for residential development focuses most of the new development on Burntwood & Lichfield. This is despite LDC’s own consultation document stating that Burntwood faces many issues, which include:
• The need for better town centre facilities.
• Existing social infrastructure including health provision requires improvement.
• Limited supply of sites for development within the existing urban area, including brownfield sites.
• Nature, scale and direction of future growth.
• Significant environmental constraints near the town, including sites of special scientific interest area of outstanding natural beauty and special areas of conservation.
• Issues regarding transport movement & accessibility.
LDC planners are also proposing to produce a new Green Belt review, which if it follows the pattern of previous reviews, will make some parts of our surrounding countryside appear not to be important to the Green Belt and could therefore be released for housing.

Virtually all the green land surrounding Burntwood & Hammerwich has already been submitted by landowners to LDC for possible housebuilding.

If like us, you want to save the remaining green surroundings of Burntwood & Hammerwich it is imperative that you respond to the LDC Consultation and say that you:
• Do not support the Preferred Spatial Strategy
• Want it replaced by a strategy, which focuses new development on new settlements outside the Green Belt.
• Have no faith in any Green Belt review
1. Go online and use the council’s consultation portal:
2. Go online and download the official ‘representation form’:…/Loc…/Local-plan-review.aspx (scroll down to the bottom of the ‘Have your say section’)
3. Send your comments by email (using the 3 bullet points above if you wish) to: [email protected]
4. Reply to this post and request a specimen letter written by BAG to be sent to your own email address, which you can then post or email directly to LDC (LDC address will be on the specimen letter)

Posted by David Rathband in Burntwood Action Group, 0 comments

Meeting with councillors

We are pleased to report that we had a constructive meeting yesterday with County Councillor’s Sue Woodward & Helen Fisher. We discussed protection of the Green Belt around Burntwood, development ideas for Sankey’s Corner, easy access to Chasewater, responsibility for parks, opening of the railway line between Brownhills and Lichfield as a walkway/cycleway and health care provision.

Posted by David Rathband in Burntwood Action Group, 2 comments


We are pleased to confirm that there is now an opportunity for everyone to see the new Local Plan for Lichfield District, which will be used to shape how Lichfield & Burntwood will be developed up until 2036.
Plans are available in reception at LDC offices in Frog Lane and the Friary Centre in Lichfield and also at Burntwood Leisure Centre and Burntwood Library. Or you can go online to read the plan and give your views if you go to:
MOST IMPORTANTLY for Burntwood residents & businesses we all have the opportunity to meet the planners at a drop in session at Burntwood Library on Saturday the 9th of February between 10am – 2pm.
Please take this opportunity to meet the decision makers, see the concepts and ensure that Lichfield District Council understand how interested and concerned the people of Burntwood are regarding the development of their district.

Posted by David Rathband in Burntwood Action Group, 0 comments


Further to our Facebook post earlier this week (9th of January) regarding modifications to the Lichfield District Council Local Plan Allocations document – which is in relation to housing and employment – we can now further update you on the guidance given by Mr Mike Fox the independent inspector following his review in September last year:
Lichfield District Council have been advised to:
Account for local housing needs AND that of the Greater Birmingham & Black Country Housing Market Area – including the unmet needs of Tamworth & Birmingham.
Conduct a comprehensive Green Belt review to consider whether further Green Belt release is needed to accommodate new development in the District
Conduct a comprehensive view of employment land requirements in the district.
There are significant reasons for concern for the residents of Burntwood regarding these proposed modifications.
Firstly, the need to consider helping to meet the housing needs of authorities in Greater Birmingham & the Black Country Housing Market Area is based on a Duty to Co-operate policy which all neighbouring councils must consider should a nearby council claim that they have insufficient capacity to accommodate their own shortfalls.
In summary this means that LDC will probably have to increase the number of new homes than they were originally planning for the District.
Secondly a comprehensive Green Belt review in effect means ‘look at which Green Belt can be released to accommodate new build homes’.
This is extremely concerning as Burntwood Action Group are now aware that developers have been in discussion with LDC regarding Green Belt land at Bleak House Farm – land near Kingsdown Road, Duke Road & Ironstone Road in Burntwood. We are currently seeking clarification as to the extent of those discussions and we will keep you updated.

Posted by David Rathband in Burntwood Action Group, 0 comments

Help For The High Street

Please see below an excerpt from a recent BBC report on the regeneration of the High Street.
‘Britain has twice as many shops as it needs, according to the author of a report looking at how to revive the nation’s High Streets.
Retailer Sir John Timpson said local councils must be given more money to turn town centres into communities and meeting places.
Sir John told the BBC revival should be a “bottom up” job, with councils taking the lead.
“People should be allowed to get on and do it themselves,” he said.
Sir John, a member of the founding-family of shoe repair and key-cutting business Timpson, said each town centre needed to establish a task force to address issues such as planning. He said “planning must be made simpler and quicker”.’
The report wants the £675m already announced in the Budget for High Street improvements to be spent at the local level to improve public spaces and transport links.
Sir John told BBC Breakfast that reviving High Streets and town centres was not just about shopping. “It’s about communities and creating a hub for entertainment, medical facilities, housing. We probably have about twice as many shops as we need. But we are short of housing”.’
Burntwood Action Group believe that Sankeys Corner falls exactly into the category described above and have already set out such a scheme in their vision for a better Burntwood, which both BTC and LDC are well aware of.
We have further urged BTC to investigate this funding initiative and to make an application for funds at the earliest opportunity.
We will continue to press both local councils to ensure that this opportunity is pursued with vigour.

Posted by David Rathband in Burntwood Action Group, 0 comments

Developers and landowners beware…

Please see below an interesting article recently reported in the national press…

‘LANDOWNERS could be stripped of large portions of their profits from selling sites, under proposals expected to be unveiled in the Budget.

An official review commissioned by Philip Hammond, the Chancellor, is understood to endorse controversial calls for the state to “capture” more of the increase in value of sites when they are granted planning permission.

Sir Oliver Letwin, the former minister carrying out the review, is expected to say that councils should be able to seize greater amounts of landowners’ profits to fund the construction of local infrastructure.

“He has alighted on the fact that landowners are making more money than they should,” said a source familiar with Sir Oliver’s work.

Downing Street and the Treasury are now in discussions over how radical an approach to adopt.

Sir Oliver’s report could go as far as recommending compulsory purchase at prices that exclude the “uplift” in value from planning permission. But some fear this would be toxic among traditional Conservative supporters.

Mr Hammond is planning to set out Sir Oliver’s proposals in the Budget on October 29, although he is likely to fall short of formally adopting any ideas until they are further scrutinised.

Sir Oliver’s report comes amid growing calls from MPs, charities and think-tanks for the state to claw back more of the increase in value that landowners gain from planning permission.

Developers claim it would be a “wholesale erosion of private property rights” and insist that existing mechanisms already allow councils to extract money for local infrastructure.’

Burntwood Action Group would hope that if this report passes in to full scale legislation our local councils would fully utilise the additional funds to radically improve the infrastructure in the Burntwood area.

Posted by David Rathband in Burntwood Action Group, 0 comments

Special General Meeting Tuesday 16th October 8:00 p.m. at St Matthews Social Club, WS7 9EP

Burntwood Action Group are holding a special general meeting in order to discuss and agree on an update to our previously agreed constitution.
The purpose of this update is to document and agree that BAG will be taking on a wider role to try to push forward the changes which are needed to make Burntwood a more attractive and sustainable place to live and work. We believe that our locally elected representatives need the help of a non-party political organisation such as ours to formulate and drive forward such changes.

If you are interested in attending this meeting please just turn up at St Matthews Social Club and join our meeting.

Posted by David Rathband in Burntwood Action Group, 0 comments


Having previously attended and observed the majority of the government inspectors examinations of LDC development plans over the past 7 working days, Burntwood Action Group & Hammerwich Action Group formally took our appointed places yesterday to answer any questions in regard to the documentary evidence we have previously submitted to the inspector.
A summary of our evidence would show that we accept the fact that Burntwood has to accommodate additional housing in the in future, however it is our contention that previously identified brownfield sites should be fully developed before any Green Belt is released.
During the session devoted to development plans specifically for Burntwood we were able to draw the inspector’s attention to the number of ‘windfall’ houses that have been built in our area since the inception of the Local Plan Strategy. These ‘windfall’ houses (houses typically built in back gardens) amount to 219 dwellings, which is 30% above the number of new houses which are allocated to be built in Burntwood during the plan period. We are hopeful that these unplanned additional houses will help to persuade the inspector that our Green Belt can be preserved, at least in the near to medium term.
The inspector also noted the opposition in Burntwood to further building on Green Belt and was very well aware of the 4500 letters of objection that Burntwood & Hammerwich Action Groups had previously submitted to Lichfield District Council.
The inspector will now visit the areas in Burntwood that are proposed to be built on and will also take time to visit our Green Belt areas too. Once the examination process is complete the inspector will review all of the submissions, from LDC, developers, land owners and of course Burntwood Action Group & Hammerwich Action Group and will then provide his conclusion probably in the New Year.

Posted by David Rathband in Burntwood Action Group, 0 comments