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.

2.94
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.”

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