Our Position On…

LICHFIELD DISTRICT CORE STRATEGY

COMMENTS FROM WFEG

Housing

WFEG believes that 8000 additional properties is too high for Lichfield District. We believe that much of the work carried out to arrive at this figure took place prior to the major recession which we are now experiencing. Housebuilding is now at a very low ebb and this level of development is very unlikely to be realised. It would also adversely affect the regeneration of the conurbation - brownfield sites there could be left to as developers 'cherry-pick' attractive Greenfield sites. The logic for this level of housing permissions therefore needs to be revisited.

Some development makes sense in the villages eg starter homes, homes for older people, supported housing. New green belt development should be excluded and account needs to be taken of the capacity of villages to absorb new development eg the levels of traffic congestion which are already serious in Whittington in streets like Church Street, Back Lane and Main Street.

Housing generally should be sympathetically designed to be in keeping with the size and character of surrounding environment. However this should not preclude high quality modern development in appropriate locations.

High levels of 'green infrastructure' including trees and wildlife area should be included in all but the very smallest new developments.

Transport

WFEG strongly supports policies to improve walking cycling and public transport - and to reduce the need to travel through the sustainable location and design of facilities and development.

The strategy should strongly encourage traffic calming measures and 20 mph zones in rural villages, including Whittington.

Climate Change and Renewable Energy

Development which does take place in Whittington (and more generally) should meet the highest possible standards of sustainability - aiming for zero carbon development at the earliest possible time.

A sympathetic attitude should be taken in relation to carbon-reducing home improvements in Whittington in the Conservation Area - solar panels and double glazing should be generally permitted other than on listed buildings with high visibility.

More generally:
The highest priority in any new development must be to encourage the highest levels of energy conservation. Renewables should be seen as an addition - not a substitute. While we support the establishment of the proposed Carbon Investment Fund we do have concerns that this could result in lower standards on the sites concerned and should not be subject to developer 'preference'.

We propose modifying the policy statement removing the highlighted phrase:
However where achieving minimum targets are prohibitive, or where developments prefer to limit on-site measures, then, in seeking to achieve the zero carbon standard, a one-off payment can be made.

Careful consideration should be given to management and distribution of the Carbon Investment Fund - with full consultation on the establishment of the criteria which should include support for retrofit projects as well as renewable energy. Consideration should also be given to investment in renewables which will generate further income for the fund via Feed-in Tariff or the proposed Renewable Heat Incentive so that the fund can be replenished over time i.e. a rolling fund. The possible of a Community Company in the district to manage the investment of these funds should be seriously considered.

The over-enthusiastic approach to 'bio-energy' needs to be carefully considered - as bioenergy crops have the capacity to cause serious environmental damage if not produced sustainably - land use competition, air pollution - must not be seen as an alternative to high standards of insulation and energy conservation

Wind energy - small and medium-scale developments are to be encouraged and larger developments in non-sensitive locations. Standards must ensure that existing communities are protected from noise and flicker. The restriction to 6 x 2.5mW turbines across the district should be reconsidered as it appears arbitrary. Developers should be strongly encouraged to talk to neighbouring communities before any plans are submitted – and to give communities the option to share in the profits of the development - there are a number of options for this including a number where one of a group of turbines has been owned by a community. The restriction to three turbines on any one site should be reconsidered as this may preclude community ownership of one of the turbines –this is more likely where there are 5 or 6 rather than one. Community benefit should be a major consideration in assessing these applications

The target of 10% of the District’s needs being met by renewable energy by 2020 should be regarded as a minimum to be exceeded if possible.

Wider Environment

WFEG strongly supports the development of 'green infrastructure' particularly that which is wildlife/biodiversity friendly and believes that Developers should contribute to this wherever possible

WFEG Supports Campaign against High Speed Rail (HS2) Proposals

WFEG has looked at the case for the new HS2 rail line which the Government wants to see built from London to Leeds and Manchester. We have tried to look at the case for and against – particularly the impact on carbon emissions and energy use. WFEG is not a 'nimby' organisation – in other words we try to take the wider view and not just look at the local impact of development – though that is obviously important too.

HS2 would be one of the largest commitments of public funds. It is imperative that it is based on facts and sound analysis. Building new High Speed Rail (HSR) lines has been promoted as a valuable means to tackle climate change. Yet it would have a limited effect in reducing carbon emissions, particularly once the emissions from construction have been factored in.

Only with demand management measures, such as increasing the cost of flying and driving and limiting road and runway capacity, can HSR be part of a sustainable solution. The other side of the coin is that these measures would require a step change in rail capacity, which on the busiest corridors may be best catered for by additional tracks or new lines.

Our considered view is that the case for the High Speed Rail line from London to Leeds and Manchester does not stand up to critical examination from either an environmental or economic perspective. From the environmental perspective consider the following: HS2 will not reduce CO2 emissions. 360km/h trains use more than twice the power of 200km/h trains. Journeys on HS2 will indisputably create more emissions.

Only a new railway line can solve the rail capacity problem. Extra capacity could be achieved with just extra rolling stock on the West Coast Main Line and without the material disruption caused by the construction of HS2.

HS2 will not greatly reduce domestic air travel Any reductions in domestic air services will be replaced by more polluting long haul services. Experts agree air wins against rail for trips over 3 1/2 hrs.

It is unsurprising that HS2 is not 'green' because:

• Speed is not 'green'. Most of HS2's forecast passengers would otherwise be travelling on less energy consuming conventional rail.
• Encouraging more travel is not 'green'.
• HS2's only means of reducing emissions is winning traffic from air. Domestic air passengers have been reducing from Heathrow since 1997, domestic passengers from all London airports to the North West and Scotland (lowlands) has been declining since 2004 and total domestic passengers have been reducing since 2005.

There is no London/Birmingham air market and rail already has 80% of the Manchester-London flow. The forecast gain from air exceeds the entire of the current flow of air passengers between these places and Heathrow.

Whether the introduction of HS2 leads to an overall increase or decrease in emissions is almost entirely dependent on the impact of changes in demand on aviation emissions. There is considerable uncertainty around this and actual changes in emissions will depend on how airlines respond to reduced demand.

The Government are committed to reducing emissions by 80% by 2050. How can it be sensible to have the proposed HS2 transport investment make little or no contribution to this? It appears we are being asked to pay an unacceptably high price for a flagship project which will yield little discernible environmental benefit.

Fisherwick Quarry Proposal

WHITTINGTON & FISHERWICK ENVIRONMENT GROUP STATEMENT UPON THE MINERALS CORE STRATEGY DEVELOPMENT PLAN: CONSULTATION ON ISSUES & OPTIONS (2) – published by Staffs. County Council, September 2008.

Whittington & Fisherwick Environment Group (WFEG) recognise that there may always be a varying requirement to meet the needs of the construction industry for raw materials, but WFEG doesn’t support the presumption that any or all of this has to be solely derived by the extraction of aggregates from the natural environment.

WFEG would suggest that a greater proportion of such material should and could be sourced by prudent and effective recycling of existing materials and waste which in turn would reduce to a minimum the type of environmental damage that would be caused by any of the proposed extractions contained within the Staffs Minerals Core Strategy Development Plan (MCSD).

The MCSD presumes a continuing level of requirement for minerals / aggregates based upon future projections that are highly likely to be incorrect in the current economic climate. It also presumes that such extraction continue to be sourced disproportionately from within Staffordshire and puts no reasonable basis forward as to why this should be the case.

The MCSD also implies that it is entirely acceptable to approve and undertake such extraction on the presumption that at some time in the future the resultant desecration to the environment, the disruption, loss of amenity and quality of life to the local populace and the effects upon the flora and fauna can somehow be recompensed in the longer term by ameliorating the damage. The evidence locally suggests that even if this were proven to be the case, which is extremely doubtful, there is no statutory guarantee that the extraction companies will honour agreements to undertake such nor the Public Bodies charged with ‘policing’ this will in fact do so.

WFEG is therefore of the firm belief that the proposals as they stand do not form a sound basis upon which Staffordshire County Council should make decisions upon future mineral extraction in Staffordshire and WFEG will, as it deems necessary, lobby upon this basis.

Update April 2010

At a meeting of the Regional Assembly in Lichfield on Wednesday 17th March 2010, it was agreed that Staffordshire’s contribution to the regional sand and gravel quota for the West Midlands would fall from 65% to 55%. That equated to an annual 1 million tonne reduction over the next decade. This meant that the newly agreed quota could be fully met from existing quarry works, albeit it was theoretically possible for the industry to seek a Judicial Review upon the decision.

Common sense, environmental considerations, and a recognition that the world is changing as well as more recycling of aggregates and changes in the building industry are all factors that produced the outcome.

However the baseline upon which WFEG formulated its statement about the MCSD have not changed and would be equally applicable should a similar situation arise in the future.