Mr. Ian D. Thompson,
For the attention of:
Lichfield District Local Development Framework
Dear Mr Thompson,
Thank you for consulting the Civic Society on the Options and Draft Policies for the Core Strategy.
As a general point, we would say that there appears to be some duplication of questions since similar issues are discussed under both the options and policies headings. We would also have preferred to see a shorter set of key strategic questions, bearing in mind the extensive set of documents to study, the scale of which cannot be conducive to the promotion of community involvement. For this reason also we are disappointed to find the documents written in highly technical language with few concessions to plain English.
Firstly, as to the time horizon for the Framework, we believe that it should be up to 2016, given that it will be subject to regular review. There are too many unquantifiable factors to prepare a Framework with a time horizon to 2021.
We do not believe that the promotion of new development outside the two main settlements of Lichfield and Burntwood is sustainable. However, having said that, we accept that some limited new development will occur in Lichfield, principally as set out in the housing strategy. We recall that at the earlier public inquiries into the Lichfield District Plan, inspectors have raised their concern over the capacity of the City to absorb new development. We believe therefore that any future review of the Framework will of necessity need to readdress the role of Fradley as a truly self-sustainable settlement accommodating some of the growth needs of the area. This may well need to be addressed as part of a post 2011 scenario. We do not believe, however, that the Council should be setting the direction of development post 2011 now, for any assumptions to be made on housing demand projections must, of necessity, be vague.
You have asked about the role and function of Lichfield and Burntwood Town Centres. We believe that there is only limited physical capacity for expansion at Lichfield. That scope seems limited to "Kennings Corner and its environs". Otherwise we have to ask if there is any scope for new retailing development and if there's a demand. The major omission is, of course, that of a large retailing park for non-food goods. However, such facilities already exist at Tamworth and Cannock. Perhaps any new provision should be made at Burntwood? This would fit in well with your Council's desire to continue the regeneration of the Burntwood area. We appreciate that earlier proposals were rejected but remain of the view that such development, coupled to the bypass, would act as a stimulus to Burntwood and possibly be well located in respect of similar retail parks at Tamworth and Cannock. If further retail development at Burntwood does not go forward we believe pressure will build for a freestanding retail park to serve Lichfield adjacent to the M6 Toll, in closer vicinity to Lichfield. Finally, we support town centre housing; especially "over the Shop" schemes if suitable sites can be found.
Turning to rural issues, we support the need to develop a hierarchy of rural service centres. The introduction of policies to retain rural facilities, especially shops, is very laudable and should be supported, but a policy in itself will not tackle the underlying issue of the role and function of our villages. They now often act as commuter homes where shopping etc. is done elsewhere. The Council will need to work with a range of agencies and prepare a strategy to practically support rural facilities in those villages selected as main centres. This means that hard decisions will need to be made.
As far as affordable housing is concerned, whether in urban or rural areas, we recognise this as a real and growing problem. We have no new suggestions to make but believe that the Council will need to maintain its current policies in an endeavour to ensure that key workers can live in Lichfield and that new house buyers can get a toe hold on the housing ladder. This means providing affordable housing on new developments, by builders providing sums of money for the Council to apply to other sites, by supporting Housing Associations and by the Council supporting fiscal measures such as equity sharing.
We are uneasy at the suggestion that allocated employment land which has not been taken up should be deallocated. The Council need to investigate the underlying reason why such land is not coming forward. Compulsory Purchase may need to be a last resort solution. There may, for instance, be infrastructure problems that need resolving. We are especially concerned to see any suitable brownfield sites released for employment use. Land at Burntwood, linked to the bypass and close by the M6 Toll may be suitable.
You have asked about leisure and recreation. Whilst many will support new or refurbished facilities because they are by definition a good thing, there are a number of practical issues. Firstly, Lichfield is a small city and we doubt that some of the sought after facilities, such as ice-skating rinks and more leisure centres, can be economically sustained on the basis of such a small catchment. Whilst not wishing to be negative, we would urge the Council to carry out a thorough assessment of the need for a wider range of facilities and the financial implications of providing them. It should be borne in mind that the private sector are increasingly providing recreation facilities.
In response to your recreation questions, we believe that new recreation facilities at Burntwood should be supported as part of an expanded town centre and that land at Chasewater could be released from the Green Belt to promote it as a sub-regional recreation area with a wider range of facilities. It is time that local authorities took positive steps to realise its potential, which has been stifled by over-vigorous interpretation of Green Belt policy.
You are considering providing open space standards in the LDF. Whilst we support the general approach you need to be careful to avoid being overly prescriptive, since every site needs to be judged on its merits.
Most would support your desire to have a range of policies which actively support the improvement of the quality of the environment, protect the route of canals and increase biodiversity. In respect of the last item, we believe it would be wrong for the Council to introduce its own biodiversity standards when there is already in existence a Staffordshire Biodiversity Action Plan, which we assume you have endorsed.
You propose a core policy (No. 1) on Sustainable Development. Whilst we would not disagree with your proposal, we query whether you can make the sentiments in the policy happen. Sustainability in the Government's terms is about protecting the environment, promoting economic growth, using resources prudently and ensuring social exclusion is minimised. For the Council to balance all these competing philosophies is a tall order. It is certainly one, which Central Government has failed to tackle. Your proposed policies, which are designed to contain urban growth, develop brownfield sites, invest in rural communities and regenerate Burntwood, would appear to go some way to promote sustainable living but we remain sceptical that the Council can deliver on this proposed policy.
Moving onto housing design, we welcome any efforts the Council can make to promote sustainable building design and in particular, energy saving. We note that you will maintain housing densities in line with Government Guidelines, but your suggested exception of areas of "special character" is, we fear, fraught with problems. How do you define "special character"? Planning policy in this respect will need very careful drafting.
The issue of Tourism is a difficult one for Lichfield. We do not know the extent of tourism and its economic impact on the City. Do most visitors merely come to the Cathedral? Do people visit specifically for the range of restaurants or the theatre and Festival? We suspect that Lichfield's tourism potential is lower than imagined. Certainly, the experience of members of the Society is that Lichfield is not seen as an important tourist destination.
We trust these comments are of assistance to you.