The Local Development Framework |
Core Strategy - Preferred Options
The Civic Society has considered the Council's emerging proposals and this submission sets out its views for your consideration.
Firstly, we note that the preparation of the Preferred Options is predicated upon acceptance of housing figures set out in the ongoing Review of the Regional Spatial Strategy. You will know that the Regional Assembly's housing target for Lichfield District has been proposed as 8000 dwellings. The Civic Society has made representations over this figure to the Regional Assembly. We are concerned over its cumulative impact, given the unusually high level of District housing completions (2320) between 2001 and 2005. If this 8000 figure were to be accepted, then the 2001 to 2026 total completions would approach 11000 dwellings. We believe that such high housing numbers, even if the building rate could be consistently sustained, would have a detrimental effect on the character and environment of the City. This would also put a severe strain on the City's physical and social infrastructure; even if we could be assured that new service provision would partner new development. This has not always been the case with earlier housing developments in the City.
Therefore we have to express concern over the Council's apparent acceptance of the 8000 figure as a basis for the preparation of the Core Strategy. Your consultation paper states that "the Council will continue to lobby to keep the number of new homes at a sustainable level". Many people will assume that by using the 8000 target for the Core Strategy consultation, the Council has conceded the debate. The Society's comments on the Core Strategy should not, therefore be interpreted as acceptance of the proposed housing target.
Turning to the general thrust of the draft Strategy, we are disappointed to see that the Council can offer little but the continuation of the recipe as before. Despite the fact that your consultation leaflet refers to the public's desire for the character of the city to be protected from large scale development pressure and reports that Option Four, a new settlement, was marginally the most preferred during the earlier consultation phase, you have chosen to allocate 50% of the housing growth to the city. In particular, you suggest that 850 dwellings might be acceptable at Streethay and 1650 south of Lichfield. This is no more than a further bolting on to the City of new development in an unimaginative way. It would lead to a further erosion of the character of Lichfield as a compact cathedral city, as well as undermining the integrity of the Green Belt around the City.
The Society has long advocated that the Council should address the long term future of Fradley. Whilst we do not support the "Curborough" proposal, it being too close to Lichfield to avoid coalescence, we firmly believe that further development at Fradley, in excess of that proposed in the Core Strategy would enable the village to become a more sustainable settlement, as well as diverting development pressures from the City of Lichfield. Whilst you propose some development for Fradley, this opportunity is to be missed yet again.
We believe that your emerging strategy smacks of short-termism and that the reasons set out in paragraph 12.14 rejecting major development at Fradley could be addressed. You have already conceded that Fradley could accommodate a not insubstantial scale of residential development. Doubtless at any future roll forward of the LDF, the potential for further development at Fradley would need to be readdressed to assist in meeting future housing targets. There is a danger that, by default, Fradley will emerge as an unplanned large scale settlement, without the benefit of the appropriate range and level of physical and social infrastructure.
You will be aware that substantial development has taken place in the City, notably at Darwin Park in a relatively short period of time. If the City is to accept more residential development, it is important that a detailed and enforceable phasing policy is prepared to ensure that land is released in a timely manner. The phasing should expressly require timely provision of infra-structure such as recreational, community and social facilities unlike the Darwin Park development fiasco.
With the exception of Fradley, we generally welcome your emerging proposals for Key Rural Settlements, where a balance needs to be struck between limited growth, sustainability and the protection of each village's unique character. Where development does take place, we would urge the Council to be more vigorous in its negotiation for infrastructure facilities through the planning process.
You make reference to new shopping facilities. Besides the Friarsgate development, we note that new facilities are proposed for the existing Bird Street and Friary Car Parks. We find it difficult to comment on these proposals from a quantitative point of view, since they appear to be based on the (now outdated) assessment of shopping capacity made by your consultants in 2007. Since that time, not only have general economic circumstances changed, but further shopping development has occurred in neighbouring towns.
Furthermore, it is clear from the number of vacant retail properties in Lichfield that the demand for retail development on the scale that you envisage is over optimistic. This must bring into doubt the forecasts made in 2007. Moreover, you propose retailing development on Bird Street Car Park. Whilst not objecting in principle to such a scheme, the Society regards the site to be of great sensitivity in its location, in respect to its proximity to the Cathedral and Minster Pool. Any development on this site would need to reflect this sensitivity in its scale and quality. However its redevelopment at this time and in the current economic circumstances, seems at the very least, to be premature.
In addition the overall level of car parking in the City to cope with approved and proposed developments needs to be reviewed. The additional demand that the Friarsgate scheme will generate has not been fully provided for within the scheme. Further development on the Bird Street and The Friary surface car parks will create additional pressures worsening an already inadequate provision evidenced by the high level of on-street parking in residential areas around the City centre.
Finally, we note that little mention is made of any need for additional employment land. Some land, thus allocated at Fradley, is proposed in the Core Strategy to be reallocated for housing. Indeed, we see no evidence of a vision for future employment in Lichfield City.
We trust that these comments are of assistance.