Lichfield District Core Strategy |
Shaping our District
|Comments of the Lichfield Civic Society|
1.1 The most important point to be made in relation to this Chapter concerns the statement in paragraph 2.4 that describes "the City of Lichfield as an important historic centre, with a major conservation area based around the Cathedral, a medieval street pattern and historic city centre buildings". There is a vital and over-riding need for the policies and approach put forward in the document to emphasise the importance of safeguarding and enhancing this character overall and of the constituent parts, as defined in this Chapter.
1.2 It is a principal concern of the Civic Society that this need for safeguarding and enhancement is not addressed effectively, and that the policy approach and proposals in the document fail to adhere to these early statements describing the importance of the historic character of the City centre. In reality, there is a significant and unacceptable conflict within the Council's approach between the contents of the Spatial Portrait and Strategic Objectives 14, Built Environment, and 15, High Quality Development (as referred to in Chapter 3), and the very substantial additional development proposed in retail and office space (as well as in housing numbers) for the City centre in particular, and the City in general. This conflict is very largely ignored, and certainly not addressed in an adequate or satisfactory manner in the document by the Council.
1.3 The Council has made an important and welcome move to substantially reduce the areas of Green Belt proposed for housing development. It would be a major step forward if the Council were to commit itself to no loss of Green Belt in the emerging Core Strategy. As we understand it this would only affect two sites i.e. the South of Lichfield Strategic Development Location and land in the Council's ownership between the A5 and the M6 toll adjoining Chasewater. The long-standing commitment of the District Council to retention of the Green Belt is highly commendable and ought to be continued. This would best be achieved by amending the Core Policy 1 - The Spatial Strategy which refers to "The role of the Green Belt is recognised ..." to a firm unqualified commitment of the Council to retention of all Green Belt in the current plan period.
1.4 The reference to 'South Lichfield' as a Strategic Development Location is described elsewhere in the document as 'South of Lichfield'.
2.1 It is considered that the statement of "Vision" should give greater emphasis to particular aspects critical to the long term future of planning for the District. The most important issues requiring re-emphasis are as follows:
The importance of the historic character and environment of Lichfield City Centre and its immediate surroundings, and the fundamental aims of achieving protection and enhancement. This will require a more balanced distribution and location policy for additional development, giving far greater weight to the importance of the historic environment than is apparent in the current approach. It will require avoiding the imposition of unacceptably large scales of development (housing and commercial) upon the City area which at currently proposed levels is potentially jeopardising the special character that now exists.
[The West Midlands Environment Priorities Review prepared by WMRA in July 2010 noted that on a national basis the West Midlands Region faced the highest level of risk to the historic environment from new development and regeneration activity. It is considered the scale of proposals emerging for Lichfield City is precisely the sort of threat referred to in the Regional report].
Housing provision to be primarily focussed on providing for locally generated needs only.
Better balancing the distribution of development proposals between the main settlements of Lichfield City and Burntwood and the growth centre of Fradley, in relation to the current needs of the two towns, environmental considerations and the emerging proposals for Fradley to create a more "rounded" and balanced settlement.
2.2 The Vision in paragraph 3.14 on page 23 should include a clear policy for Burntwood which is one of the largest towns in the country without a rail service.
3.1 The housing numbers proposed (8,000) is queried, and will be considered in detail later in this submission in relation to Chapter 8.
3.2 The balance and distribution of the housing allocations is queried, in particular the relative proportions of housing numbers allocated to Lichfield City and Burntwood (and to a lesser extent, Fradley). In view of the similar sizes of the two main towns and the fairly equal numbers of houses needed in both settlements, the proposals for 41% of the total provision for Lichfield set against only 13% for Burntwood seems to be creating a very skewed situation. It is desirable to consider some amendment to these proportions and distribution so as to ensure housing provision more closely relates to localised needs. Not proceeding with the proposal for providing housing on the Area of Development Restraint and Green Belt at Lichfield South would assist in moving towards this.
3.3 Although Fradley is proposed to accommodate much of the rural housing needs of the District, it has potential to accept further housing on land to the west of the area currently proposed for re-allocation from industrial to housing. This additional area up to Gorse Lane is previously developed, and is similar in nature to the adjoining land currently being put forward by the Council. The additional land offers an opportunity to relieve further the development pressures on Lichfield City, as well as supporting enhanced service and facility provision at Fradley.
3.4 It is noted that the recommendation of the WMRSS Phase 2 Revision EiP Panel to undertake "a comprehensive study of the most sustainable way to meet long-term development needs" to the north-east of Lichfield has not been undertaken. However, the Society recognise that the current proposals go some considerable way forward in addressing the matter in an effective manner. It is considered that the focus on creating an enlarged and more sustainable settlement based on Fradley is appropriate, and is a far more acceptable approach than the suggestion for the development of greenfield land at Curborough by a consortium of developers.
3.5 The scale of the proposals for retail and office development in Lichfield City are excessive in terms of the cumulative overall total of new floorspace in relation to protection and enhancement of the historic environment and character. This will be considered later in this submission in relation to Chapter 9, Economic Development and Enterprise.
3.6 Core Policy 1 states: "Rail travel will be enhanced through environmental and infrastructure improvements at Lichfield City Station. At Trent Valley Station accessibility will be improved and a new strategic park and ride facility provided. ......" However Core Policy 5 on Sustainable Transport has no reference to Lichfield City Station but does repeat comments about Lichfield Trent Valley Station improvements present in Core Policy 1. This inconsistency should be resolved.
3.7 In Core Policy 1 the reference to "Trent Valley Station" should be "Lichfield Trent Valley Station" to avoid confusion with Rugeley Trent Valley Station which is also in the District.
3.8 The need for improved disabled access at both Lichfield Stations should be explicitly set as policy objectives.
3.9 Map 4.1 on page 34 appears to have missed the Canal extensions.
4.1 Chapter 6 on page 51 sets out the Council's Strategic Plan ambitions as being:
"Joint Effort - We believe the best way to achieve all this is through a joint effort working in partnership with local people and organisations."
It is therefore disappointing that the Civic Society, Residents Associations, the Residents' Alliance and those affected by weaknesses in the delivery of infrastructure on recent developments were not invited to participate in or comment on the process.
4.2 The Core Policy on page 28 of the Core Strategy, which is repeated on page 6 & 7 of the IDP, should include safeguarding of the route of the Lichfield - Brownhills rail line to assist in sustainable transport improvement in the longer term.
4.3 The Core Strategy makes no reference in Chapter 6 or the Chapter on Sustainable Transport to the need for a car parking strategy for Lichfield City. In the Infrastructure Delivery Plan there is a section on Town Centre Improvements & Redevelopment but no direct consideration of car parking strategy. This is a serious omission which should be addressed in the Core Strategy for the following reasons.
4.4 The scale of housing proposed in the Lichfield City and commercial development on three major sites in the City will add to the already congested local road network, increase the problems associated with on- street car parking and increase demand for car parking. Whilst moves to encourage use of public transport are welcome the current proposals will have a negative rather than positive impact. The bus station facilities are being dramatically reduced by the Friarsgate scheme and as yet the Council have failed to identify a suitable location for coach parking facilities being displaced by the Friarsgate and Friary Outer car park developments.
4.5 There is no evidence that the Council has a coherent strategy on car parking provision within the City nor that they intend addressing the issue. There a number of initiatives and developments under way or planned that impact on car parking provision.
Below are of some of the matters that need to be considered:
4.6 The consequences of the substantial under provision of car parking for the scale of development in the Friarsgate scheme is not mentioned anywhere.
4.7 The move towards replacing surface car parks with multi-storey buildings will further discourage use of the City centre in favour of nearby towns that offer free surface car parking. Current surface provision to be replaced includes Friary Outer car park, Birmingham Road bus station, Bird street car park and potentially the Redcourt House site in Tamworth Street. In addition several of the existing surface car parks are temporary. These include The Friary site adjoining the South Staffordshire College, which has a temporary planning consent because the site is designated Framework Open Space, and the site on the corner of Sandford Street and Swan Road that the Council sold and are leasing back.
4.8 Bird Street car park because of its location and it being a surface car park is the most popular and heavily used car park. Redevelopment of this car park and securing replacement of the existing spaces and the additional provision for the retail and commercial elements implies either a multi-storey building of some considerable height, underground car parking, provision elsewhere or a mix of these. The reluctance of drivers to use the lower deck on the Lombard Street car park and relatively low utilisation of the Birmingham Road multi-storey car park indicate a user preference for surface car parking provision. Introduction of more user friendly ticketing arrangements would also be an improvement including pay on exit systems. Ticket pricing is, in relation to nearby shopping centres, relatively high and is another significant factor in encouraging local residents to shop elsewhere.
4.9 There appears to be no realistic attempt to deliver public transport as a mode to substitute for the lack of future car park capacity.
4.10 Our view is that without a comprehensive and coherent car parking strategy for the City the Core Strategy is unsound.
4.11 Core Policy 4 - Delivering Our Infrastructure states "New development will be required to provide the necessary infrastructure at a timely stage to meet the community needs arising as a result. Development will also be expected to contribute, as appropriate, to strategic projects that support sustainable development and the wider community." and "New development will be required to provide the necessary infrastructure at a timely stage to meet the community needs arising as a result"
Page 52 concludes with the following statement:
"Both strategic and local infrastructure provision will be linked to the phasing of new development. Phasing details are set out in the Infrastructure Delivery Plan (IDP) and the Concept Statements relating to the Strategic Development Locations (SDLs) identified in the Core Strategy."
IDP paragraph 1.4 says "It is recognised that any proposed growth within Lichfield District must be supported by improvements to physical, social and green infrastructure, and where necessary, be delivered in advance of development."
4.12 We fully support the statement in paragraph 1.4 but are concerned that the mechanisms and processes to ensure timely delivery of infrastructure are not referred to in the Core Policy or the IDP document. The reference in paragraph 8.9 to regular reviews and giving priority to 'encouraging the provision of key essential infrastructure' does not properly address this issue. There is no definition of what is key essential infrastructure. The developer, residents, the District and County Council's will have different views on this. The need for conditions, contractual requirements or section 106 agreements and their effective enforcement to secure timely delivery of infrastructure should be a strengthened policy commitment expressly included in Core Policy 4. The reference in the IDP to delivery of infrastructure, where necessary, in advance of development should also be included in the Core Policy. Conditions relating to phasing and control of density to ensure the overall scale of development is consistent with the allocations and the consent are also essential. We are submitting some additional comments in an appendix on the detailed content of the Infrastructure Delivery Plan.
4.13 The issue of phasing details in the Strategic Development Locations (SDL's) so far as it relates to strategic housing sites refers, for example on page 115 of Core Strategy, to Community and Green space provision being "During development and first occupation" It is not clear whether this means the Community Hub will be provided before the occupation of the first house or when a yet to be specified number of houses have been built. Given the timing problems on Darwin Park with the Community Hall and adoption of open space greater clarity is needed. The phrase "During development and first occupation" is used repeatedly for the SDL sites and in the Infrastructure Delivery Plan. Adoption of highways and public sewers has taken over 10 years on Darwin Park. The phasing details, controls or other requirements that will be implemented to avoid these situations being repeated should be spelt out.
4.14 Similarly clear statements should be made about how these issues will be dealt with on large scale housing sites that are not Strategic Development Locations.
5.1 We have made comments that also relate to this policy in our comments on:
1. Chapter 4 about Core Policy 5 on Sustainable Transport having no reference to Lichfield City Station although it does repeat comments about Lichfield Trent Valley Station improvements present in Core Policy 1, and
2. Chapter 6 on infrastructure about the lack of a car park strategy and
3. Chapter 8 concerning the Southern Bypass extension and improving highway and footpath standards in residential developments.
6.1 The target figure proposed of 8,000 new homes is neither appropriate nor justified. The contents of various papers produced by the Council and other sources quoted do not clarify nor justify the requirement. It is questionable, therefore, whether there is adequate evidence available to support 8,000 additional homes as proposed. Further substantive and compelling evidence for the Council's proposed target is, therefore, necessary in order to justify the figure.
6.2 An additional and related question arises concerning the statements made in paragraph 8.6 that 645 sites could potentially be delivered within the next 5 years, with 645 thereafter, "on a range of previously developed and previously undeveloped sites within settlement boundaries".
6.3 This statement may have been based on information collected and assessed in the preparation of the SHLAA some 12 months ago, but there is no clear link to this. Additionally, with the continuing downturn in the economy and in housing starts and completions, the delivery of these numbers is unlikely to be achieved, other than over a longer period of time.
6.4 It is the opinion of the Civic Society that clarification of this and the relationship of these additional 1300 homes to any "windfall" assumptions being made is required to ensure the approach is both robust and justified.
6.5 In relation to the proposed 8,000 homes target, the SHMA report (2008) suggested the housing need figure for Lichfield District was 7,000 dwellings for the Plan period.
6.6 There are regular publications by Central Government of Sub-national population and household projections, and the 2004 and 2006 household projections for Lichfield District have ranged from 6,000 to 9,000 respectively. Household forecast projections for 2008 have not yet been issued, but it would seem reasonable to assume, with the following points taken into account, that the figures will reduce from the 2006 levels to the 2004 figure of 6,000.The factors for supporting this (and as referred to in the Housing Topic Paper - 2011 paragraph 3.12) are as follows:
1. The downturn in the economy
2. The significant recent fall in net inter-national migration into the region
3. The continuing losses of population from the West Midlands to other regions
4. The rate of household formation, as driven by population increase and inter-national migration, and
5. The variation in household formation is greatly affected by net in- migration.
6.7 These points clearly indicate a decrease in household formation and hence housing requirements. Cumulatively these on-going changes are having a considerable impact on household formation and the number of additional homes needed.
6.8 To illustrate this further, the Council's Demographics Paper (2009) at Table 2.2 indicated that for the District, "internal migration" was the largest component of forecast population change for the period 2006-26 (with an increase of 20,100) whereas "natural change" and "international migration" contribute to a decrease (of 2,500 and 4,000 respectively).
6.9 The decline in housing completions in the District during the last year or so further supports this argument, with the most up to date information showing that only 102 dwellings were completed in 2009-10. Even over the longer period, from 2006-2010, on average only 312 units were completed, which falls well short of the Plan's proposed 400 per annum.
6.10 Based on these factors, it is considered that a figure of 6,000 new homes is realistic and deliverable and should, therefore, be the target for the District for the Plan period, 2006-26.
6.11 It is accepted that over the past decade or so, under different planning regimes, that greater numbers of houses were built in the District on average each year than are currently proposed or needed. Completions in the District were 4,900 approx (1996-2007) and 4,100 approx (2001-2009). Two points need to be made concerning these figures. Firstly, these previous build rates have made very substantial additions to the "new" housing stock of the District, with significant impact on Lichfield City and other locations, as well as putting the physical and social infrastructure and the historic environment under great pressure. Secondly, previous planning regimes accepted significant levels of in-migration to the District. With the Localism Bill bringing the opportunity for a changed emphasis, primarily to address local needs and requirements, there will be no need to incorporate significant housing provision for in-migration.
6.12 Now, it is time to adjust to a lower level of provision, a slower pace of provision more closely related to the scale of local needs and the existing availability of physical and social infrastructure, which can more readily be assimilated into the "sensitive" environment of the District. A proposal for 6,000 dwellings in the Plan period would facilitate this, and is, therefore, considered to be justified.
6.13 Within the "Shaping Our District - Non-technical Summary" document (2010) views are sought by the Council on the implications of a number of alternative levels of growth.
6.14 Paragraph 2.44 considers 4,000 homes over the Plan period, which it is agreed is too low a figure and inadequate provision for the general reasons stated.
6.15 Paragraph 2.45 considers 6,000 homes over the Plan period, and paragraph 2.46 suggests the various advantages to be gained from such a lower growth figure. The reasons listed are supported, with the additional benefit not referred to, of creating less impact and harm to the environment of existing settlements in general, and to the historic environment and character of Lichfield City in particular.
6.16 Paragraph 2.47 then lists a number of alleged disadvantages of the lower growth levels. A number of these are considered to be inadequate as reasons not to accept, say, 6,000 homes as the target figure. It is not acceptable or appropriate to use an argument for substantial need for "affordable" housing as the basis for proposing large, and unsubstantiated, numbers of houses overall. The assessments of total "affordable" housing need appear excessively high (at 3,000 within the next 5 years) and unrealistic and the approach has weaknesses, as, for instance, in the manner in which it is stated to exceed the overall housing target, and then is arbitrarily reduced to fit. Additionally, to suggest that larger, strategic sites are required and proposed to ensure the proposed 15 unit threshold is exceeded to ensure provision can be sought appears to be a contrived approach. It is considered that a range of homes (tenure, type and size) can be provided within an overall housing target figure of 6,000.
6.17 It is a further concern of the Civic Society that the District Council's proposals for housing might be predicated on the basis of financial gains from proposals by Government for a "New Homes Bonus". The Civic Society wishes to seek an assurance that the possibility of benefitting from financial incentive is playing no part in the formulation of the housing target proposals of the Core Strategy.
6.18 The statement concerning infrastructure made in paragraph 2.47 is also questioned. Any existing gaps or shortfalls in infrastructure should not be made the responsibility of future development proposals. Proposing an increased scale of development in order to address current infrastructure deficiencies should not be acceptable as the basis for justifying an increase in the scale of development proposals. A developer can only reasonably be expected to provide, or contribute to provision of, infrastructure that is needed for development to proceed, and cannot be expected to provide solutions for existing shortfalls. If community facilities are "inadequate" today, or if a housing development is needed to justify and fund a road link, is not a proper justification for increasing the scale of development. Only provision of infrastructure which is directly related to a particular development in scale, kind and location can be justified as legitimate.
6.19 In terms of the statement concerning implications of lower levels of retail and office growth listed in paragraph 2.51, the advantages referred to - not increasing congestion, and alleviating pressure on the historic built environment and existing services and facilities - are critically important and should be recognised and accepted in the case of Lichfield City as paramount in addressing the issue. There is justification to decrease the scale of both proposed retail and office provision (as well as re-considering housing numbers) in the City Centre in particular and in the City in general in order to benefit from the advantages expressed in paragraph 2.51.
6.20 It is considered that the alleged disadvantages of lower growth listed in paragraph 2.53 are illusory, and far out-weighed by the advantages quoted earlier.
6.21 There is no discussion or policy statement about the use of phasing to control densities within developments to prevent the Darwin Park approach of allowing high densities in the initial phases thus enabling on the remaining areas substantially more additional housing to be built over and above the allocated and approved planning consent number.
6.22 The Darwin Park experience throws considerable doubt upon the reliability of numbers used by the Council for site allocations. On Darwin Park the Council deliberately took no steps to control the numbers resulting in an increase of 72% being built compared with the Local Plan allocation. Such an enormous difference in the projections of housing numbers and allocation on sites and the actually number delivered raises questions as to whether the existing range of numbers particularly on the Strategic Development Locations are understated.
6.23 Darwin Park was allocated in the Lichfield Local Plan for 650 houses. The number approved is 1122 which is an increase of 72.6% over the site allocation. If an increased figure of say 70% is applied to the Strategic Development Locations then the higher figure total for these sites of 3675 increases to 6247. Even if only 35% were applied, it represents an increase of over 1280 dwelling. That additional number is sufficient to enable several of the contentious Strategic Development Locations to be dropped.
6.24 The Council gave evidence at the Lichfield Local Plan Public Inquiry that the area allocated for housing was not excessive and when asked to use powers to control the density of phases within the development declined to do so. This inevitably leads to serious concerns that the range of figures now being put forward cannot be relied upon and could well be substantially exceeded. It is important to recall that the permission for Darwin Park was given before PPG3 was modified and there was therefore no power to require or obligation to permit higher densities than originally approved.
6.25 The Core Strategy ought to clearly indicate that the site specific allocations are a maximum that will be permitted and include a policy commitment that powers will be used to control densities on the phases of development to ensure the overall allocations on individual sites are not exceeded.
6.26 The gap formed by Green Belt land between Lichfield and Sutton Coldfield/Birmingham is already vulnerable, being relatively narrow and containing a significant number of sporadic built up areas, a number of which are fairly recent, including, for instance, the Wall Island commercial development and the Fosters/Wyevale Garden Centre. Additionally the M6 (Toll) Road, with its various ancillary developments and buildings, has been introduced into this same area in recent years. Any further encroachment of the City towards Knowle Lane would be contrary to Green Belt principles, leading to loss of separation, imminent coalescence of the urban areas and loss of openness. The gap between the urban edge of the City (if the South of Lichfield development takes place as currently proposed) and the Wall Island development would be reduced from some 1800 metres to approximately 1000 metres.
6.27 There is some confusion as to the boundary of the proposed housing development and the proposed boundary of the Strategic Development Location. Because the SDL includes land in the Green Belt the boundary line shown on various plans publicised by the Council should be formally withdrawn and this action should be confirmed making it clear that the two boundaries proposed are contiguous.
6.28 It is of concern that the boundary line shown for the southern edge of the proposed housing area does not follow any physical features on the ground, and is, therefore, open to uncertainty. It would not provide the "defensible" and easily defined boundary necessary at the edge of Green Belt for long-term protection and certainty. It is suggested that the boundary be amended to bring it into line with existing features on the ground and maps of the area. One such field boundary runs across the site a short distance to the north of the currently proposed boundary line.
6.29 One of the fundamental issues in the original designation of the Area of Development Restraint was that in relation to that land and the land outside the area closest to Knowle Lane that no development would be allowed which projected above the horizon when viewed from south of Lichfield including Knowle Lane. That design principle seems to have been lost or abandoned in the concept rationale and key design principles. It should be explicitly spelt out as an essential requirement.
6.30 There is some uncertainty about the future of the area of land within the site boundary, which is designated as Green Belt. We have heard two apparently conflicting explanations.
Firstly, a Council statement in the Lichfield Mercury on 10 February 2011 stated that:
"With any development, we create a boundary that shows where houses will be built, and where supporting development could take place. The boundary we've drawn around the potential development site in South Lichfield includes some Green Belt land.
No housing development will be allowed to take place on the greenbelt land within this boundary."
Secondly, during the consultation process we understood that the Council had indicated that the Green Belt designation is to remain for the area outside the land designated as an Area of Development Restraint. This explicit commitment should be included in concept rationale.
6.31 At the moment the design strategy on page 110 says "The southern extent of the Strategic Development Location will be defined by the landscape and topography setting, with reference in particular to the contours of Knowle Hill and Aldershaw Hill, and with due consideration to notable buildings of importance or prominence.". This implies flexibility over the boundary and potentially there will be encroachment into the designated Green Belt. It should be made clear that the Green Belt area closest to Knowle Lane should not to be encroached upon, built on, developed, removed from the Green Belt or treated as meeting the open space provision or other development requirements of the allocated site required directly or indirectly for or to support the housing development. The Council should make it clear that in no circumstances will they permit or facilitate the removal from any land within this site of its designation as Green Belt. If it is the Council's intention to remove the Green Belt designation or that there is to be development permitted on this area of land within the Green Belt that ought to be expressly indicated so that the issue can be considered at the forthcoming Public Inquiry. If not expressly indicated and it is the Council's intention that there should be supporting development located within the Green Belt they will be effectively trying to progress matters by stealth rather than being open and transparent about the proposals. It should be noted that in the Lichfield Local Plan chapter on 'Environment, The Countryside and Rural Economy' the Council stated that the Area of Development Restraint was "a sensible long term boundary which will not need to be altered beyond the plan period." This commitment should not be breached.
6.32 These comments are without prejudice to objections to this site allocation and should not be construed as in any way supporting the proposed allocation.
6.33 There is a history of school, college and recreational uses allocations on Boley Park and Darwin Park not being developed for the purpose they were allocated for. This raises concerns that the safeguarded sites such as the proposed primary school site allocations in the South of Lichfield, East of Lichfield (Streethay) and Fradley Strategic Development Locations may not be used for that purpose. If this is the case, what mechanisms will be in place to prevent the site(s) being used for additional housing? The Council should state clearly the intended alternative use as it relates to each location if the school site is not used for the safeguarded purpose. If housing is the safeguarded use then the numbers should feature in the housing numbers projections.
6.34 The proposed Southern Bypass Extension is not a "bypass", as development as currently envisaged, would be located on the land beyond the road line to the south. It is, in effect, a development road. It should further be pointed out that this approach is not consistent with the existing length of the Bypass where all development and the urban edge lies within the line of the Bypass.
6.35 The proposed Southern Bypass extension (as well as the proposed South of Lichfield development) could be withdrawn from the Plan and abandoned. Traffic from the west and north-west of Lichfield wishing to travel towards the south, south-east and east could be re-directed south from the existing Bypass to the A5 at Wall Island. From there routes to the south and east can provide quality access towards Birmingham, Tamworth and Burton-on-Trent via A5 and A38. Compared with the construction of the Bypass extension, relatively modest improvements and alterations would be necessary to accommodate this change to utilise Birmingham Road. It is understood the Highways Agency have already prepared improvement proposals for the A5 Wall island junction, and it is suggested any additional changes required by this proposal should be included in the scheme.
6.36 There are two issues are of concern:
What policy action the Council will take to ensure that a majority of social housing allocations are to local residents? In the recent past a high proportion has been to non-residents. Given the level of need and in line with current Government policies greater priority should be given to local needs.
The Fordham Research study recommended a requirement for 20% would be broadly reasonable yet the Council has decided on 40%. Setting such a high requirement will be a disincentive to local investment and become self defeating in securing affordable housing. It will encourage developers to look for sites in areas with more realistic policies that enable viable schemes to be progressed.
6.37 It is common knowledge that highway design, car parking, road safety and emergency vehicle access are problems within the Darwin Park development. There should be a clear policy commitment in the Core Strategy that design requirements for these matters will be implemented to avoid these problems on new development sites.
6.38 There is independent and authoritative information which substantiates the nature and scale of these issues in the "The Manual for Streets - evidence and research" prepared for Traffic Management Division, Department for Transport by I York, A Bradbury. S Reid, T Ewings and R. Paradise. The report TRL Report TRL661 is available on the Department for Transport's website.
6.39 The research involved case studies of 20 developments across the country. Darwin Park was one of the case studies. The work included a survey of residents concerning highway issues, car parking, footpath safety and related issues, was undertaken in respect of each of the 20 sites.
6.40 Darwin Park had the second highest response rate to the questionnaires. Residents comments reproduced in the report demonstrate a number of ongoing major concerns on many sites including Lichfield about safety for adults and children, vehicle speeds, numbers of vehicles on roads, parking and lack of visibility for drivers and pedestrians.
6.41 The Council's Strategic Objective 15 High Quality Development should embrace all aspects of residential development not just the buildings. The Council should make it clear that they will agree with the Staffordshire County Council highway standards for new developments that avoid repetition of the problems in Darwin Park.
6.42 We consider the following strategic decisions are justified and should form part of the Core Strategy:
1. To reduce the housing target from 8000 to no more than 6000
2. To remove the Strategic Development Locations of South of Lichfield and East of Lichfield from the proposals.
3. To commit to fully protect the Green Belt in the Plan period.
4. To include a policy statement that the Council will operate effective controls to ensure that the maximum number allocated to a site is not exceeded and will also ensure that whilst individual phases within a site may have varying densities the cumulative total of all phases will not exceed the overall site allocation.
7.1 It is noted that because of existing commitments, principally in the form of planning permissions for employment uses, no new allocations are to be proposed. In fact, some areas are to be taken out of proposed employment use and proposed for additional housing at Fradley and Burntwood. The principle of this approach is supported at Fradley, although it is considered a greater area of land adjoining and to the west of the current re-allocation could be introduced and this would increase the housing target at Fradley further. The existing imbalance of jobs to residents at Burntwood, resulting in further out-commuting, will not be assisted by the current re-allocation proposals, and further additions to the employment portfolio are desirable.
7.2 One further element of the employment strategy is questioned, and this relates to the notion that "high value employment" can be provided through the Plan, including bringing "higher wage opportunities in growth sectors relating to business, education and research". In view of all current employment allocations already having planning permissions, primarily for B1/B2/B8 use, with a predominance of B8 Storage and Warehousing take-up continuing, particularly at the District's major allocation at Fradley, it does not appear realistic or possible for the Council, as local planning authority, to control the situation to ensure the stated aspiration can be achieved on these sites. It would only be possible to seek to address this matter through the formulation of new, carefully designated employment allocations, based on a special restrictive policy.
7.3 In terms of the proposals for additional retail and office provision, it is considered by the Civic Society that in the light of the current economic situation, as well as the need to safeguard and enhance the special historic character and environment of Lichfield City, these target figures should be reduced. They are neither deliverable in economic terms, nor acceptable in environmental terms. The impact of the very substantial cumulative totals of new development being proposed on the historic fabric and character arising will be such that the very features recognised elsewhere in the document (eg Chapter 2, Spatial Portrait) will be irreparably damaged, through the mass and scale of the new buildings, the increased congestion and the impact on the existing infrastructure, including, for example, car parking provision.
7.4 Core Policy 7 states existing employment areas will be protected and retained for employment. Statements have been made that this will include the Eastern Avenue, Lichfield employment sites. The policy does not seem to be being applied with a retail park (07/01146/FULM) having been recently approved. It is unfortunate that it appears the Council does not implement its own policies when they have an interest in the land as they did in part of this site. If the allocation of the industrial/employment land at sites such as Eastern Avenue and the Trent Valley Road area is to be changed that ought to be stated as part of the Core Strategy proposals.
7.5 Consideration should be given to locating new housing and office space within walking distance of public transport wherever possible.
8.1 The principal concern of the Civic Society, as referred to earlier in these representations in relation to Chapters 2 and 3, relates to safeguarding and enhancing the special character of the historic environment of the City. There is particular unease about the feasibility of the proposal "to balance" the special environment against "development" (paragraph12.1). This approach by the Council is referred to a number of times in the Chapter (paragraphs 12.2, 12.4 and 12.7) as well as within Core Policy 14, Our Built Environment, and Policy BE1, High Quality Development.
8.2 There is even greater concern at the contents of paragraph 12.2, which states:
"The City of Lichfield will be a place which values and enhances its rich cultural, streetscape, architectural and archaeological heritage whilst embracing visionary new landmark developments serving all our residents".
8.3 From recent experience of new development in the City centre, there is great concern as to how this aspiration relates to the development policies, given the proposed scale of development for the City centre and City. Neither is appropriate nor acceptable for a sensitive and fragile historic environment, and the whole approach should be re-considered by the Council as a matter of urgency to ensure an appropriate balance is achieved when the draft Core Strategy goes forward to the next stage. Despite the evidence of the special historic character and assets of Lichfield contained within the Historic Environment Character Assessment (Feb 2009), which is part of the Council's Evidence Base, there is every reason to seek a change in the approach and to give much greater priority to safeguarding and enhancing the historic character and environment of the City.
8.4 The potential height, massing and overall appearance of these developments is a significant issue of concern, particularly because of the conflict with Core Policy 14, The Built Environment, intended to protect and enhance the character and appearance of the City Centre and protect the skyline of the City and not to adversely affect views in and out of the City Centre and of the Cathedral. The Core Strategy ought to clarify how such policy conflicts should be resolved, particularly where the Council has a potential role conflict as landowners.
8.5 There are a number of areas in Lichfield City and elsewhere in the District, not meriting Conservation Area status but, nevertheless, possessing an environmental quality, ambience and character based on factors such as buildings layout, density, topography or landscaping which should be protected and enhanced by the inclusion of an appropriate policy and designation in the Built Environment Chapter of the Core Strategy. Examples of areas in the city would include Borrowcop, Gaia Lane, The Friary, Nether Beacon, Swinfen Broun Road, Tamworth Road and London Road. There are also likely to be other areas worthy of consideration within the other settlements of the District. Such recognition in policy terms would provide a practical interpretation of the Council's vision statement.
8.6 Another important aspect of the character of Lichfield City is the open space designated as "Framework Open Space" in the Lichfield Local Plan Policy L.49 and currently a saved policy. The policy protects these areas by providing that any new development will only be permitted for recreation and open space uses and specifies that additional restrictions apply to sites in the Green Belt. The Local Plan states "These areas of both public and private open space are a vital component of Lichfield's landscape providing an attractive contrast to the urban character of the historic city centre and surrounding residential areas." The designated sites which we agree are critical to the character of the City are:
1. Beacon Park and land to the west of the A.51 (Green Belt).
2. Land adjoining Eastern Avenue (Green Belt).
3. Minster Pool.
4. Friary Gardens and land adjoining The Friary.
5. Darnford Park.
6. Dam Street - Netherstowe `Green Corridor'.
7. Land at rear of King Edward VI School.
8. Land at Greenhill.
8.7 The Core Strategy should state that it is intended to bring forward policy proposals to designate areas where the environmental quality deserves protection and conservation and to continue the open space protection currently in place for the "Framework Open Space" sites.
Shenstone PC have managed to get a reference to their car parking problems in paragraph 4.38 on page 19 of the IDP but there is no mention of Rugeley Trent Valley Station where the problems are even more serious. Colton Parish Council has discussed the problem more than once.
Paragraph 4.39: Error. Aldridge is NOT on the 'disused' rail line between Walsall and Lichfield.
In the City centre the scale of development on the Friarsgate site and the impact upon the highway network, traffic congestion and car parking is of concern and appears to be being down played because the Council are the land owners. Of particular concern is the low level of net increase in car parking provision for the Friarsgate scheme bearing in mind the loss of existing spaces in the bus station and multi-storey car park. If successful the Friarsgate scheme would be expected to generate greater demand for parking than the scheme includes. In addition the frequent and severe daytime queuing and delays from Greenhill to the Birmingham Road roundabout junction with A51 will worsen. Linking the traffic lights and pedestrian crossings with a computer controlled management system should help but is very unlikely to resolve these problems. Our comments on the Core Strategy Chapter 6 - Infrastructure about inadequate car parking provision are equally relevant here.
The Infrastructure Delivery Plan has a comprehensive listing of requirements many but not all of which are costed. What appears to be lacking is clarity about which of these items will relate to specific developments and frequently the phrase "Throughout the plan period" is used in relation to phasing. In practice this could mean they will not be implemented because funding will not be forthcoming. The IDP more closely resembles a list of aspirations rather than commitments to implementation. The justification for some of the items, such as fire stations, solid waste collection, transfer and disposal facilities, being treated as costs attributable to new development seems tenuous.
We note with concern that there is no information provided concerning costs of the three City Centre schemes in the Economy section of the Table 4.2 on page 31.
In the IDP on page 31 Transport Table 4.1 there is £10m for Highway improvements to accommodate residual traffic. What locality does this relate to?
In the IDP on page 34 Table 4.4 about Strategic Social & Community Infrastructure - relating to Community facilities: says there is a requirement for "flexible facilities which will accommodate a variety of uses and requiring sustainable and robust management plans to be demonstrated." This presumably relates to a community hall although in the Core Strategy 'community facilities' has a much wider scope as indicated on page 52 of the Core Strategy where Social and Community section states that 'Community facilities' are 'education, healthcare, retail, community centres, sports & leisure facilities'. On the basis that the table on page 34 relates to community hall there is a need to clarify if the £250,000 for the community facilities is the building cost only i.e. it does not include land value. A guide to the cost of community hall provision is the cost of Darwin Hall in the Walsall Road development being the most up to date hall to be built in the City. The building cost for Darwin Hall was £780,000 so £250,000 seems to be an extremely low figure. Surely the specified sum for this item and infrastructure costs generally should be date related and then increased by an appropriate inflation cost index.
Lichfield Civic Society.