The Lichfield District Local Plan |
Car Parking Strategy
|Consultation response by the Lichfield Civic Society|
Q4. Do you consider that the Local Plan Strategy is justified? - No
Absence of a car parking strategy
The Local Plan Strategy makes no reference in Chapter 6 on Infrastructure Provision or Chapter 7 on Sustainable Transport to the need for or an intention to formulate 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 Strategy for the following reasons:-
The scale of housing proposed in Lichfield City and commercial development on three major sites in the City will add to the already congested local road network and increase the problems associated with on-street car parking and increased demand for car parking. Whilst aspirational statements in the Strategy about encouraging use of public transport are welcome the current proposals will have a negative rather than positive impact. The existing bus station capacity is being dramatically reduced by the approved but not yet commenced Friarsgate redevelopment scheme and as yet the Council have failed to identify a suitable location for all the coach parking facilities being displaced by the Friarsgate and Friary Outer car park developments.
In paragraph 4.9 of the Strategy it is stated that:
"Lichfield City is our principal centre and as such this is proposed to be the focus for major growth in town centre uses, such as shopping, offices and leisure activities, as these serve a wider area than their own immediate population."
This policy should be matched by strategic consideration of scale and configuration of car parking provision to accommodate the major growth indicated in the Strategy. Policy Lichfield 3: Lichfield Economy on page 99 provides for up to an additional 36,000 sq.m retail and 30,000 sq.m of office accommodation. The historic centre of the City requires careful planning to ensure compliance with conservation and sustainability objectives in the Strategy as well as improving the quality and safety of car parks to comply with NPPF policy 40.
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:-
The consequences of the substantial under provision of car parking for the scale of development in the Friarsgate scheme is not mentioned anywhere. 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 temporarily leasing back.
Bird Street car park because of its location and it being a surface car park is the most popular and heavily used car park in the City. 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.
Lichfield District is part of a three tier local government structure. The split of responsibilities in relation to planning, car parking and public transport underlines the need for a co-ordinated and strategically planned and agreed approach to the scale of provision, management and car parking consistent with other policies regarding the historic character of the City.
Implementation of proposals recently discussed to ban disabled on street car parking in the City centre to improve safety and the environment for pedestrians will displace disabled users to public car parks reducing the capacity there for other users.
The discontinuance of the Local Plan saved policy Lichfield L28 Commuted Payments which has been used to obtain commuted sums for additional public car parking provision where consent is given for developments unable to provide onsite car parking will in future for such sites increase the demand for parking without providing the funding to meet the shortfall in on site provision.
There appears to be no realistic attempt to deliver public transport as a mode to substitute for the lack of future car park capacity. The substantial reduction in scale of the bus station facilities which will occur if the Friarsgate development proceeds will reduce capacity and constrain future growth in bus and coach services.
Our view is that without a comprehensive and coherent car parking strategy for the City the Core Strategy is unsound.
Q5. Do you consider that the Local Plan Strategy is effective? - No
For the reasons set out in Q4 above.
Q6. Do you consider that the Local Plan Strategy is consistent with the National Planning Policy Framework? - No
The NPPF imposes an obligation to seek to "improve the quality of parking in town centres so that is convenient, safe and secure including appropriate provision for motorcycles" (paragraph 40). For the reasons outlined in Q4 above the absence of a car parking strategy fails to address one important element of developing sustainable transport policies for the City centre.
Q7. Please set out what change(s) you consider necessary to address your representations.
To include in section 6 on Infrastructure Core Policy 4 or in section 7 on Transport Core Policy 5 a commitment to the preparation of a parking strategy which considers the scale and location of City centre public car parking provision required to meet the needs during the plan period to accommodate demand generated by additional development or growth in tourism or other leisure activities.
Suggested wording is set out below:-
The District Council will, in co-operation with the County Council, review the scale and location of City centre public car parking that is needed during the plan period to accommodate planned development and growth in visitors with a view to formulating a strategy to ensure there is adequate accessible, quality car parking available to meet the needs of all City centre users including the disabled. The Council will undertake public consultation before finalising the strategy.
Q8. Did you raise this issue earlier in the plan preparation process? - Yes
The omission of car parking strategy was raised in a letter from the Lichfield Civic Society dated 26th February 2011 on the draft Core Strategy. The majority of the points made in this representation were in that letter. We are not aware of the reason(s) why the Council rejected the proposal we made.
Q10. If you wish to participate at the examination in public, please outline why you consider this to be necessary.
We consider the long term scale and provision of public car parking should have been considered alongside decisions on the scale of housing, retail, commercial and leisure development the City is expected to accommodate. Problems of on-street car parking in and around the City centre particularly in residential streets are a source of concern and inconvenience. Factors affecting car park usage include the level of charges, the quality and perceived safety of public car parks. If the Council is resisting this proposal they should publicly state the reasons why.