Q4. Do you consider that the Local Plan Strategy is justified? - No

It is considered this Policy is too weak and inadequate in terms of protecting and enhancing the special character and historic assets of Lichfield City and City Centre. Overall, the policy gives this important matter too little priority and weight, despite a number of references to the importance of this elsewhere within the document. The Policy, as drafted, along with Policy BE1: High Quality Environment, is inadequate to deliver the "positive contribution" required of development in environmentally sensitive or vulnerable locations.

This concern will be elaborated by showing discrepancies within the document as drafted. A fundamental point in Chapter 2, Spatial Portrait, is the statement in paragraph 2.5 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". It should, therefore, follow as fundamental, that the policies and approach put forward subsequently in the Local Plan Strategy emphasise the importance of safeguarding and enhancing this character overall and its constituent parts.

It is a principal concern that this need for safeguarding and enhancing the historic built environment is not addressed effectively, and that the policies and proposals of the Local Plan fail to achieve even the minimum requirements. Inadequate weight is given to the unique and special character of the area as referred to in the Spatial Portrait. There is significant and unacceptable conflict within the Council's approach, between the Spatial Portrait, Strategic Objectives 14, Built Environment and 15, High Quality Development 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 tension is very largely ignored, and certainly not addressed in an adequate or satisfactory manner in the Local Plan Strategy.

Again within Chapter 3, Vision, inadequate weight is given to the importance of the historic character and environment of Lichfield City Centre, and the fundamental aims of achieving protection and enhancement. It does not to fully recognise the significance and importance of the area in terms of the historic environment and the need for appropriate policies to protect, enhance and manage change effectively. The importance of such special areas was recognised in the policies of the WMRSS (2008) in Policy QE5: Protection and Enhancement of the Historic Environment, which states:-

"A. Development plans and other strategies should identify, protect, conserve and enhance the Region's diverse historic environment and manage change in such a way that respects local character and distinctiveness.

B. Of particular historic significance to the West Midlands are:

ii) historic urban settlements, including market towns and cathedral cities;"

The description contained is directly applicable to Lichfield, and this recognition at a regional level of the importance and significance of places with special character like Lichfield and the need for appropriate policies requires to be incorporated into the Local Plan Strategy with similar emphasis.

The current proposals for unacceptably large scale retail, office and housing development within the City and City Centre is potentially jeopardising the special character that now exists, and policies giving far greater weight to the importance of the historic environment are required to be included in the Plan to ensure that the character and heritage assets are not degraded. A report, The West Midlands Environment Priorities Review (WMRA, 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 being made for Lichfield City is precisely the sort of threat referred to in the regional report. Hence, a re-balancing of policy priorities is necessary.

In relation to Policy CP14 and its justification contained in Chapter 12, Built Environment, there is concern, already expressed above, that, despite recognition of the special and important historical environment of the City elsewhere in the document, there is a lack of weight and priority given to its protection and enhancement within the Policy. There is, in fact, very limited reference to Lichfield City. It is noted in paragraph 12.7 that there is concentration on maintaining views of the five spires and concern for safeguarding views of the skyline, but little else of substance. In fact, the paragraph concludes by suggesting that these views from outside will be retained or integrated in development "in most instances". This appears to be very muted protection and enhancement. Although paragraph 12.8 contains a statement of aspirations, its acceptance of long term development pressures on the City Centre is a major concern, particularly in light of the content of the Policy and lack of priority given to the historic environment of the City Centre. It is believed recent experience of permitted developments and their impact justifies these concerns.

Q5. Do you consider that the Local Plan Strategy is effective? - No

For the reasons described in Q4 above.

Q7. Please set out what change(s) you consider necessary to address your representations.

Giving greater priority to the importance of the historic assets of the City and their protection and enhancement would address the Society's concerns.

The following paragraph should be added to Core Policy 14:Our Built Environment as a new third paragraph:

"The outstanding and nationally significant qualities of the built historic environment and all aspects of these historic assets of Lichfield City will be afforded priority by the District Council in all decisions by the District Council affecting the area to ensure their protection and enhancement."

Q8. Did you raise this issue earlier in the plan preparation process? - Yes

In a letter from the Lichfield Civic Society dated 26th February 2011 on the draft Core Strategy we sought a stronger commitment from the Council towards protection of the historic character and environment of Lichfield City Centre in the following terms:-

"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)."

Q10. If you wish to participate at the examination in public, please outline why you consider this to be necessary.

Because of the importance of the issue to the people of Lichfield and the members of the Lichfield Civic Society, which was established over 50 years ago in order encourage the protection and enhancement of the historic assets of the City and to promote good design.

John Thompson
Chairman,
Lichfield Civic Society.
September, 2012