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

Para 9.19 reflects the 2008 consultant's report to the Council (The Offices Market, Capacity and Appropriate Locations For Growth: King Sturge). Its starting point is the target for Lichfield set out in the Regional Spatial Strategy of 30,000 square metres gross of new office floor space. 4 years have elapsed since this report was prepared, yet the changes in the economy and telecommunications do not appear to have been taken into account.

There has been a significant downturn in the economy, coupled with concomitant changes to the pattern of office based work. Not only have large office employers downsized, but home working has increased and communication technologies have ensured that workers who were desk based are becoming more peripatetic. It cannot be assumed that slavish adherence to the target of 30,000 square metres gross of new office floor space is correct. No up to date examination has taken place of alternative scenarios and what their implications would be for Lichfield City and the wider District, including the Green Belt.

Additionally, Para 9.19 is only a partial explanation of the implications of identifying a target of 30,000 square metres gross, for the King Sturge report makes it clear that the ability of the City Centre sites identified by them to accommodate new office floor space is limited to approximately 20,000 square metres, a shortfall of approximately 10,000 square metres. In paragraph 4.22 they state: "Unless other sites come forward in the City Centre, additional provision will have to be made outside the City Centre".

Therefore, in accepting a target of 30,000 square metres, the Council, the Council are implicitly accepting that 30% of the target office floor space will have to be located elsewhere. King Sturge suggested that brownfield industrial sites in the vicinity of Eastern Ave and Trent Valley Station may be acceptable, yet the Council has not assessed other options and thus set out its views about preferred locations and about the feasibility of its targets.

King Sturge has also suggested that office pressures may develop in the vicinity of the M6 Toll, potentially by an expansion of the Wall site. This is an unsustainable location for further development with negligible public transport links.

It is therefore submitted that no analysis of the alternative options for the scale of office development has be undertaken. The RSS figure has been accepted without consideration of its implications for the City, wider District and Green Belt.

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

Is the target of 30,000 square metres of office space deliverable? The King Sturge report states that the there are approximately 56,000 square metres of office space currently in the City. To add a further 30,000 square metres (admittedly over a period of 20 years), which is an increase of over 40%, in a location which is not seen by them as a highly attractive one for new office development, must cast doubt upon the deliverability of the target. There is a danger, given that only 20,000 square metres may be accommodated in the City Centre, that pressure will arise to locate the remaining 30% of floor space to out of centre sites. Whilst brownfield sites in Eastern Avenue may be acceptable, given their excellent public transport links, other sites, such as those adjacent to the Wall/A5 development, or in other peripheral locations may come into consideration. Indeed in the explanation of Policy Lichfield 3: Lichfield Economy in paragraph 13.14 it says a sequential approach to office location will be used and where no suitable City centre site exists edge of City centre locations will be considered. This raises a concern that is this policy could allow office construction on sites well beyond the City centre such as housing allocations, currently designated recreation zones or Green Belt. Alternatively, attempts may be made to "cram" higher density schemes, or higher rise buildings, into the City Centre, with deleterious effects on its historic environment.

The target is therefore highly unlikely to be delivered if the aim is to ensure that the majority of office floor space will be located in the City Centre

Paragraph 9.19 is silent on these matters and needs further expansion to set out the Council's precise policy intent.

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

Paragraph 9.19 requires expansion to unambiguously set out the Council's policy intent.

The revised wording suggested is as follows:-

In terms of office floor space, 20,000 square metres as a gross target is advocated to 2028 for the City Centre. Generally, the level of net floor space is equivalent to 85% of a gross figure. On this basis, the gross figure of 20,000 square metres would generate around 25500 square metres of new net floor space. Additionally, it is proposed that a further 10,000 square metres gross (85,000 net) be sought on brownfield sites in sustainable locations within the City's wider urban area. Any new development within the City Centre will need to ensure that the integrity of the historic centre is not undermined.

Policy Lichfield 3: Lichfield Economy concerning the sequential approach to office locations needs to be clarified by the a revision of paragraph 13.14 to give effect to the following:-

The sequential approach outside the City centre will only relate to brownfield sites or sites allocated for or currently used for employment purposes and not housing, recreation allocations/open space or Green Belt.

Roger Hockney
President,
Lichfield Civic Society.
September, 2012