|Lichfield City Neighborhood Plan|
Mr Tony Briggs
Dear Mr Briggs,
Lichfield City Neighbourhood Plan 2016-2029
The Society welcomes the initiative of the City Council in proposing this plan and the opportunity to comment on it at this stage. However, the Society has a number of concerns relating to the current document which it would wish to be addressed by the City Council prior to final adoption.
The points of concern are included in the remainder of this submission:
Scope of the Plan
The decision to prepare an "economic development" based neighbourhood plan for the City is considered to be somewhat unusual and is, in many ways, too narrow and restrictive in its scope and area of concern. Within the City area it does not enable a sufficiently comprehensive approach to be made in tackling issues in the planning of the City. Furthermore, because of the tightness of the City boundaries, and hence the plan boundaries, it excludes consideration of closely related and relevant locations, e.g. Streethay and Fradley. Another aspect of the scope and content is that much of the plan is concentrated on the City Centre. No reference is made to employment areas such as Eastern Avenue and Trent Valley where long standing employment land allocations are changing to retail or housing. Similarly, there is no consideration of the potential and most appropriate uses for the new commercial facilities to be provided on the Deans Slade SDA alongside the Birmingham Road and junction of the proposed southern bypass.
There are a number of worthy aspirational statements included in the plan, but the practical steps for delivery of these, and in particular the lack of any information concerning financial resources for their achievement, is of concern. Allied to this, a number of matters and suggestions are raised, and then left unresolved or incomplete in the document.
One matter of critical concern to the Civic Society is the inadequate acknowledgement of the importance of the unique environmental and historic character (the Heritage asset) of the City Centre compared with the case being made for economic development. Simply put, if tourism is to bring about a great increase in visitor numbers to the City, we cannot justify eroding that asset by inappropriate design or over-development in the form of inappropriate levels of housing, retail and office detrimental to the existing character of the City. The plan should include explicit support for safe-guarding and enhancing the environment and historic character of the City Centre as a priority in the plan objectives in paragraph 3.3.
The scale, height and materials used in new buildings and restoration work in the City Centre and Conservation area is not considered in the Plan. There are several recent examples of buildings the height and scale of which dominate neighbouring properties and have used metal materials on the facade and roofing which starkly contrast with traditional materials used in the adjoining properties and the City Centre generally.
The Plan should indicate that developments should be of such a scale, height and finished in materials that is consistent with the inherent character of properties in the City Centre and Conservation area unless there are exceptional reasons to justify alternative proposals.
The suggestion for promoting office development within the Cricket Lane SDA employment area is welcomed, but does not go far enough. Based upon recent District Council Employment reports, which state that high paid, quality jobs in office-type developments are required in the City, and that there is very limited need for additional industrial or warehousing and distribution in the District, it is the view of the Society that the whole of the employment area should be safeguarded for office uses. This approach would be environmentally and visually much more compatible with the adjoining proposed housing area and siting at the sensitive gateway location to the City. Along with the suggested hotel and leisure development, the area could accommodate and satisfy the City's office requirements over the Plan period. We recommend that Policy 1 is modified accordingly.
There are concerns in relation to the proposals made in the plan in relation to "movement routes". The main concern with Policy 4 on Primary Movement Routes, which is sound in principle, is the scope of the routes defined in Figure 5.1 and the unnumbered Figure on the following page. Although the wording appears strong, their delivery seems unlikely and the routes indicated are either not suitable or are impractical particularly for routes from the south of the City into the Centre. Significant areas of the City do not have movement routes shown into the City. This includes access into the Centre from the south of the City, the north of the City such as Stafford Road, Beacon Street, the Dimbles, properties off Eastern Avenue and also access from Trent Valley. These areas should be indicated as being served by primary movement routes. The recent appeal decision permitting housing on the Eastern Avenue site on the corner of Watery Lane underlines the need for a safe movement routes for all areas on the City's edge.
It is the view of the Society that a detailed and feasible network of cycle and footpath routes should be prepared by the relevant authorities and given high priority for implementation, as well as being included in this plan. There seems to be an opportunity at this time for a number of these to be funded / provided in conjunction with the various about-to-be-approved SDA sites if the routes were to be properly defined. A secondary but important concern is the timing of provision of safe pedestrian and cycle routes for new development to the main points of access and the City Centre. The provision for Darwin Park illustrates clearly that unreasonable delays occur. On Sainte Foy Avenue the two crossings needed were provided well after most of the development was completed on Darwin Park and Falklands Road/Chesterfield Road sites. Similarly, the crossing outside the former Victoria Hospital site was much delayed. Continuity of a safe route into the City Centre for these sites is an issue which is still outstanding. The newly designated shared footpath for use by pedestrians and cyclists along Birmingham Road ends at St John Street where there is no phase in the traffic lights for safe crossing of St John Street.
We recommend that Policy 4 ought to indicate that the provision specified in Policy 4 for new developments is to be provided at an early stage in the development of the site and provide continuity into the City Centre. This could be reinforced by including in respect of the Cricket Lane SDA by the following addition to Policy 1: "Safe pedestrian and cycle routes, including light controlled crossings, to and from the City Centre shall be provided at an early stage in the development of the site".
Section 8 of the Plan refers to two sites of redevelopment potential within the City, namely Bird Street Car Park and the "former Quonians site". These are recognised as being of importance in the future of the City by the Society, but not necessarily for the same reasons as suggested in the Plan; e.g. the statements in the Plan that the site is on a critical pedestrian route to the Cathedral from the rail and bus stations is not accurate, as it is peripheral to the main route along Dam Street. Concerning the Bird Street site, this is currently an extremely important car park within the City Centre, and probably the most important of all. Its loss to built development would be detrimental to business in a major section of the City. At present the Plan contains a multitude of proposed uses for the future, many of which, even assuming the loss of car parking can be addressed satisfactorily, would destroy the "Heritage asset" of this unique location rather than enhance it. The site's relationship to Minister Pool and the Cathedral and the strategic open corridor running between Beacon Park and Stowe Pool and beyond in either direction should be the Plan's primary objective for the future, rather than as an economic development site. Retention of a large area as a public square or open space is essential to retain the amenity value of the current openness and views and should therefore feature as one of the proposed uses for the site. The Society made comment on the visual prominence of the site and critical importance of making the right decision for the future of the area in a submission to the draft City Centre Strategy, and this is now repeated.
The future proposals for the Quonians site seem to be much less contentious, and, subject to appropriate and high quality design, the uses being suggested should enhance that part of the City. However, the future of two substantial sites in that general area need to be considered and included in the Plan before adoption. These are namely, the former What site and the former Regal Cinema/KwikSave site. In fact, the future of this whole backland area needs consideration in its planning, and should be included in this Plan.
An issue not considered in the Plan is the under-use of many upper floors within the City Centre. As these are both a wasted resource and a cause of poor maintenance, affecting the integrity of the historic fabric and leading to environmental harm, this should be addressed in the Plan. Residential re-use would be a principal potential approach at a time of significant levels of housing need in the District. In the past there were initiatives at national and local level with grant schemes to address the issue and such an approach should be considered anew.
Whilst the broad approach in the plan to economic development is sound and includes issues such as tourism and signage the importance of achieving and securing high standards in the local street scene is not sufficiently covered. Maintenance of footpaths, paved streets, grass verges, street furniture, direction signs and replacement of dead and dying trees in highway verges are cumulatively important issues in the attractiveness of the City for investors, established businesses and visitors. There is a need for improved co-ordination between the three tiers of local government to address these issues. A commitment from the City Council to proactively support these issues and where necessary use CIL monies to enhance the City centre and the street scene would be extremely helpful.
There is no reference to the City Council working with the voluntary sector on issues in connection with the conservation and enhancement of the City.
The comments in paragraph 5.7 mention a modification to the traffic regulation order and reduction in 'off-street' car parking in the pedestrianised area but makes no mention of the desirability of extended controls to reduce 'on street' parking, traffic passing through or improved traffic management or enforcement.
The reference to Sandfields Pumping station in relation to water supplies sourced from the City could be extended to Stowe Pool which was constructed by South Staffordshire Water. Stowe Pool is part of an initiative by the District Council to secure a HLF grant.
If you wish to discuss any of these matters, we are very happy to do so.