Spatial Policy & Delivery Team
Lichfield District Council
District Council House
Frog Lane
WS13 6YZ

Response of Lichfield Civic Society to the
Local Plan Allocations open consultation.

Dear Sir/Madam,

1. The Civic Society wish to submit comments in relation to the Consultation document. Although there are a number of detailed points to be made later in this submission in relation to the contents of the document and questionnaire, the Council is also requested to commence early consideration of the longer term situation of the District, the implications now emerging from various quarters and directions and the strategy for dealing with these in a positive and planned manner. A need for this approach is being generated by certain issues raised in the Consultation document, as well as from local and sub-regional changes since the Local Plan was prepared and adopted.

2. It is appreciated that a Plan Review may be, as yet, sometime into the future, but the Society is concerned that a number of issues need to be examined and implications comprehensively addressed in advance of that to ensure the best outcome results.

3. A principal issue arises as a result of the Consultation document seeking to consider Green Belt in the light of "development needs beyond the Plan period". The current Local Plan resulted in a significant loss of environmentally sensitive and long-established Green Belt areas adjoining and to the south of Lichfield City (namely land at Cricket Lane and at Deanslade Farm).

4. For the future the Society considers this approach is inappropriate and should not be the on-going strategic policy for the District for the future. There are no further Green Belt areas suitable for development close to the City to the south, west and east, and any such proposals would be contrary to the majority of the stated purposes of Green Belt. It would be a piecemeal and incremental approach to the detriment of the whole City and District which should be avoided and should be replaced by a more strategic approach.

5. Any further development needs in the District will require in-depth consideration of non-Green Belt locations, which are, or can become, sustainable for long-term housing and mixed use development. The District possesses substantial areas satisfying this criteria, and particularly suitable is the area around Fradley/Alrewas/Brookhay, which is both non-Green Belt and separated from the City. This area's potential as a growth area should be fully assessed because it is considered it could be the most sustainable location in the District for future development of housing and employment to satisfy future needs. The area has the potential in its own right for being a growth point, and in the long term to act as a more sustainable and appropriate alternative to Green Belt releases in the more environmentally sensitive and vulnerable areas of the District. This general area was included for significant development in earlier Structure and Local Plans, and then not progressed, and it was also recommended more recently by the West Midlands Regional Spatial Strategy Examination-in-Public Panel as an appropriate location for consideration for development as an alternative to Green Belt releases around Lichfield City. To date, this assessment has not been progressed. Development in the suggested location could be supported by new and improved rail infrastructure (including extension of the Cross City service from Birmingham, links to Burton, Derby and Tamworth, and new railway stations on the route), as well as express bus services along the A38.

Other Comments

6. In response to Question 2, it is agreed that the amount of retail and office development proposed in the Local Plan should be reviewed. The very slow rate of delivery of these uses to date has brought into question the original scale of these proposals. The original proposals for these uses always seemed excessive, and when large numbers of housing units are added to the total development, there was unlikely to be sufficient capacity within the City Centre to accommodate this within an environmentally sensitive Historic Centre. When the review is undertaken it is considered that, if the scale of office development remains substantial, policy should be clarified to direct a significant proportion to the Cricket Lane SDA employment area, which could act as a very suitable alternative location and be more environmentally appropriate than industry or warehousing.

The draft Neighbourhood Plan of the City Council, recently the subject of public consultation, makes specific proposals regarding office uses on the Cricket Lane site. The Society made the following representation on the draft Plan "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." Our view is that the City Council's approach on office provision at Cricket Lane should be supported by the District Council and widened to the whole employment allocation.

7. In response to a further issue raised under Question 2, it is also agreed that the Primary and Secondary Retail Areas as presently defined should be reviewed. The extent and boundaries of each zone should be such that they are forward-looking and positive, rather than being simply an expression of the current situation. With the cumulative effect of change affecting almost all constituent elements in town centres (including the growth of e-retailing, the spread of food and drink outlets and leisure activities, decrease in high street banking, etc., and increased residential accommodation) there is a need to re-consider the so-called Retail Areas.

8. One additional issue, not specifically raised in the questions, that the Society considers should be reviewed is that of timing of delivery of infrastructure in relation to development. This needs to be reviewed at an early date because of unacceptable anomalies. The current Policy CP4 'Delivering our Infrastructure' is directly relevant to this matter and states clearly at paragraph 6.5 that supporting infrastructure should be delivered "alongside" development. One example of concern where this is going to fail relates to the provision of the Lichfield Southern Bypass and the Lichfield South development. The Council approved, subject to S.106 Agreement, the housing development without completion of the Bypass, and with only a sub-standard access arrangement in its place. This was seemingly because the Bypass was anticipated as being much delayed compared with the then housing programme. As the Bypass planning and preparation is now advancing compared with that of the housing, the opportunity presents itself for the two to be tied closely together and require the completion of the whole Bypass prior to the housing development, thus complying with Policy CP4 and removing the sub-standard access from the scheme.

Yours faithfully,

John Thompson
Lichfield Civic Society,
9th October, 2016