Spatial Policy & Delivery
Response from Lichfield Civic Society to the
Policy 1: Cricket Lane Strategic Development Allocation
The aspiration to seek provision of office development and complementary uses, including hotel accommodation and health and fitness centre facilities, at this location is supported. The scale, appearance and environmental impact of these is much more appropriate for this sensitive "gateway" to the City from the strategic highway network than locating B2 industrial and B8 warehousing buildings here. Furthermore, office development will constitute a much more acceptable immediate neighbour to the adjoining residential development which is proposed within the remainder of the Strategic Development Allocation (SDA).
The suggestion that this office development could accommodate spin-off research and development, and related activities, from the nearby strategic headquarters of the Defense Medical Services, Whittington, seems well-founded and should be pursued as an effective way of retaining and growing the type of high-quality employment which both the Neighbourhood Plan and the Local Plan are seeking.
The Society's only concern is that this aspiration for significant office development here may be difficult to deliver unless the public sector authorities become actively involved in its promotion and provision.
The Policy also refers to routes linking the SDA to the City Centre and elsewhere in the City. This element of Policy 1 is considered and a response made under Policy 4: Primary Movement Routes.
Policy 2: Managed Workspace
This Policy is supported in the right locations and, for example, the Cricket Lane SDA would be one such appropriate location that the Civic Society consider is suitable. However, it is considered that the proposal made elsewhere in the Plan that such uses are acceptable as part of the development of Bird Street Car Park is not acceptable and a detailed response to this is made under Policy 12: City Centre Redevelopment Sites. The issue of avoiding the loss of open space on the Friary site adjoining the Campus is raised in our comments on Policy 3.
It is, however, also considered that such provision would only be likely to be achieved if the public sector were fully involved.
Policy 3: Lichfield Business Village, University of Staffordshire Campus
In principle, this Policy is supported provided it does not result in further significant loss on this site of the area of open space, which under the previous Local Plan was designated as Framework Open Space and protected from new development other than for recreation and open space purposes. The issue of protection and adding to the open space corridor running across the City and City Centre is also raised in our comments on Policy 12. It should be noted that the main public car park adjoining is on part of the former school playing field that was given consent as a temporary use.
Progression of the Business Village proposal may again need public sector backing to succeed.
Policy 4: Primary Movement Routes
This policy is supported in principle, but certain of the route alignments proposed and shown on the map are not considered to be acceptable and could more appropriately be located to ensure attractive and safe pedestrian and cycle movements could be achieved. One route of concern is that proposed from the Cricket Lane SDA (referred to within Policy 1) along Upper St John Street, presumably via London Road, towards the City Centre. This route is constrained, congested and polluted, and considered to be inadequate and unattractive for both pedestrians and cyclists. An alternative to this could run via Shortbutts Lane, Pasco Drive, Dovehouse Fields, Ivanhoe Road, and either / or both along Friary Avenue or Birmingham Road to the City Centre and Railway or Bus Stations.
The key nodes of conflict are not comprehensive and it ought to be extended. Two examples illustrate this issue:
a. The crossing in Bird Street on the bend with the junction with Swan Road is dangerous for pedestrians and cyclists. It is the principle route between the City Centre and the award-winning Beacon Park. It is also the crossing point on the National Route 54 of the National Cycle Network from Stourport to Derby. Following complaints we have raised this matter with the County Highways service, as have the Beacon Street Area Residents Association.
b. At the St John Street / Birmingham Road junction the crossing from Birmingham Road to the City Centre has no pedestrian refuge, nor do the traffic lights have a phase for pedestrians or cyclists to cross. A central refuge outside St John's Hospital alms houses that was set back from the junction was removed, making crossing the road particularly hazardous because there are no periods of stationary vehicles long enough to cross with any certainty of being safe. This crossing is on a designated cycle route. The crossing usage has increased substantially since the new housing developments off Chesterfield Road, Falkland Road and Saint Foy Avenue. The Friarsgate shopping and leisure development, and relocation of the bus station, will further increase pedestrian usage.
On the wording of Policy 4 relating to developer contributions we consider it is unnecessarily restricted to CIL contributions. The greatest impact on Primary Movement Routes will arise from the SDA's where the CIL charge is only £ 14 /sq.m. We consider that if the works required directly arise from a SDA then section 106 contributions should also be mentioned in the Policy as a potential funding source for the works.
Policy 5: Signage
Tourism is recognised by the Society as an important element in the economy of the City, but the Society considers insufficient positive proposals are included in the Plan both for the future and to resolve current failings. The proposal to improve signage is welcomed, but it is considered there are many other elements in the City Centre requiring positive action based on explicit policies that should be included in the Plan. Various examples can be put forward including improved heritage interpretation signs and boards, general and widespread improvements to many elements of the street scene, such as landscape and street furniture maintenance and renewal.
A significant negative element within the City Centre at present is the "pedestrianisation" scheme which is inadequate and in need of review.
Policy 6: Pedestrian Linkage of Friarsgate with the rest of Lichfield City Centre
The Society support this Policy in principle, since enhanced linkages and improved conditions for pedestrians is certainly desirable, but is concerned at the possibility of Friarsgate drawing shoppers away from the rest of the shopping area, leading to an adverse impact on the retailers in those areas. Additionally it should be recognised that the present "pedestrianisation" scheme is imperfect, adversely affecting pedestrian links, and its defects should be reviewed and the scheme revised.
The suggestion that the development of Bird Street Car Park can assist in improving links between Friarsgate and the Cathedral is questioned, since Dam Street is the direct route and the Car Park is off-set from this line. Further detailed consideration of the whole approach to this link and the future dvelopment of the Car Park is vital.
Please see out comments on Policy 4: primary Movement Routes regarding pedestrian links to Friarsgate from Birmingham Road.
Policy 7: Non-retail Uses in the Retail Area, Lichfield City Centre
Although this approach recognises the decreasing demand / need for retail space in town centres, the Society is concerned about potential adverse effects of such a policy if carried out to extremes; e.g. an excessive proliferation of cafes, restaurants and, particularly, coffee shops. It would be of concern if the retail proportion of ground floor uses across the core was so diminished that the City Centre became dominated by subsidiary activities and uses, to the overall detriment of the Centre's attractiveness to shoppers.
An issue that requires more emphasis in the Plan relates to the significant areas of upper floors in the City Centre which are unused or under-used. These, along with empty premises within the core, need positive policies and actions urgently to bring them into use, to address various issues resulting directly from the underuse at present, not least lack of maintenance which is harming buildings in the historic core. Residential re-use of upper floors has been a policy persued successfully nationwide in the past, and the introduction of a re-invigorated policy would bring many benefits to Lichfield. These benefits would include environmental gains, the provision of additional residential accommodation and added life and activity to the City Centre.
Policy 8: Tourism and Cultural Industry Employment
The Civic Society support this Policy, but would wish to emphasise that "tourism" will only continue to grow if the unique and special character of the "Heritage Asset" of the City and historic Core is not only safeguarded but enhanced, and not over-whelmed by new development which is of a scale and appearance out of character and not in keeping with the essence of the Attraction.
A further element necessary to support growth of the tourism and cultural industry relates to the need to maintain and improve the quality of the "public realm" in all its aspects.
Policy 9: Linkages with Lichfield Cathedral
The Civic Society support this policy but, as Dam Street already provides the most direct line from the City Centre to the Cathedral, would query how development of Bird Street Car Park can improve this linkage since it would be a diversion away from the direct line. This point is raised in our second paragraph relating to Policy 6.
It is the view of the Civic Society that there are other points along the line of the route between the Railway and Bus stations and the future Friarsgate development that require improvement to encourage ease of movement for pedestrians. See our comments on Policy 4: Primary Movement Routes.
Policy 10: Views of Lichfield Cathedral
The Civic Society support his Policy, but consider there should be a widening of the approach to ensure that views of and across the City Centre and the "Heritage Asset" are safeguarded and enhanced in a more comprehensive manner.
We are concerned that insufficient regard has been given in the recent past to protecting views of the Cathedral, and it is essential this situation is not continued. English Heritage (now Historic England) justifiably raised objections to the impact on Cathedral views of the housing, multi-storey car park and hotel development on The Friary which the District Council as land owners and local planning authority ignored.
Policy 11: Hotel Provision
The Civic Society consider the most appropriate sites for new hotels are within the Quonians Lane site and the Cricket Lane SDA. Too many potentially conflicting uses have been suggested for the Bird Street Car Park, including a hotel, and, therefore, this element is opposed. Comment is also made concerning the Bird Street Car Park on Policy 12.
Policy 12: City Centre Redevelopment Sites
The Civic Society has great concern about the development ideas expressed for the Bird Street Car Park. We consider that too many uses are being suggested in the Plan and this is not helpful as it may lead to the wrong mix, an over-intensive development or incompatibility between uses. Neither Hotels nor Managed Workshops are considered appropriate for inclusion in this site, particularly as there are various better alternatives available for these uses.
One significant omission from the Policy is the failure to require the development to contain provision for a significant public open space / events space, complementing and adding to the open space corridor running across the City and City Centre following the line of the Pools. In the opinion of the Civic Society this is a fundamental principle which should be incorporated in any future development of this site. As mentioned in our comments on Policy 3, the Framework Open Space policy in the Local Plan was an important safeguard of the open space corridor across the City. The environmental principle should be maintained and if the Bird Street site is redeveloped it should exploit the potential to enhance it.
If the Bird Street Car Park development cannot accommodate all the current and additional needs of the redeveloped site it raises again the issue of the absence of a parking strategy for the city in the Local Plan. Housing growth in the plan period combined with additional shopping and leisure provision, e.g. in Friarsgate, underlines the need for this to be addressed.