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Development Control Manager Planning Application No: 17/01191/OUTMEI Deanslade Park Project Land, South of Falkland Road, Lichfield Response from Lichfield Civic Society 1. Meeting the strategic aims and key design principles for the site as set out in the Local Plan Initial impressions of the proposals are that they deliver on the strategic aims and requirements for the site. However, following consideration of the detailed proposals of the development it is evident that there are some important aspects of the design that, to a material degree, fail to fully meet the aims of the allocation and the design concepts. Whilst the requirement to provide about 450 houses is exceeded by 25, accommodating this increase may be a factor in the failures on other requirements. Collectively the shortcomings indicate the need for changes and improvements. Some examples of issues of concern, as listed below, are mentioned in more detail in the main text of this representation. The design concept for the 'extensive district park' is that the "Development will provide easy access to a large new area of open space for both new and existing residents of Lichfield City". This is not true for the Country Park. It has been designed to only be accessible by car through the development with limited and inadequate car parking provision. Seeking to restrict or limit access by car users is inconsistent with the intended purpose of the allocation. The strategic sports site is also only accessible through the site although it is to serve a wider area. No attempt is made to implement the design principle of retention of the hedgerow which is an important characteristic of the A5127. The unduly cramped and visually unattractive configuration of the affordable housing should be improved. The visual impact of car parking particularly in the affordable housing locations is inconsistent with the design criteria to "ensure limited impact on visual amenity and residential privacy". 2. Phasing and section 106 agreement Phasing. A key issue is the phasing and timescale of providing, laying out and allowing access to the countryside park and play areas. The developer's record of accomplishment on delivery on Darwin Park was extremely poor and these issues need to be addressed and legally binding commitments entered into. There is no reference in the draft Heads of Terms for the section 106 agreement to phasing of the housing or the related infrastructure. Based upon the Darwin Park approach it seems likely the developer will leave provision of open space, play areas, street lighting, highway and sewer adoption and bus stop and shelters unreasonably late in the overall development of the site. Section 106 and public open space. If the ownership of the public open space and trees in the development is to be the management company proposed by the developer then it, or whoever is the owner, should hold it in trust for that purpose. The site owner should be a party to the section 106 agreement so that they are legally accountable for ensuring public access is available and for ongoing maintenance of the matters within its control and ensuring compliance with any relevant planning conditions. Presumably the developer will provide an endowment to the management company for the responsibilities for maintenance of the land. There should be legally binding obligations in place to ensure proper maintenance and free public access is guaranteed in perpetuity to the countryside park, open space and play facilities. 3. Off-site works associated with the proposed development The extensive documentation accompanying the application is predominantly focused on the site and its immediate environs. Further consideration and provision needs to be made for the impact of the development on the wider network and specific works undertaken or funding contributed to works beyond the site and improvements to ensure safe routes into the City centre for pedestrians and cyclists. Roads serving the development. To cater for vehicular traffic from the development, there is the need for a contribution to the provision and completion of the Lichfield Southern Bypass from Birmingham Road beneath the railway to connect with the committed section of road across the St John's (South of Lichfield SDA) site. In addition there are concerns about the extent, if any, to which the development will contribute financially to off-site works, e.g. the canal bridge at Claypit Lane. Walking and Cycling. The applicant suggests that the site is well accessed from the neighbouring built up area and so their cycling links and walking links will be utilised. The proposals are not convincing. There is a need for contributions for provision of direct and safe footpaths and cycleways between the site and the City Centre, the education sites serving the area (especially secondary schools), the bus and train station and the employment sites within the City. The transport assessment and safety audit has not recommended provision of pedestrian light controlled crossing points for pedestrians and cyclists moving to and from the site. It became evident with Darwin Park that such crossings were essential on Sainte Foy Avenue and on The Friary although located within a 30 mph zone. Traffic on Birmingham Road and Falkland Way, which is subject to 40 mph restrictions, tends to be fast moving particularly traffic on the A5127 entering onto Falkland Way. For children, young persons and the disabled controlled crossings ought to be planned and funded by the developer not left to the highway authority when pressure for provision emerges from users. There is a need for early provision of a direct and safe footpath and cycleway connections between the Deanslade Farm and St John's development areas. This should include both the footpath/cycle routes illustrated in the Access and Movement exhibition plan in 2015. This should include upgrading the agricultural use only bridge across the Cross-City line to facilitate a pedestrian and cycle route between the Deanslade Farm SDA, St John's (South of Lichfield SDA) and Cricket Lane. Public Transport. The Travel Plan is a long-winded document. It mostly tells us what's there now but it is imprecise over detail. As far as bus services are concerned, the applicants are floating a Lichfield-Darwin Park-Deanslade circular service every half hour. The operators are not averse, but we wonder how it will be funded? Otherwise they list services which are "easily accessible at the bus station". This statement is misleading because the distance from the development to the bus station is such that it is not easily accessible on foot. Apart from the proposed circular route there is little incentive for residents to use other bus services. 4. On-site highway and car parking issues Safety on shared surfaces. The transport assessment states: "Shared surfaces have been incorporated into the layout to encourage low vehicle speeds, ease of movement of people and people friendly quality spaces". The extensive use of shared space and private drives is also motivated by the space and financial saving by the omission of public footpaths and meeting adoptable standards. The extent of shared space provision looks to be excessive. Concerning the 'Block paving areas (Adoptable)' they are shown with a dotted line indicating a footpath area on each side of the road. Is this line to be marked on the road or just a presentational illustration? The Darwin Park experience for residents of shared space on parking and safety concerns was highlighted in the Manual on Streets Research initiated by the Department of Transport. An extract from that report is enclosed as an Appendix. Although the design of Deanslade Park sensibly omits 'courtyard' parking the issues of on-street parking generally is still highly relevant to this site. Concerns for residents can arise from several issues including: where houses have more cars than the spaces provided; the school run and parking and ensuring pedestrian safety especially for children, the blind and disabled. It is not clear that the layout provides for the needs of businesses for deliveries, providing maintenance services at households or unobstructed access for buses or emergency vehicles. More generous parking provision could be made in the visitor provision. Given the move towards phasing out internal combustion engines electric car charging points should be provided. Vehicle access and numbers for the major recreational uses. The Local Plan indicates the countryside park will be an 'Accessible Open Space' and that it will be deliver an 'extensive district park'. However the only vehicle access through the development and limited car parking provision is more in keeping with an area provided for the exclusive use of estate residents or those living nearby. The low level of car parking provision (15 spaces) for the 16.5ha dedicated country park and its location will result in users parking on shared space roads and/or on private drives. An alternative access that does not involve access through the residential roads and a substantially increased number of car parking spaces should be provided for the countryside park. A suitable access is also needed for the maintenance equipment and vehicles for the countryside park. Logically a site that is to be a 'strategic sports site' should have its own entrance and car parking rather than one exclusively via the residential site. This could be achieved off Claypit Lane. Urban edge transition. On the boundary of the residential development with the country park there are several private drives. It is not clear that visually those drives and the boundary treatment of railings meet the key design principle of Appendix 6, paragraph H.6 item 4, which states: "A clear design approach to the urban edge to allow managed transition between town and country, and to allow easy and convenient access through the site to the open district park beyond". Car parking. Concerning the specific car parking spaces proposed for parts of the development the dominant impression will be rows of parked vehicles and rows of bins lined up in front of houses. The overall design ought to be 'occupier neutral' rather than the noticeably cramped and unattractive layout currently proposed for the affordable housing locations. The Local Plan key design principle Appendix H, Paragraph H.6 item 8: "Vehicle parking will be an integral part of the plan for the scheme, to ensure limited impact on visual amenity and residential privacy. Any surface level parking areas will make provision for generous planting in order to aid visual containment and help to ameliorate the effects of climate change" is not being met. It is not clear that the road width and indicative tree planting will allow sufficient room for car parking/dropping of and picking up of children at the school. The school is bound to attract children from nearby developments off Falkland Road and Darwin Park given the 60-child admission capacity limit of Christchurch School. Adequate car parking provision should be made for the school to minimise congestion and improve safety. There is extensive use of lengthwise car parking bays as well as side by side parking. Lengthwise parking requires the vehicle nearest the road to be moved to allow the other vehicle out. It is common practice on shared space developments for one of the cars to be parked on the road for long periods to avoid this inconvenience. The consequent obstruction for other users can prevent buses and emergency vehicles gaining access. It can also a problem for the disabled, blind and children pedestrians. Community facilities on SDA sites. There is a need for an effective joined up approach to the planning and provision of community and social facilities for the three adjoining SDA sites in the City and adjoining developments. Landscaping and hedge loss. Overall there is the need for high quality and sensitive treatment as a priority along "the gateway routes" into the City, such as Birmingham Road. In this context the proposed landscaped edge towards Birmingham Road is welcomed although the concept of a landscape buffer alongside the Birmingham Road residential boundary is barely achieved. The key design principle that the landscape must demonstrate how existing trees and hedgerows will be retained, incorporated, and extended/enhanced as part of the proposed organisation of built form appears to have been ignored or overlooked. Removal of the existing hedging on the site, particularly along the Birmingham Road boundary, is neither justified nor consistent with the design principle. 5. Commercial Development The applicant appears to be looking for a wide range of commercial uses to be as flexible as possible. This could be anything from a doctor's surgery to McDonalds, for instance. Because the site is narrow, little reference has been made to design and landscaping. Sensitive, well designed commercial development is vital for the scheme on Birmingham Road, with an emphasis on smaller scale development and B1 offices rather than inappropriate B2 and B8 uses. Related to this, the commercial development area will require provision of substantial and effective landscaping along the frontages to Birmingham Road and the Bypass. It should be made clear that the detailed application for this site must include proposals for landscaping notwithstanding the narrowness of the site. Appendix The Manual for Streets: Evidence and research TRL Report No. 661 Darwin Park was included in a survey by the Transport Research Laboratory for the Traffic Management Division of the Department for Transport published in 2007; (ISBN 1-84608-660-4). The following is a selection from the report that specifically relates to Darwin Park: Lichfield had the second highest return of respondents to the survey. 100% of Darwin Park residents experienced problems with vehicles parked outside their home 'a lot of the time' and 'sometimes'. Darwin Park had the second-highest level of concern at 72% of the respondents concerning parked vehicles. Residents in Lichfield also showed the most concern about vehicles parked and obstructing footways. The issues of respondents concerning parking related to access, safety and aesthetics. Parking was identified as the main culprit in restricting access to streets. One resident said "Access to my drive is often affected by cars parked on the street" (Lichfield resident). 'Many old houses with single frontages own 2 or 3 cars, so they have to park in front of someone else's house' (Lichfield resident). School traffic is a particular issue: 'School run parking causes double parking, pavement parking and blocks driveways' (Lichfield resident). 'School run mindless parking' (Lichfield resident). 'Parking is provided away from road to improve aesthetics. Of course people don't use it and park on the narrow street. This is ridiculous, people want to park near the door, especially when they have kids/shopping/elderly. Improving aesthetics has caused the problem in our street' (Lichfield resident). 9.4 Road safety Residents generally considered that road safety was the main aspect of concern within their neighbourhood. The questionnaire explored the underlying reasons for these concerns. One of the key issues that arose was traffic speed in the residential area, and over half (52.8%) of respondents claimed to be either 'very' or 'quite' concerned about speeds when asked about road and personal safety issues in their street. In New Town, Reading, this was of particular concern: 80% of respondents were either 'very' or 'quite' concerned about vehicle speeds. Other sites where higher percentages of respondents indicated concern over high vehicle speeds include: + Eastleigh (77.8% of respondents concerned) 'My daughter was riding her bike on the pavement and a car reversed out of the drive and did not see her' (Lichfield resident). 'Pavement on both sides is grassed, therefore people tend to walk in the middle of the road, which is very unsafe' (Lichfield resident). 9.8 Summary of household survey findings Specific case study sites that stand out are New Town, Eastleigh and Lichfield. Respondents from these sites considered them to be consistently unsafe, showing concerns over vehicle speeds, the number of vehicles in their street, the lack of footways, the lack of cycle paths, the lack of visibility for drivers and the lack of visibility for pedestrians. Both adults and children were considered to be unsafe at these sites as a result of road traffic. Parking and the resultant safety issues were also major concerns for a high proportion of respondents at these sites. B.1.8 Darwin Park, Lichfield + Suburban area situated less than 2 miles south of Lichfield city centre, near to M6 toll road.
John Thompson |