Representation from Lichfield Civic Society

Question 1

Do you consider that the Local Plan Allocations (Focused Changes) document complies with the Duty to Co-operate?

Answer: Yes

We strongly support the Council's progression of the Allocations Focused Changes for the following reasons:

a. It is consistent with the legal obligation to complete the task of having an adopted and up-to-date Local Plan in place.

b. The allocations aspect of completion of the current Local Plan without delay is essential to ensure there is an ongoing 5-year housing supply. Failure to do so could result in ad hoc applications being approved on appeal that are inconsistent with Local Plan policies and/or the NPPF.

c. The Council has proactively participated with the Greater Birmingham & Solihull LEP housing study arising from Birmingham's failure to allocate sufficient sites within its adopted Plan for its own needs.

d. The Council's Cabinet has approved progression of the Local Plan Review. The proposal to examine and undertake a study of a range of growth options as part of the Review is welcomed. The Scoping Consultation will commence in April 2018 with the aspiration of plan adoption in December 2020. The likely scale of public involvement and complexity of the review, including consideration of Birmingham City's out-migration needs and inter-authority liaison with all relevant authorities, including Birmingham City Council in particular, may result in a more protracted timetable.

Question 2

Do you consider that the Local Plan Allocations (Focused Changes) document meets the legal and procedural requirements?

Answer: Yes

Question 3

Do you consider that the Local Plan Allocations (Focused Changes) document is positively prepared?

Answer: Yes

Question 4

Do you consider that the Local Plan Allocations (Focused Changes) document is justified?

Answer: Yes

Question 5

Do you consider that the Local Plan Allocations (Focused Changes) document is effective?

Answer: No

Saved policies and heritage issues in the City

Of concern is the comprehensive deletion in Appendix A of 'saved policies' from the superseded Local Plan. Whilst the underlying principle is that all policies should be within the current Local Plan there are some important issues within the saved policies that have not been carried forward into the Local Plan. The combined effect is to put at risk the heritage and character of the City centre. Some of these policies, for example policies L37 Lichfield Linear Park and L49 Framework Open Space, provided safeguards for local distinctiveness particularly in proximity to the heart of the City and the focal point of the Cathedral. The retention of visually important open space is important and loss of designation will have potential impact on character/visual quality of the City and should be addressed by re-introducing an appropriate policy or policies to the Plan and/or in an Area Action Plan.

Our previous submissions have expressed concern that whilst there are detailed Conservation and Built Environment policies within the Local Plan seeking balance between development and conservation policies the implementation of them in relation to new development in sensitive locations in the City's Conservation Area is relatively ineffective.

We feel that the Council should develop a detailed and comprehensive approach to addressing this issue through the preparation of an Area Action Plan for the City, and City Centre in particular, with the purpose of protecting and enhancing the City's heritage assets and the character and quality of the Conservation Area. This Plan could also address effectively elements of movement and access, improved arrangements for pedestrianisation, servicing and car parking to the benefit of the Area's character and environment, as well as rationalising existing and creating new and improved pedestrian and cycle links within and beyond the City centre. The Action Plan could also relate to policies in the City Neighbourhood Plan if it secures public support in a referendum in February 2018.

Funding infrastructure

The Infrastructure Delivery Plan October 2017 (IDP) sets out the current assessment but still fails to identify that sufficient funding will be available for the scale of development in the adopted Plan. The low level of Community Infrastructure Levy on Strategic Development Sites and restrictions on use of section 106 funding will continue the current situation where new development is not adequately funding improvements needed to deal with the additional pressures generated. Restrictions on local authority finances seriously diminish their capacity to pay for infra-structure works not directly funded by new development. Hence, there is a significant shortfall in funding from all sources to support the scale of development being proposed in the Local Plan and this should not continue to be ignored.

One issue, is the absence in the Local Plan and the IDP of consideration of the need for additional public car parking that may be required and where it could be located. There are several policy objectives in the Local Plan that will lead to increased demand. These include the growth in housing numbers, additional shopping and entertainment, e.g. Friarsgate, and growth of tourism. The potential redevelopment of the mixed-use scheme on Bird Street car park, mentioned in paragraph 9.36 of the Local Plan, could also generate additional demand whilst reducing the existing parking capacity on that site. This issue of car and bus/coach parking provision needs for the period to 2029 should be addressed through a planning-based parking strategy or form part of an Area Action Plan for the City. The evaluation work should include consideration of scale and suitability of both on-street and off-street parking provision.

Question 6

Do you consider that the Local Plan Allocations (Focused Changes) document is consistent with National Planning Policy Framework?

Answer: Yes

The removal of the Green Belt housing site proposals conforms with the requirements of the NPPF. In our submission on the Consultation proposals to release sites from the Green Belt we said that the requirement of 'exceptional circumstances' had not been met. The latest Housing Supply Update (Five Year Housing Land Supply Paper, 2017) clearly demonstrates that there is currently no shortfall in housing numbers to justify consideration of further release of Green Belt for residential development. The change to the Green Belt boundary at St Matthews estate, Burntwood, is justified.

Question 7

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

Introduction

To deal with the concerns expressed in the answer to Question 5 above and enhance the effectiveness of policies in the Local Plan we suggest the following modification:

"The Council will develop a detailed and comprehensive approach through the preparation of an Area Action Plan for the City, and City Centre in particular, with the purpose of protecting and enhancing the City's heritage and environmental assets and the character and quality of the Conservation Area."

"This Plan will address:

a. Elements of movement and access, improved arrangements for pedestrianisation, servicing, and car parking and parking regulations to the benefit of the area's character and environment, as well as rationalising existing and creating new and improved pedestrian and cycle links within and beyond the City centre;

b. Restoring those aspects of saved policies that contributed towards safeguarding and enhancing the environment, character and heritage of the City;

c. Policies in the Lichfield City Neighbourhood Plan if it secures public support in a referendum in February 2018."

John Thompson
Chairman
Lichfield Civic Society
February 14th, 2018