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Development Control Manager
LICHFIELD DISTRICT PLAN REVIEW 2020-2036 Response from Lichfield Civic Society Question 1: Do you think the plan period of 2020-2036 is appropriate? Answer: Yes Question 2: Which part of the evidence base do you consider remain relevant and which parts need to be updated or replaced? Are there any other evidence base studies required, and, if so, why? It is the view of the Civic Society that there is a need for updating/replacing some parts of the evidence base, as is proposed in Appendix A. The list of Actions included is generally supported, but with certain provisos. It is considered certain issues need to be given greater emphasis or priority, as described below. Firstly, because of the rapidly changing nature of traditional retail activity nationally, and locally, it is vital that the evidence base in connection with this activity is as up to date as possible. This would, therefore, need to be undertaken almost concurrently with the plan preparation in its early stages (2018-2019). This is necessary, in the opinion of the Civic Society, because of how critical it is for Lichfield City Centre, to have a realistic understanding of the scale and type of retail requirements at least initially in the short and medium term. Secondly, the need for commercial office space and realistic assessment of delivery must similarly be up to date and robust, particularly bearing in mind increased "working from home", and other new patterns of work. In relation to the Retail Evidence Base referred to in Appendix A, it is not agreed that "No Action" is appropriate, for the reasons given in this and the preceding paragraph. A third matter which should be examined in a detailed and comprehensive study with a particular focus on Lichfield City is the environmental capacity of City and its capability and capacity to absorb any additional development beyond that currently proposed. This study would need to cover such issues as the impact of further development on topography, landscape and setting of the City, including the setting and character of the special "historic asset" of the City, including the Cathedral, as well as examining the impact on Green Belt, open space and open countryside of potential development. The study should also investigate the capacity of all elements of physical and social infrastructure and services to establish the situation. It is the opinion of the Civic Society that, because of the importance of the City in the District and sub-region, and its unique character and position, it requires to be considered in a single, comprehensive study and not, as currently, in a more piecemeal manner within much wider often District-based studies. It is accepted these District-wide studies would still continue to play a part in the Evidence Base. Question 3: Do you consider all the key strategic cross boundary issues have been identified above? If not, what other issues should we be working with our partners to address? Are there any mechanisms you would recommend for solving cross boundary issues? Answer: The issues raised seem to cover all possible matters. It is difficult to suggest mechanisms to ensure a consistent and fair approach across all authorities involved, for instance in addressing the "unmet needs of the Housing Market", without an external arbitrator akin to an Inspector or EiP Panel with a remit to guide and deliver a "regional or sub-regional strategy or plan". The current approach is piecemeal, divisive, and open to commissioning bodies to brief a consultant with a potential slant. At the very least under the system currently operating there needs to be a criteria based approach which is consistently applied across the full range of issues, e.g. green belt studies, sustainable location studies. All such work should follow the same methodology and use the same criteria, and these mechanisms should be open and transparent. This should be a basis of all work undertaken by all parties involved in issues of addressing cross-boundary matters. Question 4: Do you agree that the policies listed above (Table 1.2 in full document) need to be significantly amended or replaced? Do you consider there are any other policies that need to be significantly amended or replaced? The Civic Society agree each of the policies listed in Table 1.2 require to be significantly amended or replaced. However, it is considered the following policies also need to be significantly amended, and moved from Table 1.3: CP2 Presumption in Favour of Sustainable Development. CP3 Delivering Sustainable Development CP4 Delivering our infrastructure NR2 Development in the Green Belt CP14 Our Built and Historic Environment Policy Lichfield 6 Firstly, the completion and opening of the Lichfield Southern Bypass between Birmingham Road and Tamworth Road should be included as a pre-requisite before any development within the three areas of South Lichfield is occupied. Secondly, the employment allocation within the Cricket Lane Development should be re-designated as an area for B1 Office use, Leisure and Hotel in place of the current Plan proposal for all categories of employment use. This change would be more environmentally appropriate at an important entrance to the City, and it would sit against the immediately adjoining housing site proposed for the Cricket Lane development area. An office allocation here could attract high technology activities and startups, as well as being available for spin-off activities from the nearby Whittington DMS site. In addition to those listed above, there are a number of policies where no change is proposed, but in the opinion of the Civic Society the following policies do need to be subject to amendment, as follows: Policy BE2: Heritage Assets Policy Lichfield 3 Lichfield Economy Question 5: Do you agree that the policies listed above (Table 1.3 in full document) require minor amendments? Do you consider there any other policies that only require minor amendments? With the removal of the nine policies listed above in our response to Question 4, the Civic Society agree the remainder of the policies listed in Table 1.3 require minor amendment. Question 6: Do you agree that the policies listed above (Table 1.4 in full document) require no change and can be rolled forward as part of the Local Plan Review? Do you consider there are any other policies that can be rolled forward and added to the Local Plan Review? With the exception of Policy E1, the Society agree with the list. In relation to Policy E1, the Civic Society consider this requires significant amendment for the reasons given above in our response to Question 2, paragraphs 2 and 3. Question 7: Do you consider any additional policies are required? If so what policies are required and why? A policy for protecting and extending the open space network, links and corridors within Lichfield City is needed. Question 8: Have we identified the main issues facing the District? If not are there any other issues that you think need to be explored further or addressed through the Local Plan Review? Answer: Yes, but it is considered the priority ones within the list are: No's 1, 4, 8 and 11. Question 9: Do you agree with the vision and approach as set out in the Local Plan? If not why not, and what alternative would you suggest? There is a need to give more emphasis to the Heritage Asset of the City of Lichfield within the Vision. One benefit of that, amongst others, would be to ensure the tourism aspirations expressed in policy have, and maintain, a product that merits promotion of the unique character of the historic City and Cathedral. Additionally, there is a need to remove the emphasis on Lichfield City and Burntwood Town as the main locations for future growth, for the various reasons put forward in this response, and to include reference to growth being focussed on a New Settlement beyond the Green Belt. Question 10: Do you agree that the Strategic Priorities remain broadly relevant to the Local Plan Review? Do they reflect the key issues identified? If not, how should they be changed or amended? It is considered some changes are necessary to a number of these Priorities, as follows: 1. Sustainable Communities - less emphasis on Lichfield City and Burntwood Town and more on a New Settlement as a viable Sustainable opportunity over the Plan period. 8. Employment Opportunities - add that certain currently existing important employment areas should be retained in employment use. These, such as the areas along Eastern Avenue, possess a high degree of sustainability, and support minimising levels of out-commuting for the local population. 10. Tourism - the attraction to tourists would be greatly enhanced if the Heritage Asset of the City was protected and improved, and this would offer a significantly more attractive and unique marketing opportunity. 14. Built Environment - this should give greater emphasis to the heritage asset of Lichfield City Centre and the need to enhance its character and distinctiveness. 15. High Quality Development - this aspiration should be reflected in all policies and decisions concerning development, with particular priority being expressed in relation to Lichfield City Centre and its heritage features. Question 11: Do you think the Local Plan Review should consider the inclusion of a density policy? The Civic Society does not support inclusion of numerical density policies in the Local Plan. It is considered that in principle the density of each new development should evolve as a result of full consideration of the context and surroundings of any site and the nature of the development itself. Question 12: How should Lichfield District Council assist in meeting unmet needs arising from within the Greater Birmingham Housing Market Area? Because of the scale of housing already included in the current Local Plan and the significant proportion of the District area designated as Green Belt, it is considered that Lichfield District could only play a limited part in meeting the unmet needs arising, and only provided that exactly the same criteria and methodology of approach to the distribution assessment were undertaken by every other authority within the Area, including Birmingham City. The statement that "a consistent evidence base in relation to Green Belt being advanced across the HMA" (paragraph 6.15) is welcomed. It also appears that urban extensions are being supported in principle as sustainable locations (paragraph 6.15) and, therefore, the most sustainable locations in the sub-region would be directly adjacent to the built up area of Birmingham City because of the proliferation of services and employment opportunities available and accessible. In the case of Lichfield District, after the current Local Plan sites on the edge of the City, there are no reasonable or realistic potential urban extension areas available which would compare with Birmingham in terms of sustainability. For Lichfield District, whether to address local housing need or unmet housing need from elsewhere in the HMA, a new or extended settlement in an appropriate, non-Green Belt location is the most appropriate sustainable way forward, even with the possibility of facing long lead times to achieve implementation as suggested in the report. This approach involving a new and positive strategy is necessary to replace the on-going approach of simply letting the largest settlement in the District continue to grow by adding another "onion-ring" of development on the edge of the City. As much of the last development was in sensitive Green Belt, it is timely to halt this approach. Questions 13-16: No comments Question 17: Do you agree that the retail and office requirements as set out within the Local Plan Allocations document, based upon the Lichfield Centres Study, remain appropriate for the Local Plan Review? The Civic Society is concerned that the amount of retail and office space proposed to be accommodated within Lichfield City Centre remains both unrealistic and also excessive for a location of very special quality, where at paragraph 6.32 it is stated that the Council intends "sustaining and enhancing the significance of its historic environment and heritage assets and their setting". With the rapid increase in Internet shopping, the need for retail premises in town centres is changing and decreasing significantly, and even requirement figures prepared fairly recently are likely to be out of date by the adoption date of the revised Plan. Delivery rates of new retail development in the City over recent years would indicate clearly that the most recent proposals are over-optimistic, and it is suggested further work is undertaken on this topic in the period leading up to adoption of the revised Plan to ensure realism is achieved. In terms of office requirements, because of the growth of "home working" and the IT revolution, it is considered the proposals are also excessive, and, as such, will not be deliverable. In terms of past delivery of office floorspace in the City Centre it seems most improbable that an annual rate of 1,000 sq.m. - 1,400 sq.m. can be achieved. This requirement needs to be reduced. The Cricket Lane SDA site's employment allocation should be a priority for office provision. Question 18: Do you agree that the District Council should consider progressing supporting Development Plan Documents (such as Area Action Plans, Development Briefs or Supplementary Planning Documents) for Lichfield City Centre and Burntwood Town Centre as part of the Local Plan Review? Are there any other locations within the District which would benefit from the production of further DPDs? The Civic Society support the suggestion for the District Council to prepare a number of Area Action Plans, including Lichfield City Centre and Burntwood Town Centre. The Society believes such a document has the potential because it would contain more detailed policies which would balance development proposals and environmental safeguards in a more effective manner than has been achieved recently achieved under a more high level strategic plan. Additionally, it could contain specific conservation area enhancement policies, as well as covering transport and access matters, including car parking strategy, pedestrian and cycleway links, and it could present the opportunity to improve the workings of the current City Centre pedestrianisation. One additional location is proposed for a future Area Action Plan. If, as is suggested elsewhere in our submission, a New Settlement Option is selected for progressing, such a location would be ideally suited for designation as an AAP to guide and support the development. Question 19: Are there any other types of development that we need to consider? It is suggested that policies for wind turbines and solar farms, containing explicit criteria, would be of value in making decisions regarding the most appropriate locations for such developments. Question 20: Are there any other types of development that we need to consider? Question 21: Do you think that focusing development around the existing main urban areas is an appropriate option for growth? Answer: No, this is not considered to be an appropriate strategy for Lichfield City or Burntwood. Both settlements have after many years of continuous peripheral growth, requiring the removal of land from Green Belt, reached a position where further development, beyond that included in the extant Local Plan, would breach physical and topographical thresholds, as well as environmental and many elements of infrastructural capacity. Of the Opportunities and Challenges listed, there seem to be more disadvantages / Challenges than benefits / Opportunities, particularly in the cases of Lichfield City and Burntwood. Two examples worth quoting are the real impact on Green Belt which would occur and the adverse impact on the character and historic asset of the City, if further development is focussed on Lichfield. It may, however, be possible to focus elsewhere under this option, and there may be opportunities for development, as Map 8.1 suggests, to the north-east or south-west of Tamworth, a large and sustainable settlement, with a wide range of social and physical infrastructure and employment available. Rugeley also possesses some opportunity under this option. It appears to the Civic Society that the most sustainable location for town focussed development is in the area adjoining Sutton Coldfield within Birmingham City or Walsall Council's area. This area is close to the amenities of the conurbation, is well served by various modes of public transport, including rail and bus, and has a wide range of employment opportunities near. Question 22: Are there any other opportunities or challenges that should be considered for this option? Question 23: Do you agree that focusing development around the existing town [centres(?)] and key rural settlements is an appropriate option for growth? Answer: No, this is not considered to be appropriate as an option, largely for the reasons given in response to Question 21 above relating to the main urban areas. The element of this option that has benefits / Opportunities is to ensure the key settlements have some development in order to safeguard facilities and services. Question 24: We have previously identified Alrewas, Armitage with Handsacre, Fazeley, Mile Oak and Bonehill, Shenstone and Whittington as Key Rural Settlements. Do you agree with the identification of these villages as key rural settlements? Answer: Yes, in principle these are appropriate for inclusion as key rural settlements. However, if significant change is introduced to the Plan Strategy, and hierarchy of settlements, as for instance being sought by the Civic Society, it may well be necessary to vary this list. Question 25: Are there any other opportunities or challenges that should be considered for this option? Answer: No Question 26: Which rural settlements do you consider are suitable for further development under this option? Are there any other settlements where village settlement boundaries may be required. This is not considered to be an appropriate or acceptable option to accommodate all new development. It would spread development widely and thinly, creating a particularly unsustainable form of development and increasing car movements to an excessive degree. It is highly likely to be environmentally detrimental to significant sections of the District and is one of the least acceptable options put forward for comment. There may be scope for some villages to accommodate affordable housing to meet local needs. Question 27: Are there any other opportunities or challenges that should be considered for this option? Answer: No Question 28: Do you agree with the identified locations for potential new settlements to meet this option? In the opinion of the Civic Society the New Settlement Option offers the best long term strategic direction for the District Council to adopt even though it will involve a radical change to the existing. approach. A new approach will have considerable benefits compared with simply continuing to follow previous policy. It will relieve the very considerable development pressures, beyond the current Local Plan allocation sites, facing the District's two main urban locations, Lichfield City and Burntwood; it will provide the opportunity to protect and enhance the historic asset and special character of the Cathedral City; it will remove the on-going development pressures to release important and sensitive areas of land from Green Belt immediately adjoining the two main urban areas; and over the medium to long term it will provide the opportunity to make provision for both locally generated housing needs, as well as a still, as yet, undefined scale of housing emanating from the unmet Market Area housing needs, as is adjudged necessary. The New Settlement Option, although needing a programme of infrastructural investment to be implemented over a number of years, gives the advantage of concentration and of economies of scale, in comparison with a wide spread of smaller infrastructure projects. If, as suggested elsewhere in our response submission, the District Council were to prepare an Area Action Plan for the new settlement at an early date, this would provide a framework and clear guidance to, not only landowners and developers, but to infrastructure providers, thus enabling a comprehensive, coordinated and planned approach to development. This approach would also address to a considerable extent the 'challenge' referred to in Table 11.1 of achieving the necessary provision of infrastructure. It is further noted that a 'challenge' in Table 11.1 refers to a likelihood of a slow rate of delivery of housing under this option. As the current local plan strategy (akin to Option 1) has failed consistently to achieve planned housing delivery dates, this criticism cannot be directed specifically at Option 4. In reality, a fully planned and serviced New Settlement approached in a positive manner, along the lines of a "New Town Development", could achieve the required target of housing delivery. Of the three locations put forward, the Civic Society do not support the Shenstone location, because the whole area is Green Belt. The loss through removal of such a significant area of Green Belt land and its development would be completely contrary to the fundamental policy and a main purpose of Green Belt by accelerating the merging and coalescence of Lichfield with Birmingham. At present this is one of the few remaining open areas of land within the corridor between the two built up areas. The Thorpe Constantine Option is too isolated and removed from other settlements and their higher scale community and social facilities as well as employment sites. Additionally, it is extremely difficult to envisage the creation of a sustainable and viable settlement here with no, even embryonic, public transport facilities or network. The Civic Society support the Fradley and Alrewas New Settlement location, as it is beyond the Green Belt; has the benefit of experience of recent successful development of a reasonable scale; can easily access major employment opportunities, e.g. at Fradley Park, Lichfield and Burton; and has bus services already operating , which can be improved and expanded as the development proceeds; and has the potential towards the later phases of the Plan period for the re-introduction of rail services between Lichfield and Burton (with much wider connections), including the extension of the Cross City Line. Although the report notes certain constraints within the area, it is not considered these are insurmountable. Our view on infrastructure provision for a new settlement is stated above. Minerals safeguarding and extraction can be addressed through a phasing programme and / or siting decisions. Flood risk can be avoided by sensitive locational planning and careful mitigation and design. Question 29: Are there any other locations that would be preferable and deliverable? A possible variation to the Fradley and Alrewas Option would be to include the Brookhay area as part of the new settlement consideration. Question 30: Are there any other opportunities or challenges that should be considered for this option? Fradley has recently had housing development and the opportunity exists to add further development to gain critical mass for provision of additional services and facilities to improve its sustainability. Question 31: Do you agree that employment development should be focused on the existing employment areas? located at Burntwood, Fradley and Lichfield City? As these are significant in scale, offering a varied range of work opportunity and are well located in relation to the two largest urban areas within the District, this approach is supported, with the additional proposal. This relates to any new settlement which is developed under the Revised Local Plan strategy. Such a settlement must have associated closely with it, major employment allocations to ensure daily commuting movements can be minimised by creating as far as possible a close balance between those seeking work and available jobs. Question 32: Are there any other existing employment areas which should be considered for expansion? The Civic Society consider that a number of existing employment areas should both continue in employment use or be expanded in scale. Recently a number of employment areas in the District, including sites located along Eastern Avenue, have been lost to employment use. Each time an operational employment site is redeveloped for a housing use, this results in an increased number of those seeking work having to travel further, or and often journey beyond the District. The figure is multiplied because, not only is the existing staff involved in this need to relocate work place, but also the occupants of the new dwellings who will be seeking work. It is our opinion that employment land at Armitage, Fazeley and Shenstone should be retained in that use, and, if possible, expanded. Furthermore, in the main urban areas, land at Lichfield and Burntwood should be prioritised for this to seek to maintain or achieve a balance to ease excessive and wasteful out-commuting problems from the two locations. Question 33: Are there any other opportunities and challenges that should be considered for this option? Answer: No Question 34: Do you agree with the identified locations for potential new areas for employment development? The Civic Society are content to support an additional employment area at Lynn Lane, Shenstone, but not the other two sites referred to. Land at Seedy Mill treatment works is too isolated and would be an inappropriate neighbour for the Golf and Leisure complex and the surrounding agricultural activities. Land at Bassett's Pole, Drayton Bassett is similarly isolated from existing and planned housing areas and is not considered an appropriate location for this use. Question 35: Are there any other locations which should be considered which would be more preferable and deliverable? Two suggestions are made as our response, as follows: With a New Settlement at Fradley and Alrewas, as suggested elsewhere in our submission, there should be co-located some further employment provision. With an Urban Extension to the north of Sutton Coldfield, as suggested elsewhere in our submission, there should be co-located some employment provision. Question 36: Are there any other opportunities or challenges that should be considered for this option? Question 37:
Are there any alternative options that should be considered,
or a combination of the spatial options identified? The consultation document has included four extreme examples of development options and, therefore, has included virtually every possible approach to distribution of development. In principle, therefore, no further alternative options can be put forward for consideration. However, in response to the second element of the question, there is scope for a combination of the options to come forward for consideration. The Civic Society, as stated earlier in response to Question 28, support Option 4, New Settlement Development, and would see this settlement taking a significant proportion of the District's additional housing development over the Plan period, but would expect this to be in conjunction with other settlements and locations, originating from parts of the other options that have been referred to. These other areas are seen by the Society as being: sustainable urban extensions to Rugeley, Tamworth, Birmingham and Walsall; Key Villages; smaller villages (where some affordable / local needs housing can be accommodated); and Lichfield and Burntwood (where because of the Local Plan and Plan Allocations commitments, there is only residual capacity remaining available on infill and brownfield sites). The Settlement hierarchy will therefore become as below, to replace that included in Core Policy 1 The Spatial Strategy of the extant Local Plan: NEW SETTLEMENT (Alrewas and Fradley) Question 38: Do you agree that the proposed IDP structure will enable the effective articulation of infrastructure requirements associated with the Local Plan? In a perfect world it may work effectively, and the correct questions are generally being raised, but experience indicates that the contents of an IDP, showing infrastructure needs, fail to be delivered in the final analysis, with developments proceeding without all the initially proposed infrastructure. Question 39: Do you consider the prioritisation of infrastructure a useful tool to enable delivery? We consider it is important to prioritise infrastructure requirements, but it will only matter if the delivery to satisfy this is achieved. Question 40: Do you consider that the identified prioritisation and their definition is appropriate? Answer: Yes, but delivery must be achieved as stated above. Question 41: Do you consider the extent of the evidence base studies outlined above is sufficient to provide a sound basis for the development of an IDP? The Civic Society consider that additions should be made to the Evidence Base as follows: For Lichfield City and its immediate environs, an environmental capacity study should be undertaken. It should include topographical and landscape analysis; the environmental impact on the setting, Green Belt and adjoining countryside; the traffic and transport situation within and beyond the City and the impact of these elements on the historic asset; a similar impact analysis should also be undertaken of recent built development upon the historic asset. This work should take into account the fact that a very significant amount of development in the City, committed either by non-implemented planning approvals or the adopted Local Plan and Local Plan Allocations document, has not yet been progressed to building stage, but must form the basis of impact consideration. It must be ensured that the proposed Transport Studies are extended to include detailed analysis and evaluation of all of the larger option proposals, i.e. the new settlements, and urban extensions. Additionally, it is requested that the studies include consideration of all modes of transport serving, or potentially serving, these settlements in order to establish their relative sustainability and viability. Question 42: Does your organisation have an adopted strategy to action plan which could influence the What, Where, When, section of the IDP? Answer: No Question 43: Do you agree that the proposed stakeholder engagement process will result in the identification of infrastructure requirements and enable delivery of those requirements? We believe you are likely to put enough effort into this exercise to obtain a fairly complete list of infrastructure requirements, but we remain unconvinced as to the success of achieving their delivery in anything but a partial form. This could be due to many reasons, largely out of the planning authority's hands, including changes of policy or spending priority by the providers, initial inadequate or inaccurate cost information. The plan needs a strong policy on infrastructure that is listed in the IDP, to ensure approval is only given to applications when there are legally binding commitments on implementation either prior to or in phase with the development. John Thompson |