The Lichfield District Local Plan |
Representations of the Lichfield Civic Society
1.1 The Lichfield Civic Society welcomes the preparation and publication of the Lichfield District Local Plan. It compliments the Council on the way in which the policies and proposals have been set out, on the clarity with which they have been expressed an on the use of the print which enables the document to be easily readable.
1.2 Most of the policies and proposals contained within the Plan are fully supported by the Civic Society. Understandably, however, there are misgivings about some of the contents of the Plan. The District Council will be aware that the Society made representations on the Lichfield Local Plan and gave evidence at the Public Enquiry, under the Chairmanship of Mr. George McDonic, held in June/July 1992. The Society has take into full account the Inspectors' report and considers that his conclusions should be accepted in the main, not withstanding that they may not have supported the Society's views.
Background to the Society's Representations
2.1 The Lichfield Civic Society believes that there seems to be a lack of vision as to the future of Lichfield. What purpose does the City perform? How large should it be? Does it have characteristics which require its development to be treated in a manner which is unique to itself? The Civic Society in the course of the next few months will be addressing these issues and will hopefully produce its own 'vision statement' as a positive contribution to the planning of the City. In the meantime, in the absence of such a statement and, as the background to its specific representations, I can do no more than reiterate and quote extensively from observations previously made, notably in the Society's letter to the Director of Planning dated 9th December 1988, which remains relevant.
2.2 There is little doubt that there is a general view among members of the Society - a view probably shared by the majority of residents of the City - that Lichfield has reached its optimum size. Understandably, the Society is principally concerned wit the conservation of Lichfield's historic legacy and the quality of its environment. Lichfield is one of the most beautiful cities in the country. This beauty is derived not only from the existence of the Cathedral and the attractions of the mediaeval/Georgian centre but also from the open spaces within the City and the rural approaches to it. Unlike many historic towns "the setting of the City remains largely unimpaired. The approach to the historic core does not take place through endless development" (9th December 1988).
2.3 The City centre is already under stress. There are serious parking problems evident and these parking problems and deficiencies of the highway network to cope with existing traffic levels will be seriously aggravated by proposals to substantially increase the residential population, to encourage further industrial and business development and to promote Lichfield as a major tourist attraction. The pressures applied to the City Centre will result in a deterioration in its ability to function efficiently and in the quality of its environment. Moreover, these proposals will cause the loss of open spaces which are important to the urban structure of Lichfield - the Cricket and Hockey ground, the Friary School playing fields - and will undermine the att activeness of the approaches to Lichfield, especially along the Birmingham and Walsall Roads (9th December 1988).
2.4 The Civic Society is aware that the Lichfield District Local Plan, to be certified on its adoption, has to be in conformity with the Staffordshire County Structure Plan, approved by the Secretary of State. The Society is sympathetic towards the difficulties imposed on the District Council by that Plan. The Structure Plan is based on the continuation of the conventional planning philosophy which over recent decades, sought to solve the problems arising from development pressures by allocating growth o towns and villages on the outer edges of the Green Belt e.g. Tamworth, Lichfield, Burntwood/Chasetown. These settlements expanded to house the young, active and mobile households, mainly from the conurbation.
These households generated further households, which in turn created pressure for further development around towns and villages. There is a self perpetuating process, the inevitable consequence of which is that a place like Lichfield will continue to grow in size in the future. This is amply demonstrated by Policy L7 "Area of Development Restraint". The price of this growth will be extra strain on the already inadequate infrastructure of the City, the loss of open spaces and further encroachment into the Green Belt.
2.5 There is a need for more radical alternative polices. This is why the Civic Society strongly supports the District Council's appointment of Consultants to investigate the opportunity to create a new village settlements within the District. If the conclusions of the Consultants are positive, the Society would urge the early implementation of a village settlement - despite the long lead in period - which would reduce the housing levels at Walsall Road within the Plan Period.
Representations on Specific Policies and Proposals - Area Policies for Lichfield
[3.1] LI, L2 and L7 Housing: Walsall Road and Chesterfield Road; Area of Development Restraint.
1. The Civic Society opposes the scale of development proposed for these two sites, which together are intended to accommodate 530 dwellings in the Plan period and a further 250 in the longer term. It is acknowledged that this represents some reduction from the proposals in the Lichfield City Plan but this is negligible. Moreover, the rephasing of the development to extend beyond 2001 is merely a 'sleight of hand' and will have no effect on the final result. A development of this size is not consistent with the Secretary of State's views that around the City, development should be restricted to a 'limited degree'. It is equally inconsistent with the Public Inquiry Inspector's conclusions that "the Walsall Road site is too large to be considered and accepted as a development to a limited degree and I believe a site of this size would have a damaging effect on the environmental character of the City". To ignore the Inspectors recommendation to such a degree seems somewhat perverse.
2. The Civic Society recognises that, given the need to fulfil the requirements of the Structure Plan, some housing developments at Walsall Road and Chesterfield Road may be inevitable albeit not necessarily desirable, bearing in mind the uncertainties ssociated with 'a new village settlement'. The Inspector at the Public Inquiry did not explicitly rule out housing development - he was concerned with the scale proposed. He did not give his own definition of 'to a limited degree', but when dealing with Berryfields Farm (Para 2.473 page 76) he believed that a development of 300 dwellings would meet necessary criteria.
3. The Civic Society strongly opposes the loss of the Cricket and Hockey ground. The proposals contained within the Area Plan represent a token change to the earlier Lichfield Plan. The modifications do not overcome the Societies earlier representations (see Para 14 of letter dated 9th December 1988).
4. Other proposals contained within Policies LI and L2 will be dealt with under the comments L23, 24 and 25.
5. The Civic Society opposes the proposals for the identification of land as an "Area of Development Restraint" (Policy L7) to the south of the route intended to be safeguarded for the Southern By-Pass in the vicinity of Wordsworth Close/Byron Avenue. I this section of the by-pass is built, it should form the permanent boundary of Green Belt around Lichfield. Any development beyond the By-Pass will have no clearly defined boundaries and it is inevitable that the process of building will continue in the future. It is recognised that the Government advises through Planning Policy Guidance No. 2 (PPG 2) that regard should be given to long-term requirements of future development as well as to Green Belt objectives. PPG 2 is intended to provide guidance for all towns and cities affected by Green Belts, but the question has to be asked as to whether there are certain circumstances which exist, whereby exceptions to the need to provide these "Areas of Development Restraint" may be acceptable. The Society believes that these circumstances arise in Lichfield, because of its historic and environmental character. Where are the limits to development in Lichfield?
L10 and L11 Employment: Watery Lane and Sandford Street.
1. The Civic Society opposes Policy L10 Eastern Avenue/Watery Lane. This site should be deleted from the Area Plan as a location for industrial/business uses. Although the allocation has been reduced to 6.1 acres from that proposed in the Lichfield Local Plan, development of the land would still constitute an encroachment into open countryside and would be conspicuous and lead to visual harm. The Society supports the views expressed by the Public Inquiry Inspector (Para 4.21 page 90) and believes that the Green Belt should be extended over the site. The deletion of the Watery Lane site will not undermine the district Council's requirements to meet the Structure Plan's overall requirements of 160 ha.
2. The Civic Society accepts that the sites at Sandford Sreet (Ell) are suitable for office development in principal but, in the light of the shortage of convenient parking spaces in the City, the land at the S.E. corner of Swan Link Road and Sandford Street should be retained as a public car park. It is tidy, well used and serves a valuable purpose for shoppers and visitors to the library.
[3.3] L13 and L17 Shopping: Bakers Lane Development and the Primary Retail Centre.
1. The Lichfield Civic Society recognises that one of the most controversial issues in Lichfield is the condition of the Bakers Lane Precinct. Over many years, its quality has deteriorated dramatically and this has undermined the perception of peoples' views on the amenities of the City Centre. The Society supported proposals for the redevelopment of the area, which were approved several years ago but, were never implemented. Circumstances have changed and more modest proposals have been put forward, which include the retention and refurbishment of the existing multi-storey car park. The City Centre Insert Plan should be modified to reflect these changed circumstances, since the relevant proposals are based on an earlier scheme which is not likely to be carried out in the Plan period. The Civic Society does not wish to see the bus-station incorporated into the shopping area. It is difficult to see how in practical terms it is possible to retain the bus station and to extend the retailing into the area. It is regrettable that there is no reference in the transportation section to any policies for bus related public transport. The District Council should actively promote public transport facilities and, to this end, should seek the improvement of the bus station and its increased use.
2. The Civic Society has serious reservations about the inclusion of the Bakers Lane car park and bus station in the Primary Shopping Area. This is very much an area on the outer edges of the shopping centre. The Primary Shopping Area should be much mor concentrated. There is surprise that Bore Street is not included within the Primary Shopping Area, despite the fact that under Policy L26 through traffic will be excluded. Bore Street is becoming more attractive, contains some interesting shops and the flow o shoppers has noticeably increased, especially since the opening of Wilkinsons.
This needs to be encouraged and policies to increase the level of retail investment in the street should be encouraged.
[3.4] L23, L24, L25, L26, L30: Transportation; New Road Construction; Road Line Safeguarding; Road and Junction Improvements; Traffic Management; Car Parking Commuted Payments.
1. Lichfield Civic Society acknowledges that the provision of a Southern By-pass to Lichfield may well have significant benefits to the City. There is no question that the west-east movements for traffic on the south side are not easy, requiring the use of residential streets, narrow country lanes - Shortbutts Lane, Knowle Lane, Fossway, Cricket Lane. In addition, a by-pass would relieve the problems on St John Street and Birmingham Road close to the City Centre which are used by vehicles undertaking through journeys. The Society, however, shares those concerns expressed by others - elected members, other organisations e.g. Leomansley Action Group and individual members of the public for the following reasons:
a. The funds for the by-pass will be provided largely by the private sector in relationship to associated housing development. Is the price to be paid in environmental terms too high, bearing in mind the Society's earlier comments on the growth of Lichfield?
b. The proposal to construct only the Walsall Road link within the Plan Period is not satisfactory. The consequences of this would be to impose considerable problems for those people living in Shortbutts Lane and Cricket Lane. If there is to be a Southern By-Pass, it should be completed in total within the Plan Period and either in advance of, or concurrent with, any housing development which may be approved.
c. It is not difficult to see that, with the construction of the By-Pass pressure will increase to provide a link between Walsall Road and the Western By-Pass. Environmentally, a suitable route for this link would be difficult to establish, and if the premise is that the costs should be borne by the private sector, then it will be inevitable that the funding will be forthcoming only on the basis that housing development beyond the Western By-Pass will be allowed. Such a proposal would be unacceptable to the Civic Society.
2. The Civic Society opposes the construction of a new road between Birmingham Road/Friary Road roundabout and the proposed Walsall Road- Birmingham Road Link for these reasons:
a. The perceived need for this road is inevitably linked with the development of the Walsall Road site on the scale envisaged in the Plan and the construction of the Walsall Road - Birmingham Road link. In the absence of a firm decision on these, it would be premature to endorse proposals to build this road.
b. The building of the road will adversely affect the Cricket and Hockey ground, the retention of which in its entirety is supported by the Civic Society.
c. The proposed road is not essential, even if the residential proposals for Walsall Road are adopted. In engineering terms, the Highway Authority may consider this to be the most suitable means of accessing the site. What alternatives have been considered? Why have they been rejected? If the Cricket ground was not there and the land was developed already, how would the Highway Authority propose to provide access to the housing land? Some alternative would have to be found. Moreover, this road will merely attract additional traffic towards the City Centre, along St John Street and Birmingham road.
It will act as a short cut for vehicles which the Southern By-Pass is allegedly designed to attract. There does seem to be some confusion about the way in which vehicle movements in and around Lichfield should be accommodated. Positive measures should be adopted to reduce traffic in St John Street and Birmingham Road, but this proposed road, together with the enlargement of the Birmingham Road island along with the widening of Birmingham Road itself will have the reverse effect.
3. The Civic Society's reservations with regard to Policy L24 are twofold:
a. As previously stated, if a Southern By-Pass is to be constructed, the development should take place within the Plan Period (see Para 3.4.1 above).
b. Every effort should be made to preserve the Darwin Walk.
4. Reference has already been made to the Society's concern about:
a. Birmingham Road - widening between Greenhill at St John Street.
b. Improvement of Birmingham Road/Friary Road roundabout.
5. The Civic Society fully supports the policies contained in Policy L26 - Traffic Management.
6. The Civic Society endorses the resolution of the City Council's Planning Applications Committee on 21st March 1994 "That the Plan should identify a site or sites for car parking towards which commuted sum payments contribute".