|
The Local Development Framework Core Strategy - Policy Directions | |
|
Planning Policy Manager Dear Sirs, The Society has now considered the latest consultation document and wishes to make a submission for the Council's consideration. This current submission follows comments made by the Society to previous publications prepared by the Council (including Core Strategy - Issues and Options and Core Strategy - Preferred Options). The Society welcomes the acceptance by the Council that some changes were necessary to the strategy and proposals put forward in the Preferred Options document. However, the Society does not consider that the approach now put forward has, as yet, been sufficiently altered to be acceptable as a basis for progressing the strategy to the next stage. The proposals are still fundamentally flawed, as has been pointed out by the Society and very significant numbers of residents who have responded to the consultation. The Society continues to question the number of houses (8000) proposed for the District during the period of the Plan, since this remains significantly in excess of the household projection forecasts for the District as included in various reports prepared by WMRA for consideration by the WMRSS EIP Panel. This submission considers the contents of the consultation document in the following sections: 1) An Alternative Option 1. An Alternative Option It is noted that the Council now wish to increase the use of brownfield land and to minimise the need for urban extensions, but unfortunately the Council continue to promote very substantial urban extensions using Green Belt and greenfield in the case of the City whilst continuing to avoid the clearly more acceptable option of an extended settlement on brownfield land at Fradley. It is the view of the Society that a viable alternative option exists for extending the existing development at Fradley on previously developed ( brownfield ) land at the former airfield in preference to using Green Belt and greenfield land. It appears from the Council's own reports that there is a surplus of at least 40 hectares of committed employment land at the former airfield available for re-allocation to housing which could, along with the existing and committed housing development at Fradley, become the basis of a substantial settlement for development during the period of the LDF and beyond. Achievement of critical mass would then ensure that the settlement of Fradley would have a greatly enhanced level of sustainability compared with the present situation. A range of shopping and community facilities, as well as the likelihood of provision of a secondary school, would be possible once the number of houses approached 5,000, which could be soon after 2026. This option appears not to have been fully considered and tested, and yet it was the basis of development plan policy of both County Council (in the Approved Staffordshire Structure Plan) and of the District Council until relatively recently. There are no "showstoppers" in terms of infrastructure and no significant environmental constraints that cannot be addressed through the normal development process. The Highways Agency has not raised any fundamental objection to development in the A38 corridor, and refer only to a requirement for capacity improvements at junctions. Additionally, immediately adjoining is the largest existing and committed employment area in the District, offering the long term benefits of a mixed use development. The Council has only considered the alternative settlement proposal for Curborough and then discounted it on various grounds. The principal reason for which seems to be the very high proportion of greenfield land to be taken by that particular proposal, at approaching 90% of the land-take. The fact that Barton Wilmore has made representations on behalf of clients to the RSS Phase 2 Revision and submissions to the EIP Panel for land at the former airfield at Fradley to be proposed for housing on previously developed or brownfield land (ie. the original new or extended settlement site), which had support from both County and District Councils, has apparently been ignored as a potential alternative site for strategic housing. The very fact that this proposal is currently "live" justifies the full consideration of the alternative by the Council . The Barton Wilmore submission to the Panel in relation to Sub-Matter 8F(i) includes the following statements:- "brownfield land associated with the airfield at Fradley, a Key Rural Settlement, is available for development of significant scale" (Para 1.5); land there is - "without significant constraint and is available for residential development in the short-term. Development, including a new local centre, would provide additional services for the village of Fradley, increasing its overall sustainability" (Para 1.6); the switch, as proposed, of committed employment land to residential would have "virtually no net impact on the transport network" (Para 1.10). 2. Green Belt and Greenfield Land Whilst Fradley lies outside the Green Belt, much of Lichfield City directly abuts Green Belt. In order to justify development of such areas by means of urban extensions, "exceptional circumstances" are required to be shown. This, the Council has failed to do. Firstly; it has not assessed all viable alternatives for future development, as explained above. Secondly; the only justification provided relies purely on the argument that because Lichfield is one of the two largest settlements in the District, with the widest range of facilities, it is also the most sustainable. Such an approach is extremely short-term and could be repeated at every LDF or Plan review to justify large-scale peripheral growth, leading to continued enlargement and sprawl. Unfortunately, this policy is already apparent, with Boley Park followed by Darwin Park, and now further larger and more intensive proposals, with the environmental impact increasing and the quality of development declining. To address this in a more balanced and appropriate manner, the Society believe it is time for the Council to take a much longer strategic view and make a renewed commitment to the extended settlement approach involving Fradley. This could provide a long term, sustainable solution to continuing development pressures to the benefit of both the existing Fradley village and for Lichfield City. Additionally it would be a re-instatement of a previous commitment of support from both County and District Councils, which has already led to a level of housing development at Fradley which leaves the settlement poorly served in its present state. For clarity, the Society is here referring to the Fradley located on the former airfield (which is brownfield), and generally as promoted and approved through the Staffordshire Structure Plan, and not to the Curborough proposal, which is located extremely close to the built edge of Lichfield and is predominantly greenfield land. Previously the Council in the report of the Society's views erroneously stated there was Society support for the consortium proposal for Curborough. It is considered by the Society that an extended settlement could be successfully developed at Fradley beyond the Green Belt and focussed on the existing Fradley village and South Fradley area. At the same time the development would be located to avoid any concerns of coalescence with either Lichfield or Alrewas. 3. Lichfield City The historic character and environment of Lichfield City would benefit significantly from the approach proposed above to relieve development pressures. Previously both Staffordshire County and Lichfield District Councils and the Structure Plan EIP Panel in their support for Fradley considered this development approach would help protect the historic character of Lichfield from harm created by the pressures from development. Now the Council is saying it is no longer a valid consideration. What has changed ? To date the Council has been unable to demonstrate conclusively that the character will not be adversely affected by further large scale internal and peripheral development. The overall environmental impact of the most recent developments in the City, for example at Darwin Park, has been considerably greater than that of Boley Park and other earlier developments, through its scale, density, massing and lack of open space areas. Darwin Park has had a significant impact on views of the City from the west of Lichfield. It has also resulted in the loss of the Lichfield Cricket and Hockey Club ground that had been on the site for more than a century. Policy QE5, Protection and enhancement of the Historic Environment, of the WMRSS Phase 2 Revision gives strong support to an approach which takes a much greater concern for a city like Lichfield than seems to be the approach currently envisaged by the Council in the strategy. The Policy contains the following highly relevant references, which should provide an overall framework for the more localised policies:- "A. Development plans and other strategies should identify, protect, conserve and enhance the Region's diverse historic environment and manage change in such a way that respects local character and distinctiveness." "B. Of particular historic significance to the West Midlands are:
Earlier in this representation examples of harm to the environment have been referred to, as exemplified in recent housing development at Darwin Park. Further adverse impacts have been listed in the Society's earlier submissions concerning protecting the character and environment of the City. Other impacts of the problems of large scale development are now becoming apparent and are detrimental to the character and environment of the historic centre, and one such example is the large amount of on-street car parking on all the edge of centre streets and roads. Additionally, any loss of open areas adversely affecting the "open grain" of the historic centre and other parts of the City should be avoided, and the effective safeguarding of these areas through such policies as "the Framework Open Space" approach must be maintained and strengthened. The Council statement that:- "The second potential aspect of harm to the character of the historic city relates more to the city centre and through increased activity. This could relate to traffic congestion, or the level of use of city centre facilities, services and streets. There is however little evidence for this argument arising from past significant growth of the city by urban extensions such as Boley Park and Darwin Park" is not accepted by the Society. Few, if any, residents who have lived and worked in the City prior to these developments would agree with these comments. The growth in population has had impacts upon the city centre. Additional pressures for car parking and additional shopping provision have led to a number of initiatives that have had a negative impact on the historic centre. Examples are the impact on open space of the Lombard Street car park and the temporary use for car parking of framework open space at the Lichfield College / University site. On-street car parking is moving progressively outwards on to roads surrounding the City centre which is damaging in visual terms, creates road safety hazards and considerable inconvenience to local residents. The height and scale of approved schemes for development on the Friary Outer car park will adversely affect views of the Cathedral and into the City centre. Traffic entering the City centre and passing through has over the last 20 years increased substantially, with queuing and congestion much worse than it ever was. 4. Framework Open Space The Lichfield District Local Plan policy L49 is important to the preservation of the character of the City centre and its environs. This is recognised in the saved policy comments that "the Policy provides local distinctiveness for the retention of visually important open space. Areas are shown on the Proposals Map. Loss of designation will have potential impact on character / visual quality of the City." The L37 Lichfield Linear Park policy is also very important. The Society believes that the Core Strategy should expressly indicate that the Council will progress policy initiatives to continue the protection the existing policies provide. 5. Affordable Housing Page 34/35 of the Core Strategy Policy Directions proposes that an "aspirational target" of 40% is set for affordable housing, with a threshold of 15 dwellings in Lichfield City and Burntwood and five in the rural areas. The viability study undertaken by Fordham indicates it is difficult to sustain a target of more than 20% without grant assistance and it was also concluded that only half of the sites assessed would be viable if comprising 100% market housing. Paragraph 29 of PPS 3 requires an overall (plan-wide) target which should "reflect an assessment of the likely economic viability of land for housing within the area, taking account of risks to delivery and drawing on informed assessments of the likely levels of finance available for affordable housing, including public subsidy and the level of developer contribution that can reasonably be secured." This requirement combined with the broader plan obligation to put forward sound proposals make it difficult to see how an aspirational target of 40% can be substantiated when Fordham recommended 20%. An unrealistically high target will be an obstacle to any development on sites where the requirement makes it unviable to develop. I look forward to receiving an acknowledgement of receipt of this submission, and the Society continuing to be formally involved in the LDF preparation process. Should you have any queries regarding the contents of this submission, please do not hesitate to contact me. Yours faithfully, John Thompson |
|