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The Lichfield District Local Plan MM15 - South of Lichfield | |
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Development Plans Team Q1. To which Main Modification does your comment relate? - MM15 Q4a. Do you consider this Main Modification is Sound? - No The Society is submitting a separate objection to the release from the Green Belt of the Cricket Lane and Deans Slade Farm sites and their designation as Strategic Development Sites. This representation relates to paragraph 10 of Policy Lichfield 6: South of Lichfield as modified by MM15. It concerns securing early completion of the Southern Bypass and that it should the sole means of access to the South of Lichfield SDA. Alternative changes are set out in Q4d depending on whether the two additional SDA's South of Lichfield sites are found to be legitimate and sound allocations or only the South of Lichfield SDA proceeds. Whether or not the two additional Strategic Development Allocations for Cricket Lane and Deans Slade Farm South of Lichfield City are allowed to proceed, the Plan should ensure that the early completion of the Southern Bypass is a pre-requisite of housing completions. A phasing requirement should be included in the Concept Statements for Deans Slade Farm and Cricket Lane, and re-introduced into the policies for the South of Lichfield SDA. To ensure this, it is suggested that the phasing of development on the Deans Slade Farm should be brought forward to support funding of the Bypass, and its early completion. For the South of Lichfield SDA development, the principle of vehicular access from the Bypass should be re-stated as in the submission Local Plan, with at most a phased proportion of housing completions only acceptable off this route, prior to the completion of the Bypass. It is great concern that neither the Local Plan nor the IDP do require the completion of the Bypass before construction of all dwellings. The addition to the plan of the two large SDA's in south Lichfield with at least 900 additional houses and an employment site of 12 hectares, will generate even more traffic in and out of the City. Without the early completion of the Bypass in parallel with the development of the SDA(s), thus alleviating traffic congestion, delays on London Road and Shortbutts Lane in peak hours will be substantial. IDP (2014 version) includes an expanded explanation on page 14 of the South Lichfield Local Transport Package which includes the following:- "The Lichfield Southern Bypass provides a link between the A5206 London Road and the A461 Walsall Road. Phases 1 and 2 of the bypass have already been completed by developers with Phase 2 opening to traffic in 2010. Phase 3 between London Road and Birmingham Road is not required to deliver the Strategic Development Allocation but is expected to be funded by a combination of existing developer funds, public funds and contributions from future development. The County Council is commissioning design work and a construction cost estimate for the section of Phase 3 that crosses the railway line and links to Birmingham Road. This work is expected to be completed in 2013 and once agreed with Network Rail, the earliest possible construction start date is 2014." Concerning timescales, the reference in the IDP 2014 to the earliest possible start date of 2014 implies that funding and contracts will be in place during this year. Based upon the progress of the rail under bridge construction on the earlier sections of this Bypass which took around 10 years to deliver, it is very optimistic to suggest a start date in 2014 could be achieved. We have been advised that the Highways Authority consider 2017 is a more realistic start date. The IDP as part of the evidence base is seriously misleading in that it implies the under bridge will be completed at an early stage which is clearly not going to happen. For the earlier new rail line under bridge for the Southern Bypass, the County Council secured the legal agreements for its full cost from the Darwin Park developers' consortium before house building commenced. Notwithstanding there were no funding difficulties the County were still unable to progress the under bridge construction for many years. The Plan as modified now allocates sites for a minimum of 1350 houses, an increase of 900. Even with this substantial growth of homes, there is no requirement imposed such that the developers' of the sites will be required to fund and thus deliver the completion of the Bypass. Nor is any time scale imposed for its completion in association with the concomitant housing development. The Plan as published for public consultation did impose a requirement that the Bypass would be the primary source of access for the South of Lichfield SDA. This was relaxed by the Council during the hearing process and paragraph number 10 of Policy Lichfield 6: South of Lichfield has been modified to reflect this concession. The increased allocation and growth in traffic that will arise should be accompanied by the requirement being applied to the three SDA's jointly if allowed to proceed. In terms of reasonableness, the situation on the Walsall Road/Darwin Park development is highly relevant. The original planning consent was for 650 houses. The cost of highway works was funded by the developers. The project involved construction of the first section of the Bypass which involved a rail under bridge, three new roundabouts and one enlargement of an existing roundabout. In addition, a long section of perimeter road of similar specification was built. The total length of Bypass built far exceeds in length the section remaining to be constructed. Since less than half the number of houses on Darwin Park (i.e. 650) were able to fully fund more highway works than twice as many on the SDA's (i.e. 1350 & 12ha of commercial development), the three sites should be able to fully fund the highway works. It is difficult to see any reason why the public purse via the LEP's, other funds or the County Council should meet any of the costs involved. This should be reflected in the conditions applied to the sites. It is common ground that further work is needed and agreement between all the parties to finalise the Bypass design and to facilitate implementation. Some of that work is currently in progress but is not yet in the public arena which underlines the need for clear obligations and commitments to avoid the very long delays that occurred with construction the first rail under bridge and ensure early delivery of the completed Bypass as the sole means of access for the South of Lichfield SDA. We would also respectfully seek obligations being included in the plan that will ensure that the completion of the Bypass is brought forward. This would mitigate the traffic impact arising from the new developments and also make unnecessary the permanent environmental damage caused by the proposal to demolish a house and create the secondary access for the South of Lichfield site off London Road. Suggested revisions are set out in Q4d below. Q4d. If you consider the Main Modifications unsound, please set out what change(s) you consider necessary to make it sound and give your reasons. Two versions of changes are proposed depending whether or not the release from the Green Belt of the Cricket Lane and Deans Slade Farm sites is agreed. 1. Changes proposed if only the South of Lichfield SDA proceeds Amend paragraph 10 of Policy Lichfield 6: South of Lichfield as modified by MM15 which currently reads as follows:- 10 To improve access to the sites through the completion of the Lichfield Southern Bypass. The road network within the site will accord with the 'Manual for Streets'; to revert to the original wording of the submission Plan so that it reads:- 10 The completion of the Lichfield Southern Bypass as the primary source of access. The road network within the site will accord with the 'Manual for Streets'; and to add at the end of the original wording in paragraph 10 the following sentence:- Development associated with the South of Lichfield SDA allocation will not be commenced until proposals are submitted to and approved by the Local Planning Authority and Local Highways Authority that ensure construction of the Lichfield Southern Bypass in such a way and timescale to ensure that vehicular access to the South of Lichfield SDA is only obtained to and from the new Bypass without provision of any alternative access elsewhere. Note: The proposed reversion to the first sentence of original text above brings it into line with unrevised text in Appendix C South of Lichfield which has the following:- "C.8 In summary, the following will need to be delivered:" 2. Changes proposed if the South of Lichfield, Cricket Lane and Deans Slade Farm SDA's proceed Amend paragraph 10 of Policy Lichfield 6: South of Lichfield as modified by MM15 which currently reads as follows:- 10 To improve access to the sites through the completion of the Lichfield Southern Bypass. The road network within the site will accord with the 'Manual for Streets'; to revert to the original wording of the submission Plan so that it reads:- 10 The completion of the Lichfield Southern Bypass as the primary source of access. The road network within the site will accord with the 'Manual for Streets'; and to add at the end of the original wording in paragraph 10 the following sentence:- Development associated with the South of Lichfield SDA, Cricket Lane and Deans Slade Farm SDA allocations will not be commenced until proposals are submitted to and approved by the Local Planning Authority and Local Highways Authority that ensure construction of the Lichfield Southern Bypass in such a way and timescale to ensure that vehicular access to the South of Lichfield SDA is only obtained to and from the new Bypass without provision of any alternative access elsewhere. Note: The proposed reversion to the first sentence of original text above brings it into line with unrevised text in Appendix C South of Lichfield which has the following:- "C.8 In summary, the following will need to be delivered: The completion of the Lichfield Southern Bypass as the primary source of access. The road network within the site will accord with the 'Manual for Streets';" Reasons for the proposed changes The reasons for these amendments are to ensure timely completion of the Bypass and avoid the need for provision of a second vehicular access from London Road to serve the South of Lichfield SDA. Such an access would only be required if the rail under bridge and link to the A5127 Birmingham Road roundabout were not delivered prior to the level of development on the South Lichfield SDA that requires a second road access be provided. The advantages of ensuring all vehicular access is off the new section of Bypass are:- the unacceptable scale of environmental damage likely to be experienced by residents of London Road would be avoided; there is a high risk that the London Road access will be the first and for some time the only site access with consequent disruption and disturbance from construction traffic and other vehicles accessing the site; a mature and attractive house on London Road would not need to be demolished; the adverse effect on neighbouring properties on London Road of a new road would be eliminated; it avoids the need for an access road to London Road which would encroach into the Green Belt; the need for sound insulation to residential properties for traffic noise affected by road alterations would be reduced. The Council's indicative layout is preferable to the developer's revisions. There would be one less junction on London Road which, after the Bypass is built, will be an even busier and more complex section of road. It focuses the developers' on securing timely completion of the Bypass. Q5. Can your representation seeking a change be considered by written representations or do you consider it necessary to participate in person at an examination hearing? Delivery of the Southern Bypass is a crucial component of mitigating the impact of additional traffic arising from permitting SDA(s). Delivery of the Bypass should be in a way and timescale that ensures vehicular access to the South of Lichfield SDA is only obtained to and from the new Bypass without provision of any alternative access elsewhere. Ensuring timely delivery of the most sustainable infrastructure should be a priority and explicit requirement of the Plan. John Thompson |
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