Lichfield Civic Society response – Local Plan Allocations Examination (Matter 9) Inspector’s Matters, Issues and Questions Matter 9 – Are the Plan’s provisions for Lichfield city centre, including policy Lichfield 3 and Map 8.1 justified and effective? 9.1 Is the Plan sufficiently focused on protecting and enhancing the character and appearance of the city centre? Lichfield Civic Society’s response 1. It is not considered that the Plan's provisions for Lichfield city centre provide for an acceptable balance between development and enhancement of the character of the important heritage asset that constitutes the City Centre and supports local distinctiveness. The first sentence of Policy Lichfield 3 (Lichfield Economy) sets out a seemingly unachievable desire for the two elements of major development and enhancement of the historic character to take place. 2. The City Centre is compact and of relatively small scale, which is fundamental to the character of the City Centre, and is, therefore, sensitive to large scale change, and yet at the same time there are contained within the Plan proposals of very considerable scale, in part referred to in Policy Lichfield 3. The overall scales of development being put forward for each of the following uses, i.e. retail, leisure, office and residential, is individually and cumulatively excessive, and cannot be realistically achieved without damage to the historic fabric and character of the heritage asset. Various examples have been quoted in our written submissions of inappropriate recent developments which do not enhance, but detract from, the character and appearance of the area. These include the Premier Inn, Swan Link Road, the Bromford/Outer Friary Housing, The Friary, and Chapter House, The Friary, where inappropriate design, massing, building height and material have each contributed to the problem. The priority weighting in each case clearly appears to have been given to development rather than to enhancing the heritage asset of the City Centre, to its detriment. 3. Overall the scale of development being sought exceeds the "environmental” capacity of the City Centre to accommodate such, and the policy fails to be positive in seeking to achieve balance between the two elements. It is considered that if the requirements of the NPPF were fully taken into account, and the relevant Plan policies reviewed, the on-going pressure on the historic environment and heritage asset could be addressed satisfactorily. 4. In conclusion, the Civic Society consider the Plan's provisions for the City Centre in Policy Lichfield 3, are too generalised and fail to provide for an effective direction and focus, and in their present form do not give sufficient priority to protecting and enhancing the heritage asset of the City Centre when considering development proposals. A number of policies need to be strengthened, including Policy Lichfield 3, BE1, BE2 and CP14, or ‘saved policies’ continued, including L37 (Lichfield Linear Park) and L49 (Framework Open Space) in the short term, as stated in our written submissions 6.1, 6.2 and 9.2 in order to safeguard the character of the historic environment and distinctiveness of the City Centre's heritage in line with the NPPF. In the longer term, and certainly as part of the Local Plan Review, the preparation of an Area Action Plan for Lichfield City Centre would be supported by the Civic Society. Lichfield Civic Society response – Local Plan Allocations Examination (Matter 9) Such a document is supported because it would contain more detailed policies than currently available, including conservation enhancement policies, and also it could cover transport and access matters, such as a car parking strategy, pedestrian and cycle way links, and it could present the opportunity to improve the workings of the current City Centre pedestrianisation scheme. 5. At the end of this statement is a brief perspective note on the Lichfield City Centre. 9.2 What is the rationale for deleting policies L37(Lichfield Linear Park) and L49 (Framework Open Space)? Lichfield Civic Society’s response 1. The Civic Society consider there is no justification for deleting either of these two polices from the Plan. Because of their value in helping to safeguard the character and distinctiveness of the City Centre and its immediate surrounds and the unique nature of the heritage asset, focussed upon the Conservation Area, with its various elements, the reasons for retention of these policies in the Local Plan are as strong as ever. 2. The two policies help to support a mix and balance to the constituent and inter-related elements of built environment and open areas that is a distinctive and special feature of Lichfield City Centre and its immediate surroundings. 3. The original explanation for justifying the policies has hardly changed, as the following shows. The Lichfield Linear Park policy (L37) was stated to be devised to ensure retention and integrity of the corridor of open space passing through the heart of the City (Beacon Park, Minster Pool and Stowe Pool). It could now also encompass the open corridor running north past Netherstowe School to the edge of open countryside beyond Eastern Avenue. The Council’s stated objective of the Policy was to prevent development "destroying or impairing the integrity of the linear park". This Policy was well-founded and has been very largely effective and should be retained. Otherwise, if the land is left without designation, development pressures may erode or destroy the area's character. In addition to retention of the Policy, because the City Centre Inset Map contains no open space safeguarding designations for much of the extent corridor, this also needs to be rectified, otherwise development pressures may lead to losses of the open areas. At present, only Beacon Park is given protection because of Green Belt designation. 4. The Civic Society has similar concerns regarding the deletion of Policy L49, Framework Open Space. This designation was introduced and included some eight areas of land and was to ensure built development did not adversely affect these areas of public and private open space, which were judged by the Council to constitute " a vital component of Lichfield's landscape" providing an attractive contrast to the urban character of the historic city centre and surrounding residential areas. Lichfield Civic Society response – Local Plan Allocations Examination (Matter 9) 5. Unfortunately, even before any formal deletion of Policy L49 has taken place, decisions have been made leading to incursions into the safeguarded areas, and the precedent should not be followed further. There has been loss of framework open space where an area of pay and display car park has been approved and constructed on the former school playing fields adjoining the University site at The Friary. Originally approved on a temporary basis, this site has now had renewed consent granted, and in addition a planning permission has been issued for part of the site for use as a coach park. The reversion of this area of land to open space use in future is now considered unlikely, particularly as there will be no policy justification once L49 is deleted. 6. The Civic Society is concerned that without Policy L49 ensuring protection similar decisions for incursions of development and loss of open spaces will take place, to the overall detriment of the character and distinctiveness of the area and the heritage asset of the historic City Centre. 7. To make the Plan sound in accordance with the NPPF both Policies L37 and L49 should be continued or reinstated, and the areas of land included within the Policies denoted on both the Plan Proposal Map and the Plan Insets. Subsequently the heritage assets of open space in the City Centre in the City Centre could be protected by its designation by the District Council as Local Green Space (NPPF paragraph 99). The City Centre of Lichfield: A Brief Historical Perspective “Almost in the middle of England, this cathedral city has much for us to see that is lovely and of deep interest. It has the smallest and yet perhaps the most graceful of our cathedrals, standing on one of the earliest English sites of a Christian church. From its 16th century grammar school has gone out into the world a group of boys whose names are famous in literature, law, the church and the stage; and in one of its 17th century houses was born our illustrious Samuel Johnson, the most famous man of letters of his day, creator of the first adequate Dictionary of our language”. Thus, wrote Arthur Mee in his Staffordshire volume of the King’s England in 1937. Eighty years on, Arthur Mee would still recognise many of the buildings he so admired in modern Lichfield, which remains a small, essentially Georgian, city. Undoubtedly, the jewel in the crown is the thirteenth century cathedral, prominent amongst English Cathedrals for its three spires. Its setting adjacent to the Minster Pool and larger Stowe Pool “assures it of a picturesqueness of setting which none can emulate. Moreover, it has a Close more complete than most and more intimate than many” (Pevsner). It contains many fine listed buildings, notably the former Bishop’s Palace built in 1687. At the entrance to the Close, Darwin House can be found. This listed Georgian building was home to Erasmus Darwin, grandfather of Charles, and himself a doctor and noted polymath. He was a founder member of the Lunar Society. Lichfield City Centre retains its medieval street pattern, originally laid out by Bishop Roger de Clinton in the 1140s. It received Conservation Area designation in 1970. Lichfield Civic Society response – Local Plan Allocations Examination (Matter 9) The Market Place is bordered by St Mary’s Church, currently (2018) in the course of conversion to the public library, and, notably Dr Johnson’s House and Birthplace Museum.