Response to Carlisle Development Framework






We welcome the opportunity to respond with our views on the Draft Development Framework and thank the Authority for agreeing to accept our response beyond the advertised date for closing the consultation (Stage 5 of the process). This has raised some concern in that we are sure we are not the only interested organisation where a consultation period, consisting mainly over the month of August, presents timing difficulties in respect of regular meeting dates, discussions and response. Given that the process has been in preparation for well over a year the proportionally short consultation period for something so significant to the City can only engender missed opportunities of interaction and foster frustration and potentially consultation fatigue. Wider publication and consultation periods of 2 -3 months would seem to be more fitting for major proposals that set or steer expectations for the next 16 years.


We here number our responses for ease of any future reference:


1.The Trust found the GVA report well set out and straight forward to follow but its content and format did raise some concerns:


  • The terms of reference are not clearly stated. It is difficult to establish what, if any, decisions the Authority had already made before commissioning the report so it leaves an element of doubt inh the readers mind as to what aspect the Authority is responsible for and what contribution and guidance is being made by the consultants. The reader is left with the impression that they are not seeing the whole story.


  • According to the report title there is an expectation of a comprehensive assessment of all potential development issues and options within the City Centre.   What is delivered is a fairly direct assessment of meeting only retail needs arising from the Retail Study by the same Consultant carried out for the Authority in 2012. Where other aspects are touched upon they are seen only in the context of meeting the 200,000 sq.ft. additional retail need set down by the former study.


  • We are surprised that the opportunity was not taken to commission a different consultant to the company that had undertaken the Retail Study. Doing so would have more genuinely affirmed or indeed challenged the former findings in a more dispassionate way leading to stronger and more valid advice.


  • Inclusion of quite specific sketch scheme visuals and layouts for the option ‘preferred’ by the Consultants/Authority together with indicative images from different cities may have been intended to explain scale and potential outcomes to the general public, however, the Trust believes such detail is premature and stifles consultation at this stage. Such a practice may be, on the one hand, informative but, on the other, suggests development work has already proceeded past the decisions under consideration – ie. what point is there responding, the matter is clearly a ‘fait accompli’.


2.The Trust recognises that the Authority is required to prepare a new Local Plan up to 2030 in line with National Planning Policy and to meet the recommendations set down within the National Planning Policy Framework (NPPF) and National Planning Policy Guidance (NPPG). The compulsory requirement to present an ‘evidence base’ and realistic ‘deliverability’ is clearly key to a Local Plan being supported by a Planning Inspector at the eventual formal public inquiry. Whilst the 2012 Retail Study represents a major element of the evidence base required it does not conclude that the 200,000 sq.ft. additional requirement by 2030 should, necessarily, include provision for a major anchor store which would take a lion’s share of the projected need. The Trust notes that it is only approaching 2030 that this level of expansion demand is predicted.


The Draft Framework, however, appears to follow the new anchor store model upon the basis that Carlisle shoppers have expressed a desire for stores such as ‘Primark’ open in the City – alternative strategies appear not to have been fully investigated such as aggregating vacant outlets in the Lanes to form potential far larger units. The Trust considers that this new anchor store development approach is potentially damaging. A new anchor store and supporting unit development will inevitably encourage the national chain outlets to consider re-locating closer to the ‘new’ development to benefit from perceived improved popularity (footfall). This can only damage The Lanes where maintaining full letting has proven difficult of late. There may be benefits to consideration of re-development within The Lanes for larger stores maintaining potential for medium sized retailers to cluster around in existing or improved property including historic frontages that may improve the attractiveness of Carlisle as a shopping destination not restrict it as the GVA report concludes.   Yes, the appropriate   refurbishment of historic frontages will be more costly but the Trust feels that it is inappropriate in a city such as Carlisle for the retail ‘tail’ to wag the city ‘dog’. We are also surprised to see a particular store chain being named (Primark), in fact repeatedly, – surely the store chain will take confidence from this and negotiate from a much stronger position suiting their commercial needs over the views of the City?


3.Given the considerations above, the options put forward in the Draft Framework appear too limited and restricting. The expectation of major redevelopment on Rickergate is too damaging for the City long term. Insufficient weight has been given to the redevelopment of the Citadel area where it is considered lease timing to existing proprietors is not an encumbrance to ‘deliverability’ as the retail study is only identifying the major expansion toward the end of the planned period. Retaining Rickergate ‘in the mix’ for developers’ consideration seems wise but the Trust’s view is that further consideration to scope potential for larger stores formed out of the original Lanes is also appropriate and only then directing developers/retailers to investigate the potential of the Citadel probably before Rickergate.


4.Part of the Draft considers the alterations/adaptation or removal of the 1960’s Civic Centre building. The Trust is opposed to this proposal upon the quality of consideration and justification of the Draft Framework. It is an iconic building, highly regarded in its day and it represents the spirit and times of a period in history that will not be repeated. It does not command such quality and protection in perpetuity, however, it is considered significantly enough to be of greater value than replacement by such ephemeral and short term development as a retail floor plate when there are arguably better options available as considered previously. Re-use and upgrading will be a necessary part of its near future but doubt as to its future is believed to be unwarranted and should be removed from the current options.


5.Concern has been voiced within the Trust that identifying only one area to accept the 200,000 sq.ft. required retail expansion has a significantly negative effect upon residents and businesses in the locality. Doing so may well meet the NPPF requirement for deliverability and certainty but a blighting effect can be predicted and justifys an open range of options to the Local Plan Inspector. Carlisle has experience of the negative effect of site zoning when The Lanes was first red lined for redevelopment – as there was no developer, funding or firm proposals at the outset the opportunity to consider the repair and maintenance of what was a unique mediaeval town layout was lost and the businesses and residents were caught in an equity trap that led to long term demolition and decay. The Trust does no wish to see such a circumstance fall upon Rickergate.


6.In conclusion, the Trust would like to see the Local Plan incorporate a wider vision of how the City Centre can develop positively. Support for what is often termed the historic quarter, suggestions as to how amalgamation of empty retail units can better meet market needs and suggestions and support for specialist retail outlets that add to the vitality of the shopping experience that may struggle to meet city centre rents.   In short a comprehensive framework for all city centre activity.







Carlisle & District Civic Trust                  


29 September 2014