The Society has submitted comments on the draft neighbourhood plan for the town of Lewes as follows:
Lewes Neighbourhood Plan
These are the comments of the South Downs Society, the national park society for the South Downs National Park.
The Society regards the neighbourhood planning process as a key element in setting the statutory planning framework for future decision making. With Lewes being the largest settlement in the national park, a coherent neighbourhood plan is essential for the conservation and enhancement of the special qualities of this part of the national park.
The Society recognises the considerable work that has gone into the preparation of the draft plan, and the efforts made to engage the public in and around the town in the process. The key document produced is attractive and accessible and the Town Council and the plan steering group are to be congratulated.
We welcome the emphasis in this brief summary on low-cost housing, green spaces and the natural environment around the town.
Introductory remarks and vision statement
These are a welcome identification of what makes Lewes “Lewes” – its history, geography, built heritage, creativity and non-conformity. It is right that these characteristics of the town should run through what follows. We endorse the vision statement and supporting text and note in particular such phrases as:
“acknowledging the part that the historic and environmental setting of Lewes has played in shaping our town”
“brownfield sites should be developed to avoid greenfield development especially on downland.”
“wide range of housing and work space options”
“resilient to the effects of local and national climate change”
“improvement of access to the town, particularly for pedestrians in the central area, and the development of routes for walking, cycling and public transport to service outlying areas and to connect with the town centre”
The Society welcomes the concept of “Lewes low cost housing” (p.27) and the contribution it can make to providing new housing that is genuinely affordable for Lewes people.
The Society supports all of the draft policies as being appropriate for the special circumstances that obtain in the town. We will not list them here: they seem well thought through and reflect the special qualities of the town “going forward”.
We note with approval draft policy PL2 Architecture and design and the comment (p.84):
“Lewes has a unique position in the South Downs National Park because of its attractive Medieval and Georgian central area and largely unaltered Victorian and Edwardian residential streets. New designs need to take heed of the reason why Lewes was included in the South Downs National Park”
And we note with interest draft policy HC2 (p.42) and its proposal to reconsider the use of the Phoenix iron foundry within the North Street development. As this Society sought consideration of the retention of this element of the Phoenix site in its response to the planning application for North Street, we would support this policy.
We note (p.54) that “during the plan period, Lewes can meet its housing needs within the settlement boundary without recourse to greenfield sites beyond”.
Two key questions arise from this welcome statement:
- Can sufficient sites be developed from those possibilities outlined in the draft plan to meet the target of 220 dwellings? If some prove undeliverable on practical or physical grounds or as a result of valid objections, will the above statement of intent hold good? This Society regards that intention as imperative.
- Is the 220 target likely to be affected by current legal uncertainty over proposals elsewhere, in particular at Old Malling Farm? Again, it is imperative for the integrity of the neighbourhood planning process that all of the good work carried out to date is not rendered irrelevant by decisions made elsewhere.
Allocated housing sites
This exercise appears to have been carried out with skill and sensitivity. We have studied not only those sites allocated but also those considered and discounted. While other organisations and individual respondents may present valid concerns about specific sites, this Society finds little on which to express concern in terms of meeting national park purposes.
We do however raise a strong query about the Spring Barn Farm site (PL1 50) which would constitute an unwelcome development almost in open countryside and an unhappy incentive to farms and other rural businesses to erect non-residential buildings with the prospect of securing residential value at a later stage.
We also note that a number of sites allocated for housing are currently used for car parking. If these are lost as parking spaces, there will need to be a compensatory and comprehensive approach adopted across the town to rationalise provision. This appears to be recognised in draft policy AM3.
Appendix 5: Key views to be protected
This is a welcome appendix to the plan and we are very pleased to see the iconic views identified.
Appendix 6: Contributing organisations
A useful list but could we please be given our correct title of South Downs Society?