Comments on the Santon Planning Application

Objections by Vic Ient of Save Lewes Architecture to planning application SDNP/15/01146:

This opportunity to create something worthwhile for townspeople is an exciting one but it must be approached with an eye to what is genuinely needed and what will enhance both the town and the National Park in which it lies.

National Park Duties

I respectfully remind the National Park, as listed in the Act of 1949 of its purposes:

The Environment Act 1995 revised the original legislation and set out two statutory purposes for National Parks in England and Wales:

  1. Conserve and enhance the natural beauty, wildlife and cultural heritage.
  2. Promote opportunities for the understanding and enjoyment of the special qualities of National Parks by the Public.

When National Parks carry out these purposes they also have the duty to:

  • Seek to foster the economic and social well-being of local communities within the National Parks.

The words ….conserve and enhance cultural heritage… and together with …foster the economic and social well-being of local communities, particularly resonate.

The words …enhance the natural beauty… as well as Promote opportunities for understanding and enjoyment…. are especially relevant to the river frontage.

Public Consultation

This application includes literally hundreds of documents. Most members of the public have found it bewildering as to where they start even to understand the proposals, let alone comment on them.

Santon did carry out public consultations in the lead up to the application, which is to their credit; however, with the submission of the application itself there should have been a final exhibition and conference of the actual plans & details, so the developer could fully explain their proposals and give the public a chance to directly question the developer on particular aspects of their proposals. This application should not be proceeded with without that public exhibition and conference. The SDNPA should organise a public exhibition and conference now!

There is a perfect opportunity to do this in June & July 2015. I understand that the Lewes Neighbourhood Plan Group (set up by the Lewes Town Council) is to hold a Plan ‘Visioning Day’ on the 4th June and a 3 day ‘Forum’ between the 30th June and 1st and 2nd July! The Santon application could be on exhibition during these times.

I understand that Santon, LDC & SDNPA already have a project group. I suggest that this project group sets up a ‘reference group’ of all stakeholders, including the existing businesses which operate in the North Street area. This group can be consulted with, by not only holding meetings, but by electronic means (for speed & efficiency) by using up to date internet collaborative tools. This stakeholder group can then remain in existence thought the life of the project (including the implementation stage) helping to achieve a ‘best fit’ solution for all concerned.

Apart from the major issues, like the loss of employment on the site, there are the myriad of detailed design & site layout aspects which have not been tested against public opinion or with interested parties.

The National Park should separate out principles from details. At this stage the Park should only consider the principles of purpose, key planning issues and overall architecture. Details should be considered on an incremental basis at a later stage to allow people to understand them and comment on them.

I suspect that we will live to regret the day when so much detail is passed through unnoticed amid a mass of documents and drawings. Yes, plans are on the web, and yes, one can go and see the documents, but as one council official said to me “to really understand the documents you need to set aside at least two or three days to study them.”


What is desperately needed is genuinely affordable housing, ideally “social” housing, so that the District Council can reduce its very long housing waiting list. Does the plan provide for houses to rent as well as ‘affordable housing?’

Some 400 houses are proposed. It appears that 40% are to be ‘affordable.’ But how many are designated for rental? Any planning permission should be conditional on a significant provision of rented and affordable homes. Perhaps they all should be?

Is there not an opportunity to increase the number of dwellings in some parts of the development by increasing the density per hectare more akin to what exists in Lewes already? This might allow a more appropriate level of commercial development to be provided, whilst at the same time still delivering over 400 homes on the site.

Working Together – LDC + Santon + Phoenix Rising?

This application ignores the enormous potential of the developer and the local people as well as the Council working together as a team. There is still time for the national Park to bring together these organisations to work for the benefit of the town and all concerned.

There is enough division in politics and in society – here is an opportunity to shine a beacon of light and show how major planning applications should be handled, – by working together!

Architectural and artistic heritage

Lewes has a unique and varied architectural and artistic heritage and these must not be abandoned. The key historical buildings in this area should remain and be enhanced.

The plan offered suppresses the real industrial heritage of this town, and sweeps away usable buildings. I believe this application pays no regard to the industrial heritage of this town.

Demolition of the Phoenix Iron and Steel Works

My particular concern is with the plans to demolish the remaining buildings of the Phoenix Iron and Steel Works and the loss of workspace this involves.

The existing buildings could easily be renovated to be useful and attractive to the town and a destination for its visitors, something which few new build developments could achieve.

Pastiche ‘industrial’ buildings

The developer has designed in a ‘Chimney Building.’ This resembles nothing previously built here. It confuses the understanding of the history of the site.

Please refer to the archive of Edward Reeves, the photographers established around 1855 and still continuing, provides photographic evidence of the Works and also of the variety of products made there.

Lack of innovation towards zero carbon energy and environmental goals

Santon and LDC are disenfranchising the people of Lewes and the future occupants of this development from participating in a future zero carbon society.

The provision for electric car charging points is paltry. Where are the electric van charging points?

Renewable energy is offered as an ‘also-ran.’ The developer offers a traditional approach to the prime form of heating for the development using gas. Solar seems to be offered as an option as is the possibility of using the river for ‘district heating’. Is the mention of these renewable forms of heating, just to get a ‘tick in the box’?

Santon and the LDC have a golden opportunity to install a fully functioning zero carbon heating system. If it is not done now, it never will be. Santon is preventing Lewes from taking a real step into the future. Remember these houses and other buildings are going to be here for many decades. Build for the future, not the past!

Public Transport

There are hundreds of documents submitted by the developer and I may have missed one on public transport. However, the question must be asked:

Has consideration been given to providing bus services in the site? Is there a bus turning area? Where will the bus stops be?

Increased vehicular traffic in the town?

There are a large number of documents to plough through in this application and I may have missed one concerning traffic issues across the town. Before approving this application the National Park should be assured that this development will not simply just increase vehicular traffic through the existing narrow streets of the town.

The provision of a large number of car parking spaces must not act as a magnet to draw vehicular traffic through the town. The aspect of infrastructure integration with the rest of the town has not been thoroughly investigated.

The neighbourhood plan for Lewes is in its embryonic stage but it is clear from the discussions that have already taken place that the people of Lewes want to reduce the traffic through the town, not increase it!

Continuous riverside ‘green’ walkway?

It seems that a continuous walkway with a ‘green frontage’ to the river has not been fully included in the development. This is an opportunity missed. There are steps leading down to the river at one point, but what provision is there made for some form of quay for tying up boats (always taking account of the tide, of course) alongside part of the development?

Loss of Jobs

The proposed development sweeps away virtually all of the existing buildings and with it some 400 to 500 jobs.

Yes, we need housing, but we also need jobs. Is it really necessary to take such a Draconian step to allow this development to go ahead?

There is no satisfactory alternative proposed by Santon and thus the National Park should impose an incremental approach to this development such that the sites which employ people are integrated into the development on a gradual basis. Yes, for the building construction crews this would be more difficult, but for the livelihoods of people in this town it would be a godsend.


It seems that the Santon plan provides 8,500m2 of workspace on the North Street site providing:

6,029m2 for a Health Centre
1,256m2 for Business/retail
865m2 for cultural/creative space/restaurant
300m2 for double height workshops

Has someone got the whole thing wrong at Santon?

No doubt high rents will be charged for the commercial space, which will mean that the cultural/creative space will be out of reach for artisans and small businesses. Has someone left a zero off the allocation for workshops?

A survey commissioned by Santon themselves estimated that about 5,000m2 is currently being used by the ‘creative’ workshops alone! Lewes Phoenix Rising estimates that on the North Street Estate they are using a minimum of about 10,000m2.

The National Park should require that Santon revisit their provision of workspace for this site before any application is seriously considered.
The Pells play area

Currently this area is perfectly secure so that parents can sit and watch their children using the play equipment and the grassed areas safe in the knowledge that the area is enclosed and cannot easily get out of the site except via a clearly visable gateway.

However, the proposal by Santon seems to offer an opening up of public access way out of the site towards the river. Is this necessary?

“Rain gardens” & “Swales”

The developer proposes to include “rain gardens” as part of the ‘greening’ of the site. When I visited one of the exhibitions I asked the Santon representative to explain these. He said it was to prevent the rainwater from gushing into the river and contributing to flooding. That may be a laudable effort in order to prevent flooding, but at the same time, it might be creating ‘swamp’ like habitat close to houses which will only serve to breed insect such as mosquitoes. Some people are extremely allergic to mosquito bites and with the threat of malaria getting closer to these northern areas of Europe this type of provision should be avoided.

Detailed design

It seems that part of this development is already scheduled as a detailed application, even including street names!

The external finish of the houses should be the subject of a separate application so that important details are not lost in the rush to approve the overall development. For example, in the present application it seems as though the external finish includes prefabricated window frames which are certainly not compatible with the architectural heritage of the town!

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