Planning

The Director of Planning and Environmental Services
Lewes District Council
Southover House
LEWES

7 January 2005

Dear Sir,

PLANNING APPLICATIONS LW/04/2398, LW/04/2410 & LW/04/2411
LEWES HOUSE & SCHOOL HILL HOUSE GARDEN SITES

1. The Society has carefully considered these planning applications. Although it has long since accepted the case for residential development on these Council owned sites, it has reservations about the current proposals and, as a result, it wishes to formally object to them.
2. Bearing in mind the time that has elapsed since the Council selected Ash Mill Developments to work up proposals for the sites, the Society is surprised that major parts of the Development Brief, as amended by the District Local Plan, have been ignored without any justification being offered as to why. Whilst Ash Mill consulted the Society shortly after their selection they have not done so on their detailed plans although a presentation of them was made to the Town Council, to which Society representatives were invited, once they had been finalised. This has meant that there has been no opportunity to discuss the detailed issues with Ash Mill that are raised below. In view of the height and bulk of the buildings proposed either a model, or computer generated views, or preferably both, should have been provided in order to assess the overall effect of them on the surroundings. To submit a planning application for a large development in the centre of a historic town such as Lewes without any such supporting material is unacceptable. The Society therefore objects to the information submitted being inadequate to properly consider the application.
3. In summary the Society’s detailed objections, which are discussed below, are to: -
   1. The height of the buildings proposed on the Walwers Lane site;
   2. The increase in the total number of housing units being provided;
   3. The failure of the design to reflect the vernacular;
   4. The lack of an irregular roof line;
   5. The failure to embrace sustainable principles;
   6. Total openings in the twitten walls;
   7. Inadequate car parking provision;
   8. Removal of trees on the Walwers Lane site.
4. Height - The Society notes that para 4.6 of the Development Brief said that the height of buildings should normally reflect the height of existing buildings and that anything higher than 3 storeys should be justified as an exception. It also notes that para 4.4 said that buildings should not directly face the existing residential buildings in Walwers Lane and avoid an overbearing effect. These important requirements in the Development Brief have been ignored. The requirement that buildings should not directly face the existing residential buildings in Walwers Lane should be enforced and adjacent buildings should be no more than two storeys in height. In addition high buildings on either side of Church Twitten appear likely to compromise the largely enclosed views within it. The Society therefore objects to the height of those buildings that do not meet the requirements of the Development Brief.
5. Density - The number of housing units has been increased from the original 40 plus mentioned in the Development Brief to 60 plus in the District Local Plan and 79 in this application. Whilst it might have been better to have measured density by the number of bed spaces rather than housing units, no explanation has been given for this increase which has clearly lead to higher and bulkier buildings being proposed. For this reason alone the Society objects to the density. In addition, where the town’s infrastructure is inadequate for the development, it suggests that commuted payments are sought in order to improve those services. In that connection it notes that para 3.2.4 of the Development Brief mentions that the County Council would seek a contribution to address capacity problems at nearby primary schools.
6. Design & Materials - The Society considers it important that the roofline should be irregular when viewed from afar, such as from Chapel Hill. The roofline on the Walwers Lane site seems particularly inappropriate. Using various roofing materials, such as a mixture of clay tiles and natural slate, and breaking up rooflines with, for example, dormers could achieve this. Using dormers would also enable the roofline to be lower without reducing the accommodation provided. More generally the design does not reflect the character of the town and the Society considers that an overlapping roof design, large windows and balconies are inappropriate on this site. Whilst it likes the use of render it is concerned about the over-use of flint panels, particularly if they are of a mediocre quality. The Society therefore objects to the design and materials to be used in construction, as they do not properly reflect the character of the town.
7. Sustainability - This development, the new library and the neighbouring Raven Group development presented a unique opportunity to propose a sustainable approach to minimising energy use by using a central combined heat and power boiler with a hot water distribution system which could have been designed to allow conversion to other fuels in the futures. Other sustainable methods of providing energy, which are not mentioned, are solar panels and ground source heat pumps. The need to minimise energy use was referred to in para 4.10 of the Development Brief and the Council has published a draft Energy Policy that includes a target of meeting 10% of electricity from renewable sources by 2010. The Society objects on the grounds that the requirements of both documents have been ignored. A further point is that the Society expects the development to comply with the proposed revisions to part L of the Building Regulations. The developers should not be permitted to make an early start in order to circumvent these amendments.
8. Flint walls - Whilst the Society welcomes the development of pedestrian routes through the site, it considers that these should be open all 24 hours of the day and that a private lockable estate should be prevented. It accepts the need for the small number of pedestrian openings proposed through the flint walls but considers that openings in the east wall of Church Twitten should have an arched finish. It therefore objects to the proposals to have full height openings in some of them. In addition particular care will be needed with the quality of restoration of those parts of the flint walls that need to be demolished during the construction phase whilst all other flint walls around the site need to be carefully protected and, as necessary, repaired as part of the project.
9. Parking - Although the idea of many of the residents on this site having no car is laudable, the Society considers that this is unlikely to happen in practice and, as only limited parking is provided on the site, there will be an increase in the number of vehicles seeking parking places on surrounding streets. It therefore objects to the lack of adequate parking provision because of the detrimental effect that this will have on the town. It considers that more underground parking could have been provided on the site. In addition changes should be considered to the controlled parking scheme to provide for increased residents parking both in nearby streets and also in District Council owned car parks, on the assumption that residents on the site will be able to purchase residents parking tickets. The developers could also finance the provision of additional off street parking nearby; the decking of the railway station car park would be the nearest sensible option.
10. Trees - The Society welcomes the open space provision and the retention of most trees on the site. However it objects to the reduction of trees on the Walwers Lane site and considers that the existing trees, for which a detailed survey is required before construction starts, should be properly cared for during the construction period.
11. Archaeology - Since the site is very much part of the historic town the Society considers that a full archaeological assessment should be made before any construction commences.
12. In view of the Society’s objections to the proposals it is suggested that consideration of the applications is deferred to give Ash Mill an opportunity to make amendments to their proposals that meet the Society’s points. In this connection this proposal is one of the most important to be considered in the centre of Lewes for some time and it is vital that what is eventually agreed is worthy of a 21 st century development that complements the existing built environment in this historic town.
13. If despite this objection the Council is minded to grant planning permission the Society recommends that conditions are attached to ensure that: -
    1. the materials used reflect the existing character of the town
    2. all flint walls on the site are restored as necessary;
    3. trees remaining on the site are properly cared for;
    4. an archaeological assessment is made before constructions starts.
14. In addition commuted payments should be sought to finance additional off street car parking, new trees in public places to replace those cut down, and any other infrastructure improvements needed as a result of the development.
15. The Society is very concerned, and profoundly disappointed, that the developers appear to have been allowed to ignore so may of the provisions of the Development Brief. The time and effort put into preparing this document by members, officers and consultees, including the Society, seems to have been largely wasted.
16. Finally the Society trusts that the Council will consider the applications on planning grounds alone and not allow its interests in wanting to derive maximum gain from the sale of the site to cloud its judgment.

Yours faithfully

Robert Cheesman