The North Street Quarter Development: Statement of Community Involvement, February, 2015
1. The Statement of Community Involvement, February 2015 submitted by the applicants notes that the National Planning Policy Framework (NPPF) identifies public consultation at the pre-application stage as a key component of the new planning system, but that consultation is not compulsory (paragraphs 188 and 189).
2. Nowhere in these documents is Lewes District Council (LDC) mentioned, yet LDC holds the second largest parcel of land (after Santon 53%), at 26%; the remaining land is owned by private individuals/organisations.
3. It is disappointing that LDC has not carried out its democratic leadership, engagement and place-shaping duties by taking an active and visible part in the pre-application public consultation stage of the joint application for North Street Quarter, as outlined by NPPF, quoted above.
4. LDC’s failure to recognise its role in community engagement, and its decision not to participate in it, show that it has not led or owned the community involvement process, and has failed to acknowledge its duty to exercise the powers that it holds on behalf of the community. The NPPF regards it as good practice for these powers to be used for the stated wishes of the community.
5. This failure is a major omission, because the town does not yet have a Neighbourhood Plan and the Joint Core Strategy (Local Plan), yet to be approved, does not acknowledge the existing creative industries and other businesses on the site, or its heritage. In addition, there is a lack of transparency regarding the benefits that would accrue to Lewes town from this significant and strategic development. No documents are available publicly on the LDC agreement with Santon Group, but the inference must be that LDC has decided that there is no benefit from these businesses and industries, despite their very substantial contribution to the town’s productivity and employment, and their collective value as an industry hub. Such a collection of interconnected businesses is easily destroyed, but very hard to replicate.
6. The same NPPF 2012 document cited above also states that:
“applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Proposals that can demonstrate this in developing the design of the new development should be looked on more favourably” (paragraph 66)
No evidence that either Santon or LDC has worked closely with the businesses and creative industries on the site that would be directly and adversely affected by their proposals has been submitted. These businesses/small industries have not been given the status of ‘stakeholder’ and consulted. Neither is evidence provided of any of the identified stakeholder groups acting on their behalf. The consultations carried out and documented in the Cultural Audit do not include the Estate’s creative industries or businesses as a stakeholder.
Evidence collected by a Lewes Phoenix Rising (LPR) survey in March 2014 of businesses and creative industries working on the site found that 75% had never been contacted by Santon or LDC. This is despite the statement on the Santon website throughout 2014 that ‘they were in advanced consultation with businesses on site’. A follow-up survey conducted by LPR in April 2015 confirms there has still been no engagement with the vast majority of tenants who earn a livelihood on the North Street Estate, especially those in the creative industries.
7. The Statement of Community Involvement documents Santon Group’s engagement with various stakeholders in Lewes Town, including Friends of Lewes, Chamber of Commerce, and the Community Land Trust. No written documentary evidence is provided on the outcomes of deliberations between Santon and these groups, or of their mandates for speaking on behalf of the Town.
8. In May 2014, Lewes Phoenix Rising (LPR) was established as a Limited Company with charitable aims, to act as a voice for those living and working in the town, and for the 75% of businesses on the Estate that had not been consulted.
9. LPR met with Santon and LDC on several occasions during May–July 2014. At one of these meetings* (17th July 2014), LDC and Santon agreed to explore how they might work with Lewes Phoenix Rising, and requested that we provide further information on how our plan could work within the housing requirements of SP3. The LPR Master plan was published in November 2014. It demonstrated clearly that, in addition to the 390 houses required by policy, a further 48 homes at social rents and substantial workspace, within the renovated buildings of the Ironworks, could be provided on site. Despite the request in July, both LDC and Santon have completely ignored the content of the LPR (Lewes Phoenix Rising) Master plan.
* (All such communications with LDC and Santon have been logged, and are available to view.)
10. LPR has held three public meetings in the Town and held five public consultations (December 2014) on its Master plan. 700 visitors participated. The feedback from these consultations is available on the LPR website. LPR also has 1,343 signatories and supporters (25th April 2015).
11. LPR has not been included as a stakeholder; the application or Statement of Community Involvement fails to mention LPR. This lack of meaningful engagement with LPR as a legitimate voice puts a question mark over the legitimacy of the joint applicants’ commitment to community involvement.