Public Consultation – influencing what happens on the North Street Estate and maintaining the creative and small manufacturing industries
1. A review of the documents submitted as part of the planning application suggests that the views of the public have not been taken into full consideration, and that inadequate space is being allocated to the creative industries and small manufacturing businesses. These industries currently occupy over 10,000m2. The Santon /LDC plan provides around 1000m2 for ‘creative industries’, of which only 300m2 is workshop space.
2. The Employment Assessment outlines plans for the allocation of land use and the employment expected to be generated in the new development. A review of this document suggests that the joint applicants have failed to:
- Respond to the issues raised in the consultation
- Ensure that the cultural and industrial heritage is protected, in not ensuring that space for the creative industries (arts, crafts, small manufacturing) is specifically allocated for those purposes
- Ensure that meaningful skilled employment is retained in the town
3. Using data collected by a Cultural Audit, the Employment Assessment suggests that there is capacity in the wider Lewes Town for some creative industries to re-locate to existing sites, or to be accommodated in two proposed new developments. It concludes that this would reduce the demand for space for the creative industries on the North Street site. This claim is highly contestable. The authors demonstrate an almost total lack of detailed understanding of the various creative industries, what they do, how and when they operate, and who uses them. The key question of why they are in North Street in the first place is almost completed ignored.
4. The Statement of Community Involvement provides helpful details of the public consultation processes that were undertaken, and quotes from each of the three consultations and the questionnaires that were completed. 1,658 attended the workshops, 202 were repeat attenders, 85% lived in Lewes Town, 615 went on to complete a questionnaire.
5. Attendees at the 1st consultation expressed strong support for small/cottage industries (page 19), had little desire for the site to be just a housing site, felt that provision should be made for employment, and that any retail provision should complement existing space and be small in scale.
The 2nd consultation documents continued support for local, small independent businesses including creative workspaces to enable the creative essence that has developed on the site to be maintained.
Recommendation 8 states that the development should find a way of accommodating artistic and other small, independent businesses that is sustainable and viable and that retains a creative community on the North Street site (page 25).
Recommendation 3: from the 3rd consultation (May 2014) stated that Santon Group should continue to work with the creative businesses , community groups and LDC to agree on solutions for providing appropriate creative business space in the Town (page 29). Those consulted believed that the development needed to do more to retain the spirit of the area in regard to craft, arts and manufacturing.
6. The Employment Assessment outlines the amount of land (square metres) for different land uses, and, using a standard formula, uses it as the basis for estimating the number currently employed on the site (FTE). It does not use actual numbers. This means that it does not present an accurate or true reflection of the number of individuals gaining a livelihood on the site. One of the reasons this report gives for not counting those working in the creative industries is that they are not employees of an employer, but sole-traders – yet the very nature of the creative industries means that many are indeed sole traders, or described as self-employed.
7. The Employment Assessment has chosen not to use data compiled in the report Managing Creative Flexible Workspace by an independent consultant hired by Santon. Neither has any reference been made to a survey conducted by Lewes Phoenix Rising. Both surveys put the number of those employed on the site as substantially higher: an LPR survey in April 2015 estimated that more than 450 individuals work on the site.
8. The methodology used to assess numbers employed on the North Street Estate is not appropriate, and affects the credibility of the Employment Assessment report and its assumptions, and therefore undermines its recommendations.
9. The Employment Assessment allocates floor space on the current site to various classes of land use (paragraph 6.10) and uses the B1c as the land use class that ‘most closely reflects most of the activities [on the site]’; (paragraph 3.11).
10. The report states that floor space of approximately 1,165 m2 for performance and other creative uses will be allocated (page 9). However, analysis of Table 6.10 (page 11), outlining the allocation of space, shows that the allocation is not specific, and nowhere is an amount of space allocated in those tables specifically for B1c use (creative industries).
11. The report suggests that some of the floor space is allocated to general B1 class, but the same space is also allocated to other land uses: A1, A2, A3, A4 (retail, restaurants/café, bars and clubs); D1 and D2 (healthcare and dental services). There is no guarantee of the amount of floorspace that would be allocated to each particular function, and serious danger that a significant number of current creative jobs would be lost, without suitable provision for future growth. It is not clear, either, whether the small light-industrial and other business currently on the North Street site would be provided with suitable, adequate and affordable space in either North Street or Malling Brooks, or whether, if space were so allocated, it would be available immediately so the businesses could continue to operate, and would be let at a rent that would be feasible for the businesses. All these considerations make likely a significant loss of productive employment in the town. (See pages 10–12).
12. The floor space clearly allocated (1,165 m2) is less than Santon’s own survey (4,798 m2) and much less than the Lewes Phoenix Rising survey. The latter estimated the total space used by creative industries and small businesses as 10,027 m2.
13. There is a serious danger that much, if not all, of the ‘flexible workspace’ will end up as retail, food and drink outlets (see paragraph 11).
14. The Health Hub will enable space for existing GP practices and a dental surgery to move to purpose-built facilities within the town. This is unlikely to create a significant net gain of employment; it will simply move current employees across the town.