Analysis of Santon/LDC North St Application – Housing and Employment
Summary and Conclusions
This development is the largest proposal to be considered by Lewes Town Council in many years. It will have a profound impact on the town for the next generation and beyond.
Lewes Phoenix Rising wishes to use this development as a wonderful opportunity to build on the historic strengths of our town to ensure that it has a future which is:
Socially sustainable, providing homes for our citizens, jobs for our workers and a place that is accessible to all, no matter what their income;
Environmentally sustainable, reducing dependency on cars and other forms of unsustainable transport, creating a place where people live, work and play within the same community;
Economically sustainable, providing opportunities for the town to prosper in a way that is affordable to all its citizens, encouraging local people to contribute to the economy of the town, and protecting the town from the economic threats of rising land prices, commodity prices and global economic instability which characterise our age.
We have considered the Santon/Lewes District Council’s plans, and we are particularly concerned about two specific areas which will prevent the town from achieving these possibilities;
The failure to provide genuinely affordable homes to meet the current and future needs of the town;
The damage to the local economy that will result from the destruction of the existing cluster of economic activity that has developed on the Phoenix Estate in the past ten years.
We have developed an alternative approach to these aspects of the proposed development that we will promote during the consideration of this planning application and that we would like to see introduced through the formal consultation process before the application is finally considered by the South Downs National Park Planning Committee.
Our proposals would:
Create genuinely affordable homes, through use of modern construction methods and through the generation of cross-subsidy from the market housing on the site;
Support and develop the town’s distinctive economy, by providing sustainable workspaces on the site that build on the already successful manufacturing and arts-crafts cluster that has grown on the site.
Our proposals are consistent with the National Planning Policy Framework, paragraph 17 which requires plans to proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs.
Lewes Phoenix Rising Ltd (LPR) is a community developer, based in Lewes. It is a company limited by guarantee, funded by local people, with over 1200 active supporters and a management team made up of local professionals and business people.
LPR fully accepts the principle of the development of the North Street site, but as a community developer we wish to see developer profit more fairly matched with community benefit.
LPR has prepared a masterplan for the North Street area of Lewes, which responds to the concerns of people in the town, based on the research and extensive public consultation that we have carried out in the last 12 months.
This briefing paper is a response to the planning application submitted by Santon/Lewes District Council, reference SDNP/15/01146/FUL prepared for the consideration of the Lewes Town Council at its meeting on 14 April 2015.
It covers two main topics which are of primary importance to the town of Lewes:
Employment and the town’s economy.
It addresses the planning principle in paragraph 17 of the National Planning Policy Framework that requires plans to proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs.
The objectively assessed need for housing in the town of Lewes show “huge unmet demand from young people for one-bedroomed homes” (LDC) and that more than half of those who are homeless need one-bedroomed properties.
The Affordable Housing Needs Assessment January 2014 prepared by Lewes District Council notes that:
“As the lower quartile house prices have increased from 4.2 to 10.3 times the lower quartile income, no part of the District is now affordable at low incomes. The private sector is failing to meet the need for affordable housing because there is limited supply of homes for rent in the District and housing costs are only affordable through the subsidy provided by housing benefit.” (LDC Affordable Housing Needs Assessment January 2014, para 7.1)
The report goes on to say that:
“Current social rents range up to 43% of market levels; housing association affordable rents on new schemes and re-lets are up to 76% of market levels. Government plans for further cuts to welfare spending from 2015 will almost certainly include cuts to housing benefit, jeopardising this mechanism to make housing affordable in all sectors; this will increase the likelihood of evictions for households who rely on housing benefit to pay affordable rent in addition to those renting in the private sector.” (ibid, para 7.5)
The Council’s own assessment points to the need for:
Maximising the number of homes provided for small families and single people. The report quoted above says in paragraph 7.7 that arising need for affordable housing results from the formation of new households, overcrowded and concealed households and households falling into need.
Minimising rental levels to the lowest possible. The Council’s report is clear that even at current levels of social rent (40 – 50% of market rent), given the rise in costs and downward pressure on incomes for the lowest paid, the current situation is not sustainable.
The Santon/LDC proposals, whilst increasing the proportion of “affordable housing” to 40% as a result of local pressure, does not respond to the needs as described by LDC:
Extra care beds. This may be a priority for the County Council (Santon/LDC Housing Assessment, doc 11, para 5.4) but it is not a priority for the town of Lewes. Including most of the 51 such units in the overall provision of affordable housing reduces the ability to respond to the real needs of the town for the formation of new households and for those in current, often hidden, housing need;
Rental levels. There is no indication of what rental levels will be provided in the affordable housing. This is a regrettable omission given the ability to define affordable as up to 80% of market rent when LDC notes that “…no part of the district is now affordable” if one uses current definitions of affordability;
Overall mix. Whilst the Housing Assessment does not specify the mix of affordable housing, in the overall provision (table at para 4.29) 45% of the total housing provision is in 3 and 4 bedroom homes. This is clearly an attempt to increase in-migration into the town rather than to meet the needs of those already living in the District, based on the commercial market assessment rather than on objectively assessed need.
LPR therefore proposes the following:
Target the affordable homes at the real needs of the town; young people and families, those already in housing need, those who wish to live and work in Lewes and contribute to the local economy in a sustainable way;
Reduce rental levels to the lowest possible level. This means using modern construction methods (including off-site construction, such as the ModCell system) which reduce build time and costs, and allow future residents to be involved in the design and construction of their homes. This system can achieve up to 40% savings on both costs and therefore future rental levels; and
Open market homes. To cross-subsidise the low rental levels and to generate the profits that the scheme needs, we would propose to provide more market homes that Santon/LDC are planning. Our masterplan shows that it is possible to increase the density of development on the site whilst improving the landscaping and the provision of community amenities.
Using this approach, LPR has been able to demonstrate that we can provide innovative housing on the site, including live-work units and small family apartments, at 40% of market levels.
Employment and the Economy of Lewes Town
LPR starts from the position of understanding the existing employment provided on the Phoenix Estate. This has to be the starting point for any new proposals.
LPR surveyed the existing activities on the site, and then reviewed the international literature about what makes a successful local economy.
First, there are around 450 jobs on the site, in a range of manufacturing, light industrial and arts related activities. They depend on the low rents available on this site, since commercial rent inflation has outstripped the abilities of this type of activity to remain viable in spaces rented at market rents.
Many of these jobs were not included in the Santon analysis conducted by Making Good (Managing Creative Flexible Workspace, Document 10 of the planning application) because they are sole traders. In our view, this approach fails to acknowledge the growing economic activity that sole traders represent in our local economy.
International experience shows the following:
Economic success is most often a story of successful localities, not regions or countries;
This is shown by the development of small “clusters” of economic activity that tend to grow in towns or cities, based on indigenous and historic patterns; eg IT and media in Brighton, arts and small scale manufacturing in Lewes;
These clusters have a special and distinctive identity which shelters them from external threats posed by regional or national/international pressures; eg subsidised rentals, sharing of facilities and resources, tight-knit supply chains that provide mutual support;
The most successful clusters are characterised by this so-called “collective efficiency”.
This is precisely what has grown on the Phoenix Estate in the past ten years or so.
LPR therefore starts from this distinct local character represented by the “cluster” at the Phoenix Estate, and promotes the development of an employment model on the site which harnesses the energy of this self-organised, art-craft and small batch manufacturing community.
We also promote the environmental benefits of such a cluster, which is to reduce the need to travel to work. We know that transport is an inherently energy intensive activity, and that the commuting model for urban locations will become increasingly unviable. We need to create jobs closer to where we live.
Our analysis tells us that the Santon/LDC proposals will:
Increase the number of commuters, attracted by the 3 and 4 bedroomed houses, to come and live in Lewes;
Result in the loss of the existing “cluster” on the Phoenix Estate, largely as a result of the demolition of the existing premises with no concrete proposals as to the future location of these businesses;
Continue the development of Lewes as a town that depends on external wealth from London, damaging the wider local economy and enterprise sector.
On the other hand, LPR’s proposal to build on the existing businesses, providing them with accommodation both during the development and at the end of the process through careful phasing of the development and use of some of the existing buildings, will:
Draw on the historic strengths of our town, its cultural/knowledge/manufacturing cluster, to generate collective efficiency to gain from the success of other such clusters in the wider global economy;
Strengthen the “social glue” which binds our town together, enhancing our town’s identity, protecting us from the social and economic pressures that many other south coast towns are experiencing to their detriment;
Contribute to the next generation of development of our town as a wonderful place for people to live, work and bring up their families.
LPR April 2015