Lindsay Frost Esq.
Director of Planning and Environmental Services
Lewes District Council
30 March 2006
We have the following general comments on draft No 4 of this document. We are still working on a detailed paragraph by paragraph critique of the appraisal and hope to let you have these further comments before Easter. I trust that this will not be too late for them to be taken into consideration.
- It is unacceptable that this draft is dated August 2005, but consultation on it did not begin until last month, whilst printed copies were not available until after the deadline for comments had passed. In addition the first notification that consultation had begun was an article in the Sussex Express, which indicated that the document was available on the Council’s web-site, rather than by any direct communication with this civic society. A further related point is that the statement in section 1.2 is both inaccurate and misleading since there has been no consultation with this Society, who must be one of the leading amenity groups concerned, until now.
- We consider that as the Lewes and South Malling conservation areas are contiguous, an appraisal of the latter should have been incorporated into this document. May we please know when consultation on the South Malling conservation area draft appraisal will begin?
- In many ways we do not consider this draft appraisal follows the guidelines in the English Heritage document. It pays lip-service to them but is far from the comprehensive document envisaged. There is much repetition but little depth or detail. In addition there is no glossary of technical terms or references to the source of the specialist information included.
- It would have been helpful to have provided an overall map of the conservation area and an indication on it of the proposed addition to the area. Nevertheless we welcome this proposal and consider it should be extended to include the Prison. We also consider that the Railway Land Local Nature Reserve should be included in a revised conservation area as well as the buildings at the end of South Street, plus the river frontage on the west side between Phoenix Causeway and Willey’s Bridge. Consideration might also be given to establishing a new conservation area covering the Battle of Lewes site bearing in mind its national importance in the establishment of democratic government.
- There is no reference to the past history of the conservation area, which started after a request made by this Society to the County Council almost 40 years ago, nor of the various extensions and improvements to it. This lacuna should not only be rectified but comparisons and assessments should be made with the Designation Report and Central Area plan adopted at that time so that the extent of any improvements, or lack of them, is documented. Some before and now photographs would also help to illustrate such changes.
- We should like to know to what extent local historians, archaeologists, geologists and other disciplines have been consulted since, on the basis of our limited knowledge in these fields, we believe that there are many factual errors. Since the document will become an authoritative work to which future planners and historians will doubtless refer, we consider it important that the factual and technical information should be accurate especially as it will also be the basis for the future Management Plan.
- It would have been helpful if paragraph numbers had been used in the document to make it far easier to refer to specific sections.
- There is little or no reference in the document to the following features, all of which have contributed to the present state of the conservation area:-World War II – effects of bomb damage and loss of iron railings
Litter and street cleanliness
Poor state of many pavements and boundary walls
- Whilst we welcome the reference in the appraisal to the Council’s intention to produce a Management Plan and a Supplementary Planning Document we are concerned that no such provision has been made in the Council’s draft Planning Service Plan for 2006/7 to progress this. As we understand that the production of these documents is a requirement under “Best Value”, this omission would seem to require rectification.
In light of these comments and criticisms we would be happy to attend any meeting with the consultants or your staff where these issues can be addressed as we consider it very important that a first class appraisal is produced.