Lewes Phoenix Project
Cycle Lewes responds to Planning Application
The Phoenix, a proposed new sustainable neighbourhood, is situated in the old industrial centre of Lewes.
Human Nature (the owners of the site - Human Nature - Phoenix Project) has had two major public consultations – the Design Festival in September 2021 and Public Exhibition in April 2022 – as well as more than 70 meetings with the local community and interest groups.
Human Nature submitted a ‘hybrid’ planning application to the South Downs National Park in March 2023.
Cycle Lewes broadly supports the Planning Application & we have sent our formal response with comments to the South Downs National Park.
Comments on the Phoenix Quarter development ref SDNP/23/00526/OUT.
The Committee of Cycle Lewes, on behalf of its 150 members, have considered the above planning application and resolved to SUPPORT IT because of the positive contribution the scheme, if implemented in accordance with the submitted plans, drawings and supporting documents, will make to the physical, environmental, social and economic fabric of the town.
We also believe the scheme provides an exemplar of the principles that should be followed for all other major applications in and around Lewes (and further afield) if we as a country and a community are to achieve our sustainability aspirations resulting from the climate emergency that all tiers of government – in Lewes, in the United Kingdom and across the world – have acknowledged.
We do have a number of detailed comments with respect to detailed aspects of the scheme as well as other matters that are referred to in plans and documents in support of the outline aspects of the application that we believe should and can be addressed either as conditions, through the assessment and determination of Reserved Matters or in the Section 106 Planning and / or Section 78 Highways Agreement.
Summary
Cycle Lewes welcomes the proposals to create a sustainable, low carbon liveable, low traffic, ‘15-minute neighbourhood’ in the centre of Lewes. The designs contained within the planning application provide much needed housing and employment opportunities on this strategically significant site.
Most significantly, from our point of view, the scheme builds-in encouragement for walking and cycling travel behaviours from the beginning through the design of the streets and public realm which propose minimal circulation of motor vehicles and provision of limited on-street parking (for loading and accessibility/access needs only). This will be achieved by de-incentivising the driving for short journeys whilst encouraging, enabling and incentivising scheme residents to use a range of active and non-car-based modes of travel for all or most trips whilst also providing the facility of a car club for those who need to utilise such a vehicle for the occasional trip, or due to access needs.
We applaud the plans for the North Street site that will enable and encourage residents and visitors to adopt healthy and sustainable behaviours and thus reduce the impact of motor vehicles to the wider town which is vital to reduce air and noise pollution, to minimise motor vehicle congestion and provide the basis for a radical improvement to the public realm and overall environment in the ancient and historic market town of Lewes.
This would not have been possible if the ‘predict and provide’ model of assessing car usage had been adopted. We welcome the ‘Decide and Provide’ and associated user-centric survey and assessment that the applicants have undertaken to support the application.
Car ownership will be reduced. Consolidating and limiting car parking provision for visitors in a Mobility Hub has the potential to reduce the additional number of vehicle movements in Lewes; this is welcomed. As referred above, we consider this an exemplar approach and one that should be applied elsewhere in the town as we seek to limit the impact of the 5,000 vehicles that utilise Lewes High Street as a through-route every day, to the detriment of the town, as well as the other trips that could be taken by more active travel modes.
These ambitious but vital plans for this neighbourhood have the potential to act as a model for wider change throughout the town to make streets safer for walkers, cyclists and wheeler and the creation of a network of cycle routes.
During the development of the Planning Application Cycle Lewes welcomed the opportunity to participate in community engagement initiatives and the Mobility and Access Working Group which fed into and influenced the Mobility Vision, the Design and Access Statement and associated plans.
Cycle Lewes is of the view that the Proposals relating to walking, cycling and wheeling within the North Street development conform to national and local policy, strategy and guidelines and have regard to the South Downs National Park Authorities’ own local policies. Relevant ones are listed in Appendix 1 and include Core Policies, Strategic Policies and the Strategic Site Policy SD57: North Street Quarter and Adjacent Eastgate Area, Lewes. We believe the application meets the bulk of the objectives and proposals in the Lewes Neighbourhood Plan (Movement and Access section).
I believe these aspects will be best considered through the production of a town wide transportation strategy that considers all of these, and related, issues in the round and can be covered through a requirement in the s.106 agreement for co-operation of all parties on production of such a plan through a Local Cycling and Walking Implementation Plan (LCWIP), a Neighbourhood Plan and / or Local Transport Plan
Our Detailed Concern – general access and connectivity
We do believe the proposed designs for the Phoenix Causeway and Eastgate that form the main access points into and out of the site do not accord with the otherwise exemplar design principles of the scheme and that they will not meet the needs of the existing and anticipated high volumes of cyclists and pedestrians. They do not support connectivity between the wider town and the North Street Site. Most particularly, they do not ‘signal’ to vehicular traffic users that they are entering a “low traffic” and /or pedestrian priority /shared space area and this should be made clear through signage and road / footway / cycle way layout to all users.
Cycle Lewes wishes to make the Planning Authority aware of the need for the development, and delivery of policy compliant cycle infrastructure on the existing streets network, to allow for safe, direct routes to key destinations in Lewes. Key routes include: the Eastgate- Lewes Railway Station and beyond to Priory School, South Downs College, Leisure Centre and South Downs Sports Centre, Football Club and Priory Fields.
We are of the view that during the detailed assessment of this element of the scheme the Local Planning Authority (LPA) and the Highways Authority should working with Human Nature, Generator Group, Lewes Town Council and Community Groups to re-visit and revise the presented plans for Phoenix Causeway and Eastgate and look and how safe and direct routes to key destinations such as the Railway Station and education and leisure facilities in the area can be built for cyclists and wheelers and well as pedestrians.
We welcome the opportunity to engage in this discussion as Human Nature plans progress, including during the Reserved Matters development and determination.
We also strongly believe that consideration should be given to the production of a town wide transport strategy by ESSC (Highway Authority) that considers all these and related issues and forms part of plans they are currently developing: including the Local Cycle and Walking Implementation Plan (LCWIP) and the Location Transport Plan.
Detailed Comments:
Parcel 1/Phase 1
Cycle Lewes SUPPORTs the plans, but with the observation relating to the riverfront boardwalk that whilst it is intended to be pedestrian priority, it is unrealistic to expect cyclists to dismount given the strategic importance of this both to serve the needs of the site and as a through link. It is important that both the alignment and gradients, together with its design must factor this in to ensure that it can be safely shared without restricting access by persons with prams, wheelchairs and mobility scooters.
It is noted that the cycle access and parking diagram on p.73 of the Parcel 1 DAS shows two locations for Visitor Cycle Parking within the Parcel 1 external area. This visitor cycle parking is not shown on the landscape plan on page 69 of the Parcel 1Design and Access Statement. The precise location, type and number of cycle racks for visitor parking should be confirmed and shown to be compatible with the use of the recreation area.
The layout and area requirement of the internal cycle parking area will also need to be suitable for all styles and types of bikes from standard bikes to cargo bikes, tricycles including cargo-style bikes for transporting children to school/nursery and shopping, handcycles and bike trailers in accordance with LTN1/20 and WfW-Guide to inclusive cycling.
Application proposals
The applicants Transport Assessment seeks to secure a move away from the use of the private motor car and embrace active travel which is supported. However, this seems to be based on some assumptions which are overly optimistic. Paragraph 4.5.39 states that ‘the entirety of Lewes is accessible from the proposed development by bicycle within 5 minutes’ cycle distance of the Phoenix Quarter, assuming an average speed of almost 20 kilometres an hour, regardless of the terrain and the many obstacles that interrupt journeys, such as traffic lights and crossings. This statement, it’s assumptions and influence on future designs needs revisiting.
Additionally, limited regard seems to have been paid to the outcome of the applicant’s road safety audit which highlighted many deficiencies of the existing town centre road network and the conflicts which exist for cyclists which makes cycling inherently dangerous, and therefore unattractive to users. The section on Cycling Infrastructure (para 4.5), outlines some 13 streets in the town centre all as follows: ‘There were some cycle movements along the road, although these were not significant due to lack of cycle provision which makes it an unattractive environment for cyclists.’ The assessment needs to be revisited with some appreciation of the hills, narrow medieval streets, and the existence of the pre-by-pass one-way system which encourages through traffic. Many of the streets have limited capacity for cycle lanes or shared footways and its one-way system slows the progress of cyclists.
The parameter plan 1007 for pedestrian and cycle access (rev 9) shows primary pedestrian and cycle routes along Phoenix Causeway and on the west side of the River Ouse. However, the parameter plan 1007 revision 10 showing vehicular access and circulation has a different arrangement of routes. More clarity is required.
Willeys Bridge to Lewes Precinct
Cycle Lewes notes that that the Riverside boardwalk is not intended to provide a continuous cycleway from Willeys Bridge through to the south side of Phoenix Causeway and that there are significant level changes which stepped accesses discouraging cycle use. The absence of a continuous cycleway from Willeys Bridge through to the Wenban Smith/Eastgate site is a fundamental shortcoming in the proposals clearly contrary to the policy of the South Downs Local Plan and the Lewes Neighbourhood plan. This must be addressed.
Tom Paine Bridge
The phasing arrangements indicate that the proposed Thomas Paine Bridge and the mobility hub would not be provided until the latter stages of the ten-year development phasing. This has the potential to deter residents, business users and visitors from making the modal choice that the development aspires to at the commencement of the uses, potentially undermining the active travel aspirations.
Cycle Lewes is of the view that this decision needs to be reviewed and reconsidered for inclusion in Phase 2 to prevent the anticipated large numbers of pedestrians and cyclists having to either use the existing Willeys Bridge or Phoenix Causeway to travel out of Lewes and / or travel to the Malling area. This is important as the Transport Report states that most cars and bicycles will leave the development via the Phoenix Causeway Hub. As a right turn from the Hub onto Phoenix Causeway is to be prohibited, the early provision of cycle facilities linking Eastgate and Little East Street must be in place from day one so that cycles do not need to turn left, to proceed away from the town centre, to circumnavigate the Tesco/ Brooks Road roundabout before returning to the town.
Connectivity from Phoenix Development to the Town
The application proposals, as presented do not incorporate sufficient improvements in connectivity to the town. In particular, to achieve the applicants’ aspirations there must be a more attractive and safer pedestrian and cycle routes.
The applicant / local highway authority, ESCC need to address the connectivity issues to ensure that cycling and walking can realistically be the preferred methods of movement from the development into the town and beyond.
We have reservations about the location of the bus stops and the potential harm this will cause with changes in the width and character of Phoenix Causeway which will be to the detriment of cyclists and pedestrians.
Cycle Lewes believes -based on surveys we have conducted and continue to undertake within the town (in 2021 and Summer 2023) that measures should be adopted within the town to limit the number of vehicles that use the town as a through-route (as opposed to utilising the A26 and A27 by-pass (or adopting alternative modes) to enable a radical re-design of the public realm to widen pavements and generally improve the public realm to both improve the overall environment and boost tourism and business. The CIL funds that will be forthcoming from this scheme once implemented could (and should we believe) be used to contribute towards the cost of these works as well as other improvements to cycling and pedestrian infrastructure.
Eastgate
Of key importance is the need to improve and enhance the pedestrian experience as well and making cycling safer through Eastgate, especially in a northern direction where cycle facilities are absent and where there is currently no provision for pedestrians to cross the eastern end of East Street
Measures to reduce the speed and attractiveness to motor vehicles to use Phoenix Causeway and Eastgate are essential. Both are Lewes’ busiest roads - fundamentally unsafe, particularly for cyclists in the absence of protected dedicated cycle ways across Phoenix Causeway.
This must include the narrowing of the carriageway in Eastgate to a single lane with cycleways in both directions and wider pavements. The Eastgate pavement on the east side narrows to just 1.5 metres in places and on the west side at the junction with East Street there is a need to cross the carriageway of fast-moving traffic that sweeps round from Phoenix Causeway. The alignment of this junction is such that pedestrians and cyclists crossing the road must almost read the minds of drivers and decide which are likely to enter East Street, rather than the Eastgate. As such it is one of the most dangerous junctions in the town. Because the Phoenix Quarter development does not provide access through the site to North Street and Lancaster Street beyond, more traffic will be circulating within the conservation area. This will add to the dangers to cyclists and pedestrians and should be reviewed, otherwise there will be more traffic penetrating through the narrow streets of the conservation area and the existing residential areas.
Gateway/Cuifail Tunnel Entrance to Town
In the view of Cycle Lewes more must be done at the Culfail Tunnel and Brooks Road/Tesco roundabouts to narrow the town entrance and discourage traffic entering the town in the first place and directing local traffic to the adjacent car parks.
We support a strategic review of traffic in the town to reduce traffic to essential vehicles and to redress the poor air quality of the narrow streets and residential areas.
Mobility Hub
It is understood that this will be completed in Phase 3 of the development; the facilities this provides are key to the development of zero carbon travel behaviours. We welcome the intention of the Developer to provide temporary facilities for use during Phases 1 and 2. Indeed we believe this is essential if the “sustainable travel behaviours” are to be “built in” from the start.
Cycle Parking
Cycle Lewes SUPPORTS the volume and types of cycling parking for residents and visitors. It is understood that the proposals are to provide some 1487 bike parking facilities within undercover locked communal areas and approximately 646 public parking spaces in open air locations. While ‘natural surveillance’ is able to deter theft it does not remove the needs some residents may have for lockable personal space for expensive e-bikes and consideration in future detailed design work should be given to this. In this context there must be regard to the wish of many individuals to have private use of storage spaces to provide safe storage of ebikes and equipment that can run into £1000’s.
At this stage of the Application, it is unclear if electric cycle charging points will be available this again should be clarified at future stage including designs to accommodate a range of bikes, including e-bikes, wheelers and other forms of mobility aids. It is considered that a higher number of secure cycle storage facilities all with electricity supply for charging are also necessary to deliver the policy requirements.
Appendix 1: Cycle Lewes and Low Traffic Lewes Initiative
Cycle Lewes was formed in 1998 and seeks, through the active involvement of its membership and others to promote cycling and improve the availability of safe cycling routes in Lewes and the surrounding area. In doing this we work with statutory and non-statutory bodies to advocate and lobby for great investment in cycling infrastructure, safer streets and compliance with Government and Local Policy and Design Guidelines while meeting the needs of cyclists and those that might want to cycle but feel our roads are not safe.
1n 2021 working with Lewes Living Streets we formed the Low Traffic Lewes Project which aims to limit the impact of through traffic in the town and direct local traffic to edge of town car parks as much as possible in order to enable a radical improvement to pavement widths and the more general public realm so that pedestrians, cyclists and wheelers can more easily navigate the historic town with confidence to the benefit of the environment and the local economy.
Appendix 2: National & Local Policy, Strategies and Guidelines
At a national level the government’s active travel programme and the publication of ‘Gear
change-a bold vision for cycling and walking’ published in July 2020 have reinforced the
importance of cycling and walking in the layout of developments. These policies represent
the government’s current overarching policy which is to be applied at the local level.
The UK Cycling and Walking Investment Strategy, published in 2017, sets out the
Governments ambition to make walking and cycling the natural choices for shorter journeys
or as part of a longer journey. It acknowledges that realising this ambition will
take sustained investment in cycling and walking infrastructure, to transform local areas and
tackle congestion, improving physical and mental health, therefore supporting local
economies. The strategy’s objectives include increased cycling and walking
activity, including the percentage of children aged 5 to 10 that usually walk to school.
The Governments cycle infrastructure design requirements have recently been set out in
their Local Transport Note 1/20. All of which aim to contribution to both national and local decarbonisation policy and action plans
The Royal Town Planning Institutes report (January 2021), Net Zero Transport: The Role
of Spatial Planning and Place-based Solutions states that transport and land use planning must
be integrated to help the UK to meet its net-zero carbon objective
Relevant South Downs National Park Authority polies include:
Core Policy SD2: Ecosystem i) Reduce levels of pollution; j) Improve opportunities for
peoples’ health and wellbeing; and
Core Policy SD3: Major Development. Development proposals should be sustainable as
measured against the following factors: - Zero Carbon - Sustainable Transport - Health
and Wellbeing
Strategic Policy SD5: Design 1 g) Provide high quality, secure, accessible, and where
possible, integrated storage for…. transport related equipment;
Strategic Policy SD19: Transport and Accessibility 1. Development proposals will be permitted provided that they are located and designed to minimise the need to travel and promote the use of sustainable modes of transport.
Strategic Policy SD20: Walking, Cycling and Equestrian Routes 1. Development proposals will be permitted provided they contribute to a network of attractive and functional non-motorised travel routes, with appropriate signage, throughout the National Park.
Under Strategic Site Policy SD57: North Street Quarter and Adjacent Eastgate Area, Lewes any proposal will need to demonstrate
Development Management Policy SD22:
Parking Provision 2. Development proposals will be permitted if they provide an appropriate level of private cycle and vehicle parking to serve the needs of that development in accordance with the relevant adopted parking standards for the locality. Wherever feasible, electric vehicle charging facilities must also be provided.
b) It facilitates improved linkages across Phoenix Causeway and Eastgate Street and a better balance between the use of the private car and other modes of transport, in order to enable the safe flow of pedestrians and the improved integration of the area to the north of Phoenix Causeway with the wider town centre;
c) It delivers enhancements to vehicular access and off-site highway improvements, arising from and related to the development and its phasing;
g) It incorporates a riverside shared foot/cycle route along the western bank of the River Ouse to extend the town’s riverside focus and contribute to its character and quality, and provides additional pedestrian and cycling routes to link the site (or phase of the site) to the rest of the town, improves permeability within the site (or phase of the site) and provides views out of the site (or phase of the site);
h) It provides an appropriate level of public car parking provision;
k) It makes contributions towards off-site infrastructure improvements arising from, and related to, the development;
The following policy references from the Lewes Neighbourhood Plan are also relevant.
Policy AM1 -giving priority to direct and safe walking and cycle routes.
Para 9.2 which sets out the hierarchy of users of road space.
Para 9.5 which is about separations of pedestrians and cyclists from cars.
Para 9.7 which is about new developments and in particular developer contributions.
Para 9.13 is about reducing the need for car use.
Page 145 refers to the need for a new bridge to the north (next to Willey's bridge).
East Sussex Local Cycling & Walking Infrastructure Plan (LCWIP).
The approved East Sussex Local Cycling & Walking Infrastructure Plan (LCWIP) (September 2021) is relevant to the site’s development with links to routes L12 (Landport to Eastgate through North Street development site) and L14 (route town centre to Malling along the western edge of the development site). The proposal must also have regard to commendations in paragraph 308.1.2 to replace the existing Willeys Bridge with a wider structure for shared use and paragraph 308.1.3 Widen existing footpath to a minimum of 3.0 metres for shared use. Regional Cycle Route 90 passes through the town, but the development needs to show how cyclists can safely reach this route. Whilst much of the town centre and some residential areas are covered by 20mph zones the only significant traffic calming is on Southover High Street and Mountfield Road.
Sustrans have highlighted from a review of the existing conditions, that there are a number of general factors which need to be considered:
• Traffic conditions in the town centre and on Offham Road and Nevill Road.
• Consider traffic restrictions on town centre roads to improve conditions for walking and cycling.
• Continue to develop the Egrets Way route.
• Provide new routes to outlying villages to the same standard as the Ringmer shared path alongside the B2192.
• Cycle parking at key trip generators is currently below standard in both quantity and security level, enhancing this will encourage more cyclists.
• Advanced Stop Lines to be provided at all traffic lights
It is recommended that within The North Street Quarter proposals should “incorporate a riverside shared foot / cycle route along the western bank of the River Ouse to extend the town’s riverside focus and contribute to its character and quality”. A further ambition is a new footbridge connecting the south and north banks of the river.
24th May 2023.
END