SUSTAINABILITY

Human Nature has developed a Circle of Impact, which sets out an understanding and set of ambitions for what’s required to achieve true sustainability. In this section, the sustainability credentials of the proposal have been measured against the SDNPA’s Ecosystems Services requirements, thereby displaying how the various elements of the scheme assist and complement the National Park’s commitment to preserving and enhancing natural and social capital.

The figure below identifies how various proposals of the scheme contribute to the SDNPA’s Ecosystem Services. As well as measuring aspects of the scheme against the ecosystem services described above, a detailed exercise in evaluating the scheme’s climate change impacts (arising from the construction process and the use of heat and power during the scheme’s operational lifetime) has been undertaken.

The sustainability impacts of the scheme – in greenhouse gas (GHG) terms – have been quantified in the Environmental Statement (Chapter 16: Climate Change). A summary of the likely impacts, and methodologies used in determining them, is provided below

Construction-stage impacts:

Construction-stage GHG impacts have been quantified via a detailed embodied carbon analysis for several building typologies across the scheme. The assessment has considered life-cycle analysis (LCA) stages A1-A5 (extraction of raw materials, processing/ manufacturing, transportation to site and onsite construction activities). Due to the use of the bio-based, regenerative materials described previously, when accounting for carbon sequestration, the construction-stage GHG impacts are in the order of -4,075 tCO2e. The LCA stages A1-A5 GHG intensity values for the scheme are -48 kgCO2e/m2 when accounting for carbon sequestration.

Operational-stage impacts:

The operational-stage GHG impacts, due to the consumption of heat and power over the development’s lifetime, have been quantified using the EUI metrics described in the Energy Strategy section and BEIS’ grid electricity carbon intensity projections. Over the course of the development’s lifetime, it is expected that the total annual power consumption will amount to 4,810 MWh, resulting in a GHG impact of 5,320 tCO2e over a 60-year period. When accounting for the consumption of onsite renewable energy, this is reduced to 3,723 tCO2e. As detailed in section 10.10, a worstcase EUI estimate has been assumed, thereby representing a worst-case assessment.

Net effect:

The development’s net GHG impact – given the previously stated construction and operational-stage impacts – is expected to be in the order of magnitude of -351 tCO2e (with carbon sequestration).

Future measuring/monitoring:

As the detailed design of the scheme progresses, Whole Life Carbon (WLC) assessments will be undertaken and kept under constant review to be used as a design tool in order to minimise impacts wherever possible. The site-wide WLC assessment will be verified by an accredited organisation. Additionally, Human Nature plans on partnering with an appropriate organisation who’ll assess and measure the beneficial sustainability impacts of the aforementioned Circle of Impact.

South Downs Local Plan Core Policy SD2: Ecosystem Services

“Development proposals will be permitted where they have an overall positive impact on the ability of the natural environment to contribute goods and services. This will be achieved through the use of high quality design, and by delivering all opportunities to:

Sustainably manage land and water environments

Protect and provide more, better and joined up natural habitats

Conserve water resources and improve water quality

Manage and mitigate the risk of flooding

Improve the National Park’s resilience to, and mitigation of, climate change

Increase the ability to store carbon through new planting or other means

Conserve and enhance soils, use soils sustainably and protect the best and most versatile agricultural land

Support the sustainable production and use of food, forestry and raw materials

Reduce levels of pollution

Improve opportunities for peoples’ health and well-being

Provide opportunities for access to the natural and cultural resources which contribute to the special qualities

Rain gardens/ SUDS features

Sustainable water use

Rainwater harvesting

Bio-based construction materials

High quality ‘passive’ design

Renewable & efficient energy systems and delivery

Reclaimed, reused and reconstituted site won materials

Retention of existing structures (Soap Factory, Every Hall, Foundry Workshops and Phoenix House)

10.15 FIRE SAFETY

allow fire appliances to access the fire station in addition to general UK Building Regulation requirements for access to buildings for firefighting.

fire main outlet, as measured on a route suitable for laying hose. This is extended to 60 m in sprinkler protected buildings.

While for fire safety management in buildings, compliance is with the Regulatory Reform (Fire Safety) Order 2005 (RR(FS)O) (Note: an amendment has been made through the Fire Safety Act 2021 – this brings: structure, external walls – inclusive of specified attachments and apartment entrance doors under the remit of the RR(FS)O).

For the basis of design, fire safety guidance documents such as BS 9999, BS 9991 or Approved Document B will be used as the basis to inform the strategic fire and life safety design for the buildings to be developed on the Phoenix Masterplan development. The primary objective would be demonstrating that the functional requirements of Part B of the Building Regulations 2010 (as amended in 2022) (as listed below) can also be satisfied:

• B1 – Means of Escape and Warning

• B2 – Internal Fire Spread (Linings)

• B3 – Internal Fire Spread (Structure)

• B4 – External Fire Spread

• B5 – Access and Facilities for the Fire Service

This DAS focuses on the wider side and therefore will highlight the primary B5 – Access and Facilities for the Fire Service.

The existing fire station within the Phoenix general site area is to be retained. As such, the site will have good access to fire and rescue services, but streets must be designed to

The UK Building Regulations state that the minimum clear distance between kerbs should be 3.7 metres. This includes road narrowing objects such as planters and is to allow large fire engines to pass. In addition to this, for all buildings, hose laying distances from the dry riser outlet to the most remote point on that floor are limited to 45 m, which is increased to 60 m if the building is sprinkler-protected.

In sprinkler-protected townhouses, the hose distances from the fire tender parking position to the most remote point within every townhouse is limited to 75 m if one floor is more than 4.5m above ground. Otherwise, the hose distances from the fire tender parking position are limited to 45m.

Where this is not achieved, there will be a requirement for emergency access for fire tenders within the public realm or along cycle routes. Collapsible bollards can be used to prevent vehicles from entering these pedestrianised zones during normal use. Streets within the Phoenix have been designed to accommodate standard fire tenders and high reach fire tenders (where required) whilst having the minimum impact on pedestrian and cycling priority access and playable streets. There are turning points at the heads of both North Street and Phoenix Place, two locations that have been identified as having the fewest implications on public realm.

Where a building exceeds 11 m in height, a dry fire main should be provided. However, in residential buildings less than 11 m a dry fire main may also be provided to enable internal firefighting. In all cases approval of the local fire service will be gained

In accordance with the guidance, in buildings fitted with fire mains, every part of the floor plate of all storeys should be within 45 m of the

Where timber is considered as the construction method for the buildings on site, the general principles would be that the timber construction follow an encapsulated solution. The primary objective of this approach is to ensure that the fire performance of the building structure is to be achieved by means of plasterboard (or similar) protecting the timber structure in a fire event for a specified period. Limit instances may arrive where exposed timber may be featured, and these will have to assessed by competent fire engineer on a case-by-case basis.

Site-wide fire tender access

Existing Fire station

Fire tender route

45m radii fire tender access

One-way fire tender routes (requires reversing)

Riser inlet

Riser outlet

Riser

10.16 GROUND CONDITIONS

Geoenvironmental

The existing site is characterised by historic and current use for heavy and light industry. Previous uses include a railway line; iron works; timber yard; soap factory; builder’s yards; miniature rifle range; mortuary;sawmill and a papermill, all of which have the potential to cause ground contamination.

Geotechnical

The present ground conditions are primarily due to the following social/geological characteristics of the site and surrounding areas:

The site’s setting within lowland calcareous grassland;

The site’s proximity to the river Ouse and resultant riverine/riparian environment; and

The site’s long history as a place of heavy and light industry.

The aforementioned characteristics have resulted in the following assumed ground conditions:

Bedrock

The chalk bedrock is anticipated to vary between the Holywell Nodular Chalk, the New Pit Chalk, and the Lewes Nodular Chalk.

Alluvium

Given the site’s proximity to the river Ouse, the chalk bedrock is overlain by superficial alluvium (with assumed varying depths of 0.6-6m). The alluvium is assumed to be comprised of variable clay, silt, sand and gravel.

Made ground

Given the site’s industrial history, the superficial alluvium layer is overlain by made ground (with assumed varying depths of 0-4m). The made ground on-site is assumed to be comprised of brick fragments, ash, chalk fill, stone chippings, ‘bitmac’ (bitumen bound surfacing), concrete and flint sometimes in a clay or silt matrix.

While the release of Alkalis in January 2003 had a category 2 (significant) impact to land.

While the site has not been designated as contaminated land under Part 2A of the Environmental Protection Act (1990) – given the potential sources of ground contamination described above – based on intrusive ge-oenvironmental site investigations, an appropriate and proportionate site-specific remediation strategy will be produced and carried out.

Historical site features

Refuse heap

Joinery Works

Paper Works

Stables

Allotments

Corperation Wharf

Foundry Iron Wirks

Residential Area

Timber Yard

Railwayline

Planning application boundary

Historic site features

Historic landfills

10.17 DAYLIGHT & SUNLIGHT

During the development of the masterplan, studies have been undertaken to assess and refine the design:

Shadow studies to assess the quality of light in the public realm and new courtyards

Daylight and Sunlight study assessing the effect of the proposals on neighbouring properties

A detailed study for Parcel 1 assessing the Daylight and Sunlight within the new dwellings

Daylight and sunlight impact to neighbouring properties

EB7 are a specialist consultant who have been commissioned to provide Daylight & Sunlight advice to the design of the new neighbourhood. EB7 have undertaken a detailed assessment of the potential daylight and sunlight effects proposals at the Lewes Phoenix site and their report has been included with the application documents.

This report is a detailed assessment of the potential daylight and sunlight effects of the maximum parameter and illustrative master plan proposals at the Lewes Phoenix site on the key neighbouring properties. These assessments have considered the effects of both the Maximum Parameter Scheme and the Illustrative Masterplan.

Assessments have been undertaken using the veritcal sky component (VSC) and no sky line (NSL) and annual probable sunlight hours (APSH) tests set out within the Buildings Research Establishment (BRE) guidance ‘Site layout planning for daylight and sunlight: A guide to good practice’ (2022). It’s important to note that the BRE recommendations are purely guidelines and should be interpreted sensibly and flexibly based on the site-specific context and wider regeneration benefits of the scheme. This flexible application of the BRE guidelines for housing in developing urban locations is supported in the NPPF to ensure that the developments make optimal use of sites for housing.

A regeneration development of an underutilised site will inevitably lead to a degree of change from the prevailing daylight and sunlight levels in order to fully optimise the land for housing delivery. The proposals have however been developed with specialist input to respond appropriately to the key neighbouring receptors.

While a degree of change is unavoidable as a result of a significant regeneration master plan, the results of our assessments show that all neighbouring properties either broadly meet the BRE recommendations, experience only minor deviations or maintain appropriate levels of daylight amenity for a developing urban location. This is particularly the case in respect of the illustrative scheme proposals which give a more representative indication of the likely effects. This demonstrates acceptable levels of daylight and sunlight to neighbours. A flexible approach to the application of the BRE guidelines is appropriate in respect of a regeneration scheme across an underdeveloped site.

Where there are changes beyond the BRE guidelines, primarily to some of the neighbours along North Street, Lancaster Street, Wellington Street and Spring Gardens, these are principally driven by their relatively unusually open outlook across the existing undeveloped / less dense areas of the sites.

Again, the retained daylight levels are considered appropriate for a regeneration scheme and will not unacceptably typical of an urban location. These effects are unlikely to materially impact the pattern of use across to these properties and good overall levels of amenity will be retained.

In isolated instances, there are inherent neighbouring constraints in the form of projecting wings or windows set beneath cantilevered first floors which limit the outlook and exacerbate the effects of the proposal, although the scheme will not have a material adverse effect on the normal amenity and use of the neighbouring properties. The BRE acknowledge that flexibility should be applied in such circumstances and should not prejudice the development potential of sites.

Additionally, the NPPF 2021 makes it clear that efficient use of sites, particularly for housing delivery, should not be limited by technical constraints and the proposals are not considered to result in unacceptable levels of harm to the neighbours.

With regards to sunlight, the majority of the neighbours either meet the BRE target levels for APSH or are within 90 degrees of due north, such that they would be unaffected by the proposals. Where there are transgressions from the recommended criteria, these are generally limited to effects to low angle winter sunlight. The affected spaces retain appropriate overall levels of annual sunlight.

Overall, the masterplan scheme responds well to the constraints of the site / neighbouring context, whilst optimising housing delivery. The proposals and is considered acceptable in line with the aspirations of the BRE guidance, as well as both local and national planning policy.

Daylight and sunlight study to Parcel 1

Detailed proposals for Parcel 1 are included with this application. EB7 have undertaken a separate Daylight and Sunlight study for the proposed new dwellings in Parcel 1 design which is included with this application.

Sunlight studies

The sunlight studies illustrate the impact of development in terms of sunlight and daylight access to surrounding context including surrounding buildings, public realm, public and private open space. The studies and analyses have been conducted for the following dates:

• Spring Equinox – 21 March

• Summer Solstice – 21 June

• Autumn Equinox – 21 September

• Winter Solstice – 21 December

At regular hourly intervals before and after sunrise and before sunset, including Solar Noon. Latitude: 50 deg. 52’ 34.9” N Longitude: 0 deg. 00’ 45.3” E

Time Zone in Winter: Greenwich Mean Time (GMT) Time Zone in Summer: British Summer Time (GMT+1)

BRE 209 (2011) is the primary metric used to assess outdoor sunlight access in direct sunlight hours falling on a space, as

Spring

Equinox

– 21

March recommended by the BRE Guide on which the above policies are based.

The guide recommends two hours of sunlight for 50% of new and existing external space on 21 March, while also giving guidance on how to maximise daylight and sunlight in layout design. The illustrative masterplan achieves the BRE standards in all courtyards.

Winter Solstice – 21 December

10.18 AIR QUALITY

The Phoenix has the potential to impact human health and other receptors near to the site due to the generation and dispersion of dust during the process of the construction of the development. It has been determined that an appropriately worded CEMP will render such impacts negligible.

During the operational stage of the Phoenix, the predominant cause of pollutants (particularly NO2 & particulate matters), are likely to arise from vehicular movements. Due to the measures embedded into the design of the scheme enabling a large shift towards sustainable transport modes, the effects from pollutants on human health and nearby ecological receptors have been deemed negligible. Additionally, the provision of an all-electric energy network will minimise air quality impacts on residents, visitors and other surrounding receptors.

With regards to indoor air quality (IAQ), the use of biobased materials (e.g. timber, hempcrete and natural fibre insulation) will ensure low volatile organic compound (VOC) levels, with resultant benefits to occupants of the Phoenix (particularly with respect to the prevention of respiratory diseases).

See ES Chapter 9: ‘Air Quality’ for further details.

10.19 NOISE & VIBRATION

The noise and vibration impacts during the construction phase of the Phoenix have been considered for the following sequence of construction activities:

• Phase 1: Demolition

Phase 2: Excavation

• Phase 3: Piling

Phase 4: Aggregate Crushing

Phase 5: General Construction/Concrete Operations

Phase 6: Disassembly/grinding of steel

• Phase 7: Road Works

Based on monitored noise baseline data, the noise & vibration impacts at the closest receptor (Spring Gardens residents) have been assessed. It is expected that, at this location, percussive piling methods will be precluded and a 4m noise barrier will be erected, in order to mitigate potential negative impacts.

Upon occupation of the Phoenix, noise and vibration impacts are expected to be negligible due to the facilitation of a shift towards the use of sustainable transport modes and the provision of an all-electric energy network.

See ES Chapter 8: ‘Noise & Vibration’ for further details.