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Zsolt Kerekes

Chiltington House

Chiltington Lane

East Chiltington

LEWES

BN7 3QU

To Andrew Hill, Lewes District Council Planning

16th

September 2016

Re LW/16/0695 - The creation of ponds (part retrospective) and the provision of associated

buildings with a supervisory dwelling to service a fish farm producing caviar. Planning

permission for the dwelling (only) sought initially for three years in order to demonstrate

enterprise viability | Land South Of Chiltington House Chiltington Lane East Chiltington East

Sussex

Dear Andrew (and other planning people who may read this)

I strongly object to the above scheme and in my comments below will indicate my own views,

comments and concerns about this scheme and why I think it should not be permitted to go

ahead as presented.

Summary categories for my objections include all these:- Conservation Significance, Contextual

Significance, Contrary to Policy, Drainage, Effect on Wildlife, Flooding, Historical

Significance, Insufficient Information, Lack of Infrastructure, Loss of Light, Loss of (dry) Open

Space, Noise and Disturbance, Not Sustainable, Out of Character, Overlooking, Loss of Privacy,

Overshadowing, Smell/Fumes, Traffic Generation, Within Conservation Area.

[An advance apology here. As you know this scheme is more complicated than a typical “build

a house or extension” planning application. And the nature of the scheme (the first of its type

using this experimental type of caviar production in the UK) means that we cannot defer to a

simple past history of similar applications – which would be the case if it were just another pig

farm or chicken farm or kennels. Like me many residents have invested considerable time

and expertise to research and understand how these new aspects may affect us and those who

use and enjoy this setting. And those who might come after us. At its simplest – the planning

application has aspects like a gravel pit or fish farm on a small site in a sensitive locations and

closer than ideal to dwellings. But it’s more complicated than that. Good luck with your

scrutiny of all the comments. And best wishes.]

Why should you (please) listen to what I say?

I live in Chiltington Lane close to the proposed caviar farm. My property borders the caviar farm

along a field, garden, wood and at times across a stream. And it is downhill and down slope of

the site which has since Roman times been pasture but which (if you permit this scheme) will

be more like a set of lakes with unusual things in it.

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I hope you will read and give equal credit to all the locally informed and connected comments

you receive.

To me as a layman planning policy is about place, people and predictability.

I’ve lived in the countryside for 40 years. Until these caviar farm applications came along I have

never objected to a planning application.

Why do I and other objectors feel strongly about this?

For the past 25 years I’ve earned my living by working in the countryside (using modern and not

so modern communications) to help many of the world’s leading computer and silicon chip

companies which are located in the US and China to understand changes in their markets and

grow their businesses to satisfy evolving customer needs.

I have also as a hobby for 16 years written some children’s stories which are set in the

countryside (in Hampshire and in Underhill Lane not far from Chiltington Lane). These capture

the magic of these hidden rural locations and although they were written for closely connected

children (who are now adults) my readers from as far away as the US tell me they like the

England they see.

It’s an England which is still real in places like East Chiltington.

And it is our duty as those privileged to live here not only to record why we like it (as many

locals have been doing this month in the Rural Assessment Survey) and it is also our duty to

protect it for those who pass through and to ensure that others in the future can enjoy it after we

have left. But protecting the landscape and messy organic character of places like this is

important for those who live elsewhere too. Because it makes them feel good to know that such

places still exist.

We can’t all live in castles or national trust properties or heritage countryside – but it’s jolly

comforting to know they are still there.

During my time living and working in the country I have observed and watched with admiration

how my neighbours and friends can live very different lives in the countryside yet still

together almost accidentally weave a fabric of harmony and place about where they live. Even

when they may have different views and interests on other matters.

Getting back to the plan

This revised plan following an earlier application LW/16/0180 (poor you – having to read so

many each year) shows that the development company has demonstrated no sensitivity to

local feeling.

It contradicts planning guidelines for this area and is incompatible with wider national priorities

which set the distinctions and priorities for different localities in a planning framework.

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The implementation and location of such a project here in Chiltington Lane (even with tweaks to

the plan) will always be obnoxious, alien and completely discordant with the aspirations for this

type of countryside.

I ask also that you pay great attention to any the genuine expert resident comments you

will get about this plan.

My neighbours together represent the local wisdom of many hundreds of collective people

years experience of day to day living in this very lane.

What they tell you should count for more in the balance and is more reliable than some of the

so called “independent” developer funded inadequate reports which have been written to

support the plan by parachuted-in expert report writers who pay a brief one or two days visit to a

single pair of fields in the lane and fail to look at the setting beyond and who aren’t here season

after season.

Greenwash

Language is important here too and how the you decide to interpret the meaning of words and

the reliability of statements made in support of the plan.

The development company (developer for short) when evangelizing this plan in public forums

(press and parish council meeting) has used phrases to promote this plan which in effect claim it

is a green, sustainable, diversification of British farming. That is the developer’s opinion.

But that view is not shared here around the lane. The use of such words – each of which has

genuine meanings established by usage, legality and context, can also be interpreted simply as

clever sales-oriented greenwash or marketing spin.

In this objection report and others you will see that such a scheme – the caviar farm and

processing unit and dwelling – in the small fields in Chiltington Lane are not green, is not

sustainable (from a planning viewpoint), and has little or no resemblance to traditional British

farming in the conventional understanding of that phrase.

Overall Plan - Location

The caviar farm would make a grotesque change to the landscape in this part of Chiltington

Lane. It is a risky development. Is unwanted by local residents. It will bring no advantages to

the local community or economy. Its disfiguring and strange persona will mar the view from a

panorama of locations within the South Downs national park – which lies a short distance over

the road and railway track.

This experimental in nature marine aquaculture and luxury food processing plant is too large in

relation to its settings, too intensive in scale for the land footprint which it occupies and too

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different in character from other fields along the contours lines of this end of Chiltington Lane

and Wycombe Lane.

The application refers to a previous caviar business in Devon. That business was an

incremental change to a pre-existing fish farm. A spokesperson for the developer said on BBC

radio (September 16) that a license for that site which was granted in the 1950s would be

impossible to get today from the environmental agency. It’s a different type of site and

different farming process. So referring to it as an authority or precedent for this site in

Chiltington is not valid.

In that old Devon site the main thing which changed there was substituting one species of fish

for another. Whereas in this site at Chiltington – there is no existing fish farm. The site is on hill

and slope very close to houses including listed buildings.

Sanity check. Even if the caviar site were very much larger in acreage than it actually is then

planning rules for permitted development of fish farms disallow the location of such ponds so

close to listed buildings.

If you allow this application it will set a precedent for developers to ignore carefully evolved

guidelines for the countryside which have been established by experience and other planning

experts like you over a long time. And a decision to grant permission will re-open and change

these proximity rules anywhere in the UK which currently protect people by placing safe

distances between large water structures and pre-existing residential buildings.

The idea that collecting and placing large bodies of water which overlook and overhang houses

on a hill around which there are no large open regularly flowing water courses makes no

sense to me as a precedent for you to establish.

If the developer wants to build something like this. It should try somewhere else which already

has compatible aspects.

To build the “ponds” and site infrastructure will require scooping out a hill, moving thousands of

tons of earth and creating a site which will be discontinuous from adjacent land (as the caviar

farm land will rise considerably compared to its surroundings due to all the earth – which is

being dug out having to be scattered around on site and reshaping the site in a permanent way.

If this was an application for a gravel pit – right next to a quiet conservation area would you

treat it in any different way?

This is worse - because the introduction of ponds and alien species - sturgeon - and associated

industrial park-like infrastructure (pumps and processing buildings and a dwelling) into a small

field will cause great disturbance and permanent scarring of this area. It’s illegal to release

sturgeon or their eggs into wild water courses hence the need for bulletproof water containment

and zoned spacing here in the UK.

Core policies?

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This development is alien to and out of character with its surroundings. It's in contradiction to

Core Policy 10 of the recently adopted Lewes District Council Core Strategy Local Plan and the

Lewes District Council Local Plan 2003 core policies CT1 which deals with where development

is applicable and H2 which deals with historic buildings and their settings. Both of those are still

applicable under the current policy regime.

I also strongly object to the application for a dwelling on the site and its size.

The application suggests that a dwelling is needed so that an agricultural worker can feed the fish

and sort out problems if anything goes wrong.

That same argument could be used for anyone who buys a field and then buys a horse. But you’d

throw that out.

You should throw out this idea too.

Affect on the landscape seen from the adjacent national park.

I can see Black Cap on the South Downs National Park from my garden. My view is through

the caviar farm site.

That means Black Cap can see me and see the caviar farm too.

Other iconic locations from which the caviar site is clearly visible from within the national park

are on the nearby slope off Chiltington Lane which overlooks Spooners Farm. This is one of the

most beautiful viewpoints in East Chiltington and was one of the sites chosen for the recent

landscape assessment survey.

This parcel of our land is almost the end of an ancient woodland and hedges which once

stretched all the way to the Downs. Big oak trees are a distinctive feature of this part of

Chiltington (you can see some in Hurst Barns and some along the lane hedge-line of the fish

farm). But I think from having walked around the area that Chiltington House includes the

densest collection of large and still living oak trees in the area.

The dwelling - why it fails the functional planning tests

From an animal welfare point of view a well designed pond system should be designed to run

automatically most of the time. And if there are interventions which are needed from time to

time – due to broken pumps, the need to rebalance the water with chemicals etc – then (even

with a small swimming pool) the time lags are large. It takes hours for water quality to change.

More likely for larger pools something on the order of days.

Consider this. Suppose the resident worker is out shopping or visiting friends elsewhere.

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Are we really to believe that a responsible aquaculture system would be built which would place

at risk such an expensive fish stock – just because someone is off site for an hour or so? What if

it takes a day to get parts to fix a pump?

The need for onsite personnel living here is nonsense. Water treatment plants are more resilient

and if fish need to have their tea at the same time every day they might get a bit grumpy if the

feeder is a bit late (or breaks down).

The caviar site workers can live and commute from local housing like others who work around

here.

Over 30 years ago I designed systems for water boards to give them remote control and

monitoring of water treatment plants. Nowadays many local residents have systems in their oil

tanks which can call using mobile phone technology to get them topped up. The caviar farm too

can use a mixture of technologies (internet and cell phone) to keep remote track of what’s going

on. And by pinging each system they can sure to avoid the risk from loss of communication.

Another argument given in the plan for a dwelling is security.

Really? Why is that necessary given the availability of remote alarms and the physical security

of the site which ensures that any opportunistic entrance to it by unauthorized vehicles can be

easily prevented by the site design and boundaries.

Also I reiterate – what happens when the resident “guard” is off duty or out at the pub or away

at some other social function?

In the plan documents it says that there will be no site wide lighting. So if anyone intrudes into

the site not only will they set off alarms but they’ll have a hard time getting around at night

without being noticed by neighbouring properties.

The caviar site is not unique in needing alarms.

Or are we to understand that the caviar site itself would introduce such an unusual element of

security risk?

Is that a risk for residents?

That runs contrary to the application for a wind turbine. This could be seen from a long away

could act as a beacon to a back door entry to the sight. But there are better arguments for

rejecting the wind turbine application.

I think the above analysis shows that a dwelling of any size (and particularly this size) is not

justified to support the caviar farm at this time.

Water issues – this is an aspect where detail matters

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Water plays an important part in assessing this plan because the scale of the aggregated volume

of water in the pools and its context in the land contours and proximity to other natural water

sources would make it a disproportionately heavyweight influence. Effectively a collective lake

of water up on a hill which was pasture before and which (once filled) will be a dominant

influence in its local area.

Although I am not an angler I have learned a lot about the influence of water in Chiltington

Lane during the past 10 years due to the weather ranging from the wettest to the driest in the

past few hundred years.

I walk over the stream which flows through my land nearly every day and have seen how it

changes during all seasons including the dark cold nights of winter when I go to collect logs

from a shed and when I have sometimes seen the sea trout swimming under the bridge to where

they came from - just yards downstream of the caviar farm site.

From a planning point of view I see these questions as being important.

1 – how will the sturgeon farms be filled and kept topped up?

Various statements have been seen by the developer in the submitted plan and in the media in

the past weeks.

Let’s play it safe and assume that the water could come from, a variety of optional sources.

1a – from the winterbourne. This option would not be possible in summer when the stream is dry

and there is no free running water. At this time of year the stress on evaporation of the sturgeon

pools is greatest and estimated locally by an independent expert at about three quarters of an inch

per day. In drought conditions the levels of long established ponds in East Sussex which had

feeder sources and were located down hills – reduced to almost mud levels. Clearly that would

be an unacceptable risk for the sturgeon.

1b – supplying water from the mains drinking water. When I first read about that option in

documents and statements by the developer I thought it was obscene from an environmental

point of view. Nevertheless from a practical point of view it might work although that means that

local residents will have their drinking water reduced to a trickle or will have to use bottled water

such as happened a few weekends ago due to a fault in the water grid which affected Hassocks,

Chiltington Lane and Chailey.

I’d like to draw to your attention that placing a new stress on drinking water sources by new

developments such as this (which aren’t critical for housing or conventional food security) runs

directly counter to the government’s emerging policy aims about water resources in relation to

setting the planning agenda for climate change.

1c - Abstracting water from the water table (from below ground).

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If this is feasible I see 2 problems with it.

1c-1 – Listed building risk. The water levels in the clay gravel ground around here is high

during wet seasons and lower during dry. But if water is abstracted during dry weather the effect

will be to disturb the islands of clay lower down the slopes around which 4 buildings are

located (Upper Burrells, Burrells, Beams and Kemps House). 3 of these are listed.

Neighbours in some of these have told me these already show sensitivity to dry weather

conditions due to the clay underneath drying out. It seems reasonable to assume that if large

amounts of water need to be abstracted during drought conditions to sustain the sturgeon ponds

then this may cause structural damage to listed buildings.

That’s why in “permitted” developments there are distances established for ponds in new fish

farms.

And the caviar farm plan is worse because it will be abstracting water from a higher level than

these properties. (Not on a similar or lower level as in better sited locations.) From a planning

point of view therefore it seems reasonable to argue that such ponds and their abstraction sources

should be placed even farther away than the guidance. At a minimum. (But the caviar farm site

is not big enough in length to support that.) That’s another reason the plan (regardless of the

caviar element) but simply based on an analysis of water issues – should be rejected. You are

being asked to override years of established rules which have been established by planning

experience.

1d – harvesting water from rainfall.

For this to fill the pool in less than many years the collection area around the pool needs to be

hundreds of times larger than the pool area itself.

In this plan application the pool area is too large compared to its site to ensure this can be the

primary method of filling the pool. And the relative size of pool to site also casts doubt on

rainfall being able to provide enough water for topping up.

Hence the need for the less suitable (from the environment point of view) other methods.

It’s obvious if you think about it. Over the past 2,000 years no one has built a lake on this site.

Without mains water, huge pumps and scavenging precious groundwater such a scheme

couldn’t work. A question is are the collection methods allowed or desirable?

Flooding risk – background considerations

Currently (before the caviar farm) there is no serious flooding risk in this part of Chiltington

Lane. But the caviar farm could introduce 2 risks of flooding which weren’t there before. This

was noted as a potentially serious objection to this plan by the East Chiltington Parish planning

meeting.

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Here’s what I’ve seen.

At times of heavy and sustained rain the road by the railway bridge at Beechwood Lane (at the

Lewes end of Chiltington Lane) regularly used to flood upto several feet. Also by the stream

over the bridge on Highbridge Lane (which is the same road as Chiltington Lane) the road used

to flood regularly to an impassable level. But those bridges are some way from the caviar farm.

So far so good.

The road bridge near Romans and Chiltington House which crosses the winterbourne and which

intersects with the caviar farm and Chiltington House on the other side of the road does from

time to time overflow onto the road during heavy rain. But in recent years it has rarely risen

more than about 6 inches. Upto now the adjacent properties have been close to rising water

levels but have never penetrated (as far as I know) even during the wettest seasons recorded.

Flooding risk – possible vectors from caviar farm

I think the caviar farm introduces flood risks from these vectors.

Introducing a new flood risk during construction of the site. If there are large heaps of soil

around the site and close to the land boundary or the winterbourne when heavy rain occurs then

even a small amount of mud being washed into the stream might block the natural flow along the

water course.

This would divert upstream water onto the road. And this flow down the road would be a

flooding risk for properties and would make the road impassable.

It’s important to note that this risk will be present before there is any water in the sturgeon

ponds. The risk factor is mudslides which could divert the flow of the stream.

Introducing new flood risks after construction of the ponds.

The operation of the site will require planned discharge of water but documents lodged by the

developer at the start of the resident consultation period which I’ve seen didn’t have any

meaningful detail about those processes.

In seasons of heavy rain there is a risk that planned discharge pipes (which are not shown in the

documents I have seen) will be insufficient to keep water levels in the ponds within ideal design

limits.

There is therefore a risk that water which is discharged to the reed system will be amplified by

the hard landscaping and water capture features of the site and by the presence of the ponds

themselves and that feeder channels may act to increase the amount of water concentrated in

particular directions (compared to the natural landscape position).

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Another risk factor is catastrophic overflow from the bunds. It is impossible for us to quantify

this. It is easier to state that if a large body of water wasn’t deliberately accumulated up the hill

in the first place then this risk wouldn’t be there at all.

Although the plan on the LDC web site says some things about this I have also heard different or

additional details from press reports, and other communications by the developer.

So as some of the plan details seem to be fluid I may be covering points here which have again

changed by the time you see this. In that case – just skip over them.

Here is a view of the winterbourne taken from my property showing how little water there can

be in summer. I won’t bore you with more pictures. But I’ve got a lot.

Photo above. Romans winterbourne (typically no open flow most of the year). To the left is the

fish farm. Right shows copse at Chiltington House.

However, even when parts of the winterbourne here look dry – there are still every 20 yards or so

deeper gravel areas which act as a habitat for wildlife. Fish and eels have been seen in these

little deeper ponds in the stream even when most of the stream is dry.

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These are very small bodies of water – not much bigger in volume than a typical car.

OART the Ouse and Adur River Trust are an independent conservation group which monitors

water quality in these connected waterways. And over the years they have visited this site and

sites upstream and downstream to assess the ecology impact of farming, housing etc.

In a document on the LDC site responding to this application you may have seen that they

question many aspects of the plan and the developer’s often quoted claim that it is a “closed

system”. (It is not. A closed system would have no open water and no water flowing over the

ground – as in the reed beds.) OART has serious concerns about both abstraction and

discharge.

At the same time -

2 – how will excess water flow, overflow or be discharged from the slopes down to the

winterbourne?

Loss of Amenity issues – at Chiltington House - noise, smells etc

My main sitting room, some bedrooms and a bathroom, and garden and swimming have full on

view to the caviar farm site which overlooks this property and is just a few metres away from the

curt ledge of my house. In winter when the leaves from the oaks and other trees have fallen then

my view will change from being pasture to an artificial and discordant landscape.

Just as important – workers and visitors to the caviar buildings will have full on views of my

living areas – which especially at night – was never a concern before.

At a very minimum I ask you to prevent windows in any buildings which look down to the house

and garden at Chiltington house. And to control light pollution around the perimeter of the site

where it adjoins any other property.

Noise. Between the times that people are mowing their lawns and the birds are singing (when the

developer’s noise survey was carried out) this is a unusually quiet area.

I am concerned that the continuous background noise from the flow of the water channels is

much higher than the current ambient and also this will occur at night too.

The use of bird scarers which has been mentioned as a technique to protect the site.

I don’t remember seeing them mentioned in the noise model.

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As to the pumps etc. The model details and the on to off running ratios and times haven’t been

stated (or I couldn’t find them) so the noise estimates in the supplied documents are hard to

reconcile.

I am concerned about my loss of amenity due to pollution from foul water from the fish ponds

streaming down onto our land from the so-called "reed bed". The slope of the land is such that

water naturally drains onto our land way in heavy rain. I am concerned about getting water

which is tainted with smell and other wastes.

The land already slopes down onto the field where there is a long established summer house

which was erected by a previous resident. (And regarding which your own enforcement people

have kindly informed us you are satisfied.)

I earn my living is as a writer and I walk up here to the summer house nearly every day to

organize my thoughts. (If my writing here seems less organized I apologies but I have had less

time to do these walks in recent days due to time pressures created by the deadline of this

application.)

The light and view from this point in my property will be reduced due to the ground level in the

caviar site being raised higher than it was before naturally.

The associated buildings will also have full on views to my house and garden.

See these photos for details.

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The caviar site can be seen to the right of the tree line. The unusual ridge in the background is

the side of the 2 “test” ponds which were dug in 2014 for which planning permission is being

sought retrospectively.

It’s easy to see that when more soil is dug out to dig the whole site then the bumps could get

bigger. There will also be a bunch of buildings which appear in this view too.

More significantly the caviar site looks full and is above my house and workers and visitors to

the site overlook bedrooms, children’s play area and swimming pool.

Animal issues – biodiversity and cruelty

re the Preliminary Ecological Appraisal

The document in 2.14 stated “It is considered that the survey was sufficiently rigorous to assess

the ecological value of the site.”

I disagree with the conclusion that the desktop survey and on-site survey at a single time of year

were adequate or give a reliable indicator to make an ecological determination of the impact of

this project.

I think a full ecological impact survey is needed with sampling visits over a period of time and

with sampling in adjacent properties. Otherwise any decision to grant planning permission will

be risky.

Ecological anecdotes from neighbours next to and near the caviar farm site.

Several neighbours earlier this year were reporting and photographing great crested newts in

their ponds and invited newt experts to comment on them.

My property which is adjacent to the caviar farm site has ponds and habitat which might be of

significance to a fit for purpose ecological survey. I am surprised that no effort was made to

ask if a field or pond survey could be carried out in these adjacent properties by the developer’s

contractor. It seems that the scope of what they were asked to do was woefully deficient.

I have also seen many toads and frogs this year already on my property which is next to the

caviar farm. Although I tried many times to report them using the froglife app – it just kept

hanging so I gave up. This shows that it is not reliable to infer ecological impacts for such a

sensitive location relying too heavily on desktop research. The “preliminary” report is inadequate

as a planning guide.

Biodiversity – threat to geese and ducks and loss of habitat

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I understand that protection measures for the sturgeon may include netting over the ponds. If so

I wouldn’t this idea.

We get overflying geese and resident and dropping in wild ducks in and above our property.

I have also seen geese landing in the fields and then making their way to the winterbourne.

Would the effect of netting be to trap and drown these birds?

It sounds like the opposite of biodiversity to me.

I have also on a few occasions seen Heron on my lawn standing by the side of the winterbourne

to check out the water. They were not impressed and didn’t stay for more than about 10 minutes.

So I think that the risk of maybe one visiting heron every couple of years or so doesn’t justify

extreme measures like nets.

The open drain (reed beds) could become a new breeding ground for mosquitoes and midges. I

suppose that increases the biodiversity score but would be a nuisance to adjacent properties.

Also re bigger mammals… I’ve seen rabbits and deer on the caviar farm site. After the ponds

have been dug the ecology will be different and deter them.

One of the reports talks about the benefits of adding more scrub to help biodiversity. That sounds

fine in theory but the practice on the site in the past 2 years has been exactly the opposite. The

fields are much tidier now than they used to be and areas of scrub along the winterbourne and

also along the lane have already been cut back considerably.

If planning permission is given then the site based on what I’ve seen in the application and an

artists’ impression attached by the developer on the farm gate next to the planning notice (on

September 3, 2016) will be more urban and water treatment process like. And it seems to me

that there will be less biodiversity.

Maybe not a deal breaker from a planning point of view you might say. But it makes you wonder

about the reliability of other things in the supplied documents too.

Animal cruelty

I have read that a no-kill method of harvesting sturgeon to extract caviar which was pioneered in

Germany (and which sounds similar in some aspects to the application methodology) has been

banned on grounds of cruelty and unsuitability as a human food source (if hormones or similar

agents are used to simplify harvesting). The videos I’ve seen on the internet certainly suggests

the method is cruel. I don’t like it. But my main objections are planning based. And if the site

isn’t built then it won’t be cruel.

A more serious concern is the possible use of nets to protect sturgeon.

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Such netting (if deployed) could drown visiting birds and I feel this would be disgraceful.

Inflicting death on natural species to protect an alien money making species.

But if permission isn’t granted then I don’t need to worry about it.

Re retrospective application for permission to dig test scrapes.

I object to this. They are already an eyesore and have made that part of the field useless for

arable use or animals. (Horses would break their legs or necks if they went near). So I urge you

to enforce them to be filled in as soon as possible.

We’ve already waited 2 years.

The cost of doing that will be minimal compared to the huge cost of filling in the whole site

after the caviar phase of its life was over (were you to grant permission to the current

developer).

Which brings me to sustainability.

Sustainability – objections to the caviar farm plan

This is a serious planning consideration. It focuses on sustainability of the land use (by

changing it to aquaculture) and what will happen to the land after the caviar business phase and

whether the modifications to the fields will prevent it from being economically usable for other

types of farming afterwards.

Let's for sake of argument entirely set aside any short term questions about the applicant's

business plan and the viability of the sturgeon business.

What happens afterwards? In 4, 5 or 10 years time? After a time when this sturgeon site is no

longer needed by this business for whatever reason.

All markets have their ups and downs and it would be an extraordinary presumption for Lewes

planning (or anyone else) to assume that this type of caviar production and processing from this

site would always remain an attractive business option for all new owners of the land.

With traditional farming in this area we know that the produce which is grown mostly requires

just changes of machinery and the equipment and changes of seeds or livestock. The land having

been used for one purpose does not have to be entirely re-excavated in order to make it usable

and adaptable again for other types of field based agricultural outputs.

But fish farming is different.

Reshaping the site to support caviar farming would make the plot forever uneconomic to

restore traditional farming use.

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What about farming other species of fish? Is the site big enough to support a business model?

Is the depth enough? What about smell factors? Flesh weight? Without an indication of how such

ponds could support other business models this application seems to fail the sustainability test for

allowing the change of use to a fish farm.

You as planners can see the precedent of disused gravel pits at the other end of East Chiltington.

A sustainability argument that the ponds could be viable and compatible with planning

guidelines using different fish species hasn’t been seen yet.

Without that – the application is suitable for one type of business only which may go out of

fashion or change in the future leaving a legacy of unusable land which previously was exactly

the same in character as the fields in nearby farms.

Concluding comments

It has required a lot of work to look at how this plan would affect me and my neighbours and

those who visit and cherish this part of East Chiltington.

Due to inconsistencies in the application documents on the LDC web site, missing, incomplete

and unreliable reports and due to public communications by the developer which seem to

change details of the plan from day to day it has been hard to locate a core of hard unshifting

design features.

Despite those hurdles – the plan details which I have seen and which I have mentioned above

are enough to confirm in my mind there are many serious planning reasons to reject this plan.

Another elephant in the room is the underlying business plan which is supposed to support this

application. Residents have been told that it’s confidential and we can’t examine it.

From my perspective there are enough reasons to reject the plan irrespective of whether a caviar

farm could make money on this site. It’s the wrong thing in the wrong place.

Thanks for your time.

Zsolt Kerekes

Resident of Chiltington Lane