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Seaton Town Council Response to Planning Application 06/3400/MOUT

SEATON TOWN COUNCIL POSITIVELY SUPPORTS PLANS TO REDEVELOP THE LSE2 SITE WHICH WILL BRING ABOUT THE ECONOMIC AND SOCIAL REGENERATION OF THE TOWN. HOWEVER SEATON TOWN COUNCIL DOES NOT BELIEVE THAT APPLICATION 06/3400/MOUT WILL ACHIEVE THIS OBJECTIVE, AND THEREFORE RECOMMEND REFUSAL ON THE FOLLOWING GROUNDS:

A. Non-compliance with National, Regional, County, District and World Heritage Site policies and EDDC Development Brief which impact on Seaton and its hinterland, details of which are appended , principally:

  1. Building on a flood plain
    1. The Environment Agency has already requested an extension of time to comment, on the basis that the environmental impact assessment submitted by the developer may not meet the latest government planning policy statement 25;
    2. The land is part of a primary floodplain of the River Axe and in times of heavy rain, reduces the levels of flood water higher up the valley. To build on this floodplain could upset the delicate balance between the river, its opening to the sea, the harbour and the protective shingle spit which would lead to increased flooding of the hinterland;
    3. The submitted Flood Risk Assessment proposes a site evacuation management plan, refuges on the site and the supply of deep-wheeled transport or shallow draft boats stationed at the refuges. The Council believes that for such measures to be considered necessary indicates that the proposal to build on a floodplain is ludicrous
  2. Loss of tourism facilities.
  3. Lack of tourism infrastructure to support the Visitor Centre, Megamarsh and tourism generally.
  4. Loss of employment.
  5. Lack of quality full-time employment.
  6. Gross over-provision of housing – potentially across the whole regeneration site this would result in up to 80% of entire EDDC new build allocation being provided in Seaton.
  7. Affordable housing does not meet 40% criteria.
  8. Loss of community facilities with no replacements identified.
  9. Lack of infrastructure to support development of size proposed.
  10. Negative impact on natural environment and landscape.
  11. Lack of open space provision.
  12. Lack of play/sport facilities (football field, etc).
  13. Seaton’s water and sewerage facilities inadequate for a development of this size.
  14. Poor commitment to youth facilities.
  15. Inappropriate size and siting of Visitor Centre - current proposals likely to result in centre being unviable.
  16. Need for 106 education provision ring-fenced for Seaton Primary School phase 2.
  17. Transport Implications:
    1. the impact of the infill lorries on Seaton’s road surfaces.
    2. pollution.
    3. poor state of existing roads.
    4. potential damage to private properties.
    5. potential damage to footpaths.
    6. danger to residents and particularly to school children walking to the primary school.
    7. unacceptable carbon emissions, particularly affecting children.
    8. unacceptable levels of construction traffic and significantly increased levels of on-going freight traffic passing three schools – Seaton Primary School, Axmouth Pre-School and Colyton Grammar School.
  19. Risk of contamination of Marshes from overload of combined sewer.
  20. No dedicated access for all construction traffic away from the public Highway.
B. The unanimous opposition of the entire community of Seaton to this plan.

Seaton Town Council has enabled considerable public discussion and consultation on these plans. Attendance at these meetings has been high and the views expressed have been clearly against the proposals. Many letters of objection have been received representing residents, businesses, tourism, community groups, conservation groups, young people, medical profession, estate agents;

C. The opposition of the neighbouring parishes of Axmouth, Beer, Colyton, Musbury and Axminster to this application;
D. Members object to the proposal for change of use of the site currently occupied by Lyme Bay Holiday Camp from commercial/tourism to housing.

It is imperative, in order for Seaton to achieve economic regeneration and to fulfil its role as a Primary Gateway to the Jurassic Coast, that this land is retained for commercial/tourism use. There is no other site for this purpose. WHS policies recognise low spend of day visitors compared to bed night spend; in order to realise these benefits of spend into the local economy, Seaton must retain and increase its bed night provision;

E. Members object to the proposal to erect houses on the eastern edge of the Underfleet car park because of the close proximity to the skateboard park.

Evidence of similar developments close to skateboard parks in other towns shows that to build on this location is likely to result in the removal of the skateboard park;

F. Members object to the proposal to build on the Underfleet car park.

To do so will require the removal of the open space currently provided for a picnic site on the western side of that car park, and will reduce the number of long-term parking spaces available for tourists. This lack – and indeed reduction - of tourist parking will seriously jeopardise the viability of the Jurassic Coast Visitor Centre and EDDC’s Megamarsh project, as well as Seaton’s future as a tourist town. The significant number of parking spaces proposed for the supermarket will not meet the needs of tourists because of a 3-hour restriction.

G. Members object to the proposal to build houses on the western side of the Underfleet car park.

Dwellings require the land to be raised whereas commercial properties do not. The Visitor Centre and Megamarsh Projects could proceed without this land being raised;

H. Members object to the loss of public toilets at the site.

The proposal that these be included in the Visitor Centre could seriously affect the financial viability of the Centre and will result in a reduced service for significantly increased numbers of residents and tourists

I. No commitment in the documentation submitted that all roadways and footpaths within the development site will be completed to the standard required by DCC Highways to conform with their adoption policy.
J. Roads within Seaton leading to development site have inadequate surface cover and will leave the town’s major roads in a state of major repair
K. Short-comings in Retail Impact Assessment due to survey conducted by telephone which is recognised as a statistically least reliable method of survey.
Seaton Town Council formally requests:
  1. a copy of EDDC Officer response/s to this application prior to the Development Control Committee meeting at which this application will be discussed;
  2. that they are advised of the signing of the decision notice;
  3. that they wish to be party to any 106 discussions and agreements;
  4. details of which Housing Associations EDDC has consulted regarding the provision of affordable housing on this site;
  5. a copy of a health and safety impact assessment on the proposed flood relief channel;
  6. confirmation that EDDC has evidence that the developer has the finances to meet the up-front infrastructure costs such as land in-fill. Please advise what steps EDDC is taking to assure themselves that the developer is financially robust to fulfil this requirement;
  7. How robust is Liatris and/or subsequent landowners for their on-going commitments, i.e. maintenance and liabilities;
  8. Evidence that the developer will meet all licensing controls for both the source and the transportation of fill;

Seaton Town Council reserves the right to amend or add to its response on the receipt of ANY re-submitted Impact Assessments which have been requested, but not yet received.

Attached:

1) Appendix 1 – national policies which this application does not meet

2) Appendix 2 – Regional policies which this application does not meet

3) Appendix 3 - Structure Plan/Local Plan and Development Brief policies which this application does not meet

4) Appendix 4 – World Heritage Site policies which this application does not meet

5) Appendix 5 – Youth Provision requirement which this application does not provide – in fact it removes youth provision in the town

29th January 2007

Seaton Town Council response to 06/3400/MOUT

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