Objection 1
To the redesignation of the Holiday Camp area to housing
1 This does not conform to the Development Brief
Section 5.0 Aims & Objectives, which includes
enhancing Seaton as a Visitor Destination
promoting a diverse range of tourism and leisure activity in the town
encouraging more and longer stay visits to the town.
2 This does not conform to the East Devon Local Plan
Policy TO3 (Loss of holiday accommodation) which says
“The proposals for change of use or redevelopment of holiday accommodation in…..Seaton… will not be permitted.”
We note the letter from Hollybush Hotels saying that their business is not financially viable, but this relates solely to the current owners and their current business and in no way does it show either that “holiday use” is no longer viable or that “there is no market for the business as a going concern”.
We note that the planning application now talks only of day visitors and not overnight stays. To our knowledge there has been no study showing the desirability or the impact of such a change and since overnight stays bring in approximately three times as much income as day visitors we object most strongly to the loss of “the major provider of visitor accommodation”.
It is our view that the land currently occupied by the Holiday Camp should retain a commercial/leisure planning designation.
It is totally unsatisfactory to suggest that overnight accommodation can be provided by building a hotel on land not in the applicant’s ownership.
Objection 2 - Flooding implications
1 The calculations of rising sea levels are based on out-of-date data. Current Environment Agency figures would suggest that the site needs to be raised by an additional metre (ie from approximately 2 metres above current levels to 3 metres) with corresponding implications for the amount of construction traffic and the impact on the adjoining area.
2 The application is contrary to Policy EN 26 (River & Coastal Flooding) in that it does not provide sufficient protection for the existing properties along Harbour Road. On the figures used in the application it is suggested, by the applicant, that rescue boats might be needed to ferry people to refuges from Harbour Road.
Objection 3 - Retail and Employment
1 We object to the retail provision of the application
The Development Brief Section 5 Aims & Objectives which includes
Encouraging long term viable growth for the town
Enhancing the vitality and viability of Seaton’s retail offer
Retaining employment uses in the town
The Local Plan Policy SH1 (Town Centre Shopping Areas) states
“The establishment of new shops which are outside defined town Centres will not be permitted if they would harm …the vitality or viability of the town centre”
Para 18.0 of the Development Brief states
“(the supermarket) should not be of a size that would undermine the existing shopping centre”.
The planning application offers two large retail premises separated from the main town centre. The size of the proposed development means that it has the characteristic of an out of town supermarket, although in an edge of Town location. This, together with the unreliability of the survey (see supporting document), means that we are very concerned about the continued viability of the existing shopping centre, if this development goes ahead. A smaller retail space would lead to more frequent linked trips to the town centre and involve higher spend. Links to the current Town are very poor and the proposed pedestrian crossing is totally insufficient to address this.
We object to the lack of employment opportunities in the application
Part of East Devon’s Corporate Strategy (Local Plan page 107) is
“to create a stronger and more diverse local economy ….. which offers secure and good quality employment to local people”
The Sustainable Communities Plan 2006-2016 talks of
“increasing opportunities for raising average incomes through regeneration”.
Where is the good quality employment offering career prospects?
Where is the opportunity for diversity of employment opportunities?
Live/Work units, for example, would encourage artists, craftsmen and other small business opportunities.
It is not clear whether the employment generated will in fact represent a net gain after the closure of the holiday camp and any Town Centre premises is taken into account.
Objection 4 - Housing
We object to the increase in housing from the original figure of 300 homes to the currently suggested 500, for the total LSE2 site.
This is because the increase in housing has been at the expense of tourism and employment opportunities, both of which are essential for the regeneration (as opposed to the redevelopment) of the town.
We want the presumption of 40% affordable housing to be applied to this site. This is critical for both economic and social reasons.
The purpose of the LSE2 development is intended to be the regeneration of the town. Affordable housing is a way of ensuring that those moving in are both young and economically active.
We suggest that some of the housing provision be in the form of Live/Work units. This would both increase the diversity of housing on offer and would encourage economic activity.
Objection 5 - Community & Youth Facilities
We object to the planning application on the grounds that it does not conform to the Development Brief , Section 5.0 Aims & Objectives which includes:-
“Enhance and diversify the range of community facilities.”
The following facilities are being lost:-
Youth Centre, which was also a venue for dances, bowls, bingo, table tennis, Craft and other sales
Day Nursery
Fitness Centre (including swimming pool, gym, sauna and Jacuzzi)
The only replacement being offered is the suggestion of a room attached to the Visitor Centre.
Objection 6 - Transport
1 We understand that the Transport Impact Assessment has been sent back for amendment, but we have no idea what these amendments refer to, let alone what they might be.
2 The application offers no mitigation of the impact of 90 16 tonne HGVs (or 65 20 tonne HGVs) per day, 6 days a week, (plus the return journeys) for three to four years.
3 Construction traffic may not be routed through Axmouth but the developed site will generate considerable extra traffic. The implications of this for Axmouth are serious.
Objection 7 - Open Space
We object to the lack of provision of Public Open Space
The children’s play areas and the skateboard park on the north west boundary of the site are already in existence and cannot be considered as part of the open space required by this development.
The only other so-called open space would appear to be the monsoon ditch (or flood relief channel). This is totally unacceptable, partly as the proposed profile makes it dangerous but also what is the intended leisure use?
For a development on this scale and density, the planning of landscaping and open space should be incorporated from the beginning.