Seaton Regeneration Area Plan :: Planning Support Statement

Planning Case in Support of the Application

5.1 The planning case in support of the application of Liatris Holdings being granted reflects the fact that the site is already allocated for development in the East Devon Local Plan and the proposals of the plan have been subject to public scrutiny in the form of the public inquiry into the Local Plan itself. Whilst comment is made on this issue below, the Local Plan proposals in principle were also regarded by the County Council as being in conformity with the Devon Structure Plan and the proposed development of the Seaton Regeneration Area has been the subject of various consultation processes in which the County Council, as strategic planning and highway authority, has been involved.

5.2 The contents of this part of the planning support statement also reflect the fact that Chapter 5 of the environmental statement sets out in full the relevant planning policies at national, regional, county and local level that apply to the application proposals. These cover not only housing and employment issues but also retail issues that are summarised in the separate assessment. It is therefore not proposed in this statement to set out at length the relevant policies as this will be duplicating issues covered elsewhere (particularly the EIA and retail assessment). It is though important to establish the context for the proposals and compliance with key policies before assessing the relationship of the proposals with the Council’s Planning Brief and highlighting key aspects of the development that are supported in planning terms.

Enhancement of the Role of Seaton

5.3 As set out above, it is important that the role of the application proposals in the Council’s overall Local Plan and economic strategy for Seaton is appreciated. The socio-economic chapter of the environmental assessment looks in detail at the current economic indicators in Seaton and they confirm why the Council has priority on regenerating the town through the development of the allocated site in the Local Plan. Some key issues with regard to Seaton’s economy include –

• the lack of population balance within the town and the concentration of older age groups to the relative lack of spending power of tourists visiting Seaton, either in the holiday village or on a daily basis;
  
  
• the lack of tourist attractions within Seaton;
  
  
• the high proportion of retail expenditure that leaks from the town’s economy to other town centres because of the lack of attractive food and non-food retail stores to complement the quality of individual traders within the town;
  
  
• the lack of job opportunities;
  
  
• the lack of a unique selling point for Seaton to distinguish it from other towns on the South Devon coast.
  
  

5.4 The principal means of trying to resolve the perceived difficulties that led the Council to allocate the regeneration site for development are the following: -

a) the need to attract new investment into Seaton;

b) the need to attract new people;

c) the need for development to be of sufficient critical mass to provide meaningful investments in enhanced tourism facilities;

d) a critical mass to provide the expenditure to attract significant new retail facilities that will then retain expenditure that leaks to other centres;

e) the ability to subsidise existing facilities.

5.5 The objective, particularly in tourism terms, is to change Seaton’s offer. The holiday village as set out in chapter 6 of the economic assessment attracts approximately 26,000 people per annum to Seaton and the types of tourist it attracts are generally people who do not have significant amounts of disposable income to spend on goods and services within the Seaton economy when they visit the town. The socio-economic chapter demonstrates that with the provision of the Visitor Centre (and also the marshland scheme) the tourism character of Seaton will alter radically, more tourists will be attracted and they will be in a position to dispose of more expenditure into the Seaton economy. The change will inevitably lead to the loss of the holiday village but what will transpire over time will be a much more robust tourism offer for Seaton.

5.6 The provision of the housing on the site will also generate in the region of 850 new residents who will be able to add their income into the Seaton economy and support local community and other facilities.

5.7 The provision of a new convenience goods store will seek to reverse the trend of expenditure leakage so that the Seaton retail economy will be far more self sustaining. There will also hopefully be a reduction in the amount of car borne retail trips to other towns that currently take place at an extremely high rate in Seaton. Currently more than 75% of comparison goods shopping trips and more than 60% of main food shopping trips take place outside the town from residents within it. This trend needs to be reversed.

5.8 The provision of appropriate car parking to serve tourism and retail facilities is also important given the convenience of car parking is an attraction to incoming tourists. The ability of the retail car park to provide short term parking for tourists is also important and is provided for within the scheme.

5.9 It is therefore important to appreciate that the loss of the holiday village is a key part of the process to upgrade and change Seaton’s tourism based economy. The fact that the holiday camp is unviable in its current operation adds to the need for its replacement by facilities which respond to more modern tourism demands than a holiday camp emanating from the 1950s. The size of the overall regeneration site development does give the critical mass to make meaningful contributions to the development of these proposed tourism facilities. With the arrival of significantly more tourists than currently happens – indeed up to 280,000 tourists are anticipated per annum through a combination of the Visitor Centre and the marshland, this will then itself lead to developments for further overnight accommodation which could be provided by new hotels within the overall master plan area and elsewhere.

5.10 The application therefore should not be seen as simply a large housing, retail and mixed use development. It is the means through which regeneration and improvement of Seaton’s economy can take place and in this respect the importance of implementing the Council’s Local Plan policy for the site is very high. The development of the site is the means to secure regeneration in the form of economic tourism and social benefits.

Compliance with the Development Plan and other Planning Policies

5.11 Chapter 5 of the environmental statement sets out in full the relevant planning policies that should apply to the development of the site for residential purposes. These policies at national, regional and county level set the policy context for the development of the site in principle. This states that new housing development inter alia should take place in a sustainable way and the location of new housing follows the sequential assessment as set out in PPG3. There is an emphasis in planning policy on the development of previously-developed land or brownfield sites. The fact that the vast majority of the application site (and indeed the regeneration area) is previously developed – being either car parking, the developed part of the former and existing holiday camp, land in employment use and/or hard standing, confirms that in principle the development of the site for housing purposes would be a priority in national and regional policy terms.

5.12 At strategic level, the Council is required to provide land for 10,200 dwellings between 1995 and 2011, 3,500 of which should be in the Exeter Area of Economic Activity. These requirements are within the Devon Structure Plan. Whilst the requirements are likely to be updated in the Review of RSS, the Local Plan relates to the approved Structure Plan covering the timescale referred to above. The Council has via its Local Plan process made decisions about how the overall housing allocation for the rest of the district outside Exeter is to be made – decisions that have been accepted by both the County Council and the Local Plan Inspector during the Local Plan public inquiry.

5.13 The key site specific policy relating to Seaton Regeneration Area is Policy LSE2 which seeks to provide an “….. overarching framework for the site and guides the mix of uses within the Seaton Regeneration Area”. Whilst it is not therefore intended to be prescriptive, there are a number of objectives within it that are taken further by the Planning Brief for the site that are worth emphasising at this stage. With reference to objective numbers 5 to 12 within Policy LSE2, the following comments can be made (objectives 1 to 4 were deleted in the Revised Deposit Local Plan): -

Objective 5

There is enhanced pedestrian cycle access through the regeneration area, including linkages between the town centre, Seaton Marshes, the seafront, the Axe Riverside and the harbour.

Objective 6

There is enhancement of community, leisure, tourism and recreation facilities, particularly the new square and the proposed new Visitor Centre.

Objective 7

The master plan promotes the harbour area as a gateway to the town.

Objective 8

There is retail and commercial frontage along particularly the Underfleet to complement the town centre.

Objective 9

Employment floor space within the area is retained.

Objective 10

There is residential development involving a variety of dwelling types and sizes providing approximately 385 units (the total potential of the site is 500 dwellings).

Objective 11

There are flood management measures in place on land within the flood plain.

Objective 12

There are measures to retain and enhance nature conservation interests throughout the area.

5.14 The policy also requires there to be mechanisms in place to achieve the delivery of a comprehensive regeneration scheme involving development contributions. This is anticipated to be provided through the means of a Section 106 Agreement, which is in the course of negotiations with the Council. The involvement of retail operators and housing developers will ensure the delivery of major elements of the scheme in any event.

5.15 There are various other aspects of the policies relating to Seaton that are relevant dealing with retention of employment, shopping and the town centre tourism and community facilities. The proposals of the master plan ensure existing employment is retained and enhanced; the retail assessment produced in conjunction with the proposals for the new food store and non-food store show that there is accordance with the shopping policies; the potential provision of the Council’s Visitor Centre enhances the tourism potential of Seaton. Any potential shortfalls of employment land are being addressed by the Council through means of an allocation of land for the employment use at Harepath Road.

5.16 In these terms, therefore, the proposals would be compliant with development plan and other relevant planning policies.

Relationship with the Council’s Planning Brief for the Site

5.17 Following the receipt of advice from consultants, the Council progressed to adopt a Development Brief for the Seaton Regeneration site in March 2005. It is important to emphasise that the Development Brief is not aimed at being prescriptive but seeks to suggest a framework upon which future development proposals should be based. Whilst the Planning Brief is recognised as having the status of supplementary guidance, the development proposals for the site need not strictly adhere to the ideas it puts forward, however, it is important that the objectives it is seeking to facilitate are provided by any alternative master plan proposals.

5.18 Whilst the nature of the objectives is discussed below, in the Development Brief is a plan indicating the Council’s intentions for the disposition of land uses within the regeneration site. This plan can be compared to the zoning master plan submitted with the application by Liatris Holdings. In making the comparison between the plans, the area of housing proposed is very similar with the only difference being that the main area of public open space associated with the housing area on the Council’s plan (shown on the southern part of the site adjacent to Harbour Road) is moved on the Liatris plan and contained within the wider site. The open space in the north west corner is retained. In the central and western part of the site, there is a difference in the location of the ‘commercial’ areas on the plan – principally the applicant has combined the two commercial areas with the car parking in the western part of the site whereas the Council had split the commercial area in two with the second area being in the southern part adjacent to Harbour Road. Broadly speaking, however, the combination of commercial areas and car parking in the western part of the site and housing in the eastern part of the site has been respected.

5.19 The Council proposed a vehicular and pedestrian ‘boulevard’ stretching from the Underfleet through the central part of the site running north west to south east, culminating in a viewpoint alongside the River Axe. The applicant shows an east/west link of a similar type, however, it has not been considered appropriate to extend the vehicular and pedestrian part of this ‘avenue’ as far as the Underfleet. This relates to the position of the Seaton Tramway Station on the site. On the Council’s plan, it was intended to be part of the ‘activity hub’ in the extreme north western corner whereas on the applicant’s plan, the tramway has been brought further into the site intended to terminate at the new square. As it is not possible for vehicles to cross the Seaton Tramway, the location in the square prevents a vehicular link being provided across it from the Underfleet to the central/eastern part of the site. It is also the case that there is no highways requirement for such a vehicular link to take place. Therefore it is not possible to have the ‘boulevard’ across the entire width of the application site and there is more benefit of having the tramway station near to the town centre, rather than in the north eastern corner of the site.

5.20 Whilst there are differences between the Planning Brief and the applicant’s master plan, it is considered the main difference relates to the location of the Seaton Tramway terminus and the implications in terms of the boulevard and other commercial uses.

5.21 It remains the case, however, that the aims and objectives for the development set out in Section 6 of the Planning Brief are accorded with, in particular: -

5.22 The commentary in the Brief concerning technical aspects has also been taken into account in the master plan proposals and these and other more specific land use benefits are explained in the next section.

Sustainable Development

5.23 The applicant has submitted with the proposals a statement relating to sustainable energy use and acknowledges that it is an important part of the developer’s responsibilities to provide development in as sustainable a way as reasonably possible. Discussions are taking place with regard to a number of energy saving measures that could be introduced as part of the housing and commercial development and the developer would be committed to a sustainable energy regime as part of the conditions on any outline planning consent granted. The types of measures that are being discussed include the following.

5.24 The objective of the applicant is to ensure that development will take place in a way that uses the most up-to-date techniques in terms of energy saving so that development would be regarded as sustainable in the context of Government policy in PPS1.

5.25 A sustainability appraisal has been undertaken and this is contained in a separate statement. However, to summarise, the main sustainability initiatives of the proposed scheme are:

• The proposals will result in the regeneration and development of a predominantly brownfield site. The master plan has been developed to promote key aspects of the site and local area and should provide a number of important facilities and tourist attractions.
  
  
• The proposals will provide facilities (eg, supermarket) and services needed by the local community. The improvement to the existing public transport links to and from the site should significantly reduce travel and ‘food miles’ completed by local residents. The development promotes the principle of sustainable communities by providing a live/work environment.
  
  
• An energy supply and demand assessment will be undertaken during the detailed design phase to determine the potential for utilising renewable or energy efficient technologies. Energy efficiency will also be promoted through the commitment to a BREEAM and Ecohomes accreditation.
  
  
• The client has committed to adopting a more suitable approach to natural resources and waste. Where possible, sustainable materials such as FSC approved timber will be selected. Water efficiency will also be promoted through the provision of rainwater butts and water efficient appliances.
  
  
• Important local ecological sites such as Seaton Marshes and Axe Estuary and Marshes will be protected during the development through the use of buffers and pollution prevention and control measures.
  
  
• Public consultation has been undertaken which has resulted in a number of changes/additions to the design proposal. Overall the development has been designed to create a more sustainable community by providing local access to jobs, leisure, retail and community facilities.
  
  
• The development will bring significant economic benefit to this area by providing a number of employment opportunities. Efforts will be made to recruit locally particularly from the on-site residential elements.
  
  
• A CEMP will be developed for the construction phase of the development which will address all aspects of sustainability such as waste, pollution, stakeholder involvement, energy and noise.
  
  
• During the operation phase of the development, the client will encourage any businesses to adopt an environmental management system accredited to a recognised standard. Efforts will also be made to promote recycling and resource efficiency.
  
  

5.26 Overall, the scheme is considered to be contributing positively to the national, regional and local policy objectives of implementing sustainable development. A number of sustainability initiatives have been implemented by the client and further commitments have been identified to improve the construction and operational phases of the development.