Seaton & Colyton MATTERS

My objection to the proposal for a housing estate in the Seaton-Colyford Green Wedge

Posted on February 23, 2023

I have submitted the following objection. Please submit your own, in your own words, selecting the issues that are most important to you – no need to go into as much detail as I have. We now have around 100 objections but we need more!

Application number 22/2781/MOUT: Land Adjacent To Harepath Road, Seaton EX12 2WH

On 21 February 2023 I chaired, as a former County Councillor for Seaton and Colyton, a meeting of over 150 Seaton and Colyford residents who were almost unanimously opposed to this application (only one person was not opposed). Many reasons were given for opposing the building of a housing estate on this site, but some fundamental issues stand out. In this objection I why the proposal contravenes the Local Plan and the Council should reject the proposal.

1. None of the land proposed for housing is allocated for this purpose in the plan, and much of it is outside the Seaton Built Up Area Boundary. Since this is classed as Countryside, the proposal is contrary to Strategy 7 of the Plan, and since it is part of the Seaton and Colyford Green Wedge, the proposal is contrary to Strategy 8. The scheme will bring Seaton’s urban area right up to the A3052, virtually closing the Green Wedge between Seaton and Colyford on the Harepath Road side, and creating a precedent for filling in the Green Wedge altogether.
2. The proposed housing estate will bring suburban development close to the northern end of Seaton Wetlands, opposite its main entrance at the Cemetery, harming wildlife (including but not only bats) as well as their attractiveness for residents and visitors alike. This is contrary to the Local Plan’s commitment to Seaton’s environment: “Seaton’s outstanding natural environment especially its wetlands is its most precious and defining asset, and policies for the conservation, enhancement and sensitive management of the landscape, heritage and wildlife of the area will be prominent.”
3. The development therefore also contradicts the Local Plan’s view of Seaton’s economic future: “Longer term growth of tourism, especially green tourism, is a fundamental objective to be promoted and we will seek to enhance the social and community facilities of the town. The Axe wetlands, Dorset and East Devon Coast World Heritage Site (Jurassic Coast) and surrounding exceptional coastline will be key environmental assets that will be integral to the future success of the town.” This impact is therefore is contrary to Strategy 25 (Development at Seaton) which states, “we will promote Seaton’s role as an important ‘green’ tourism destination on the Dorset and East Devon Coast World Heritage Site (Jurassic Coast)”, and to Strategy 33, on tourism.
4. Contrary to the applicants’ claim that “the proposed site is readily accessible by non-car modes of travel including walking, cycling, bus and train”, there is no train service in Seaton, bus services have deteriorated, and the site is not sustainable for pedestrians. The walking distance to the centre of Seaton is approximately 1.5 km or 25 minutes average walking time, compared to the accepted 800 metre norm; moreover the most direct route via Colyford Road is unsafe as I explain below. The site is also more than 800 metres from the GP practices, local schools and Seaton Hospital. A suggestions which has been made for a new crossing to assist the new residents to access the Stop Line Way Multi-Purpose Trail would not solve this problem since this route would lengthen the journey to most facilities still further, and so is not an answer to everyday travel issues. The proposal is therefore contrary to Policy TC2 which states, “New development should be located so as to be accessible by pedestrians, cyclists and public transport and also well related to compatible land uses so as to minimise the need to travel by car.” Seaton needs development on brownfield sites near the centre, from which residents will use town-centre businesses and facilities, not edge-of-town developments that will send residents off in their cars to shop in other areas.
5. The development will increase car movements on the narrow and winding Colyford Road. This is without pavements on some sections and is therefore unsafe for pedestrians. I asked Highways to investigate this issue when I was County Councillor and it was concluded that because of the width of the road, itself constrained by the buildings on either side, it was not possible to provide the necessary pavements. The proposal is therefore contrary to Policy TC7 which states that permission will not be granted if “the traffic generated by the development would be detrimental to the safe and satisfactory operation of the local highway network”. The applicants’ transport assessment recorded vehicle movements on a school day outside the main holiday period, although Seaton is a seaside tourist town with greatly increased traffic numbers during holiday periods. For example, Seaton Tramway had 93.5k visitors in 2022. The transport assessment was also undertaken at a time when the tourist attraction Seaton Jurassic was closed. This is due to re-open, bringing substantial numbers of additional visitors.
6. The eastern side of the development is likely to cause additional run-off to the south of the site, acknowledged as an area of flood risk where existing properties (in streets including Buttercup Close, Primrose Way and Celandine Close) have suffered from flooding in recent years. While the development itself may be in Flood Zone 1, the proposal is contrary to Policy EN21 which states that a flood risk assessment must demonstrate “that the development will be safe, without increasing flood risk elsewhere and, where possible, will reduce flood risk overall.” As the Environment Agency confirms in its objection, the applicants have not submitted a satisfactory flood risk assessment.
7. The proposal to add up to 130 dwellings in Seaton comes after the town has already delivered or is in the process of delivering more new dwellings than required by the local plan, with additional dwellings expected in other smaller developments. In these circumstances the proposed number of houses on this site is contrary to the local plan’s commitment that ‘there will be limited housing development in the short term beyond that already proposed in the regeneration area’ and that the authority will ‘restrict any further significant housing developments beyond the existing Built-up Area Boundary by locating the majority of the required 150 houses within the existing town.’  
8. Strategy 25 recognised that in Seaton “community facilities, school, health, social and cultural, were seen as borderline or inadequate with no capacity to serve additional residents.” The pressures have only become more acute since the plan was adopted in 2016: GP appointments are difficult to obtain and the school had only two spare places at the beginning of 2023. The development underway at Seaton Quay and the final tranche of houses at Pebble Beach will already add to these pressures. Since the application envisages that CIL money will be devoted to the football facilities, it is unlikely to generate significant resources for basic infrastructure, contrary to Strategy 50, which states: “It is essential that in areas where substantial new development is proposed, and in areas lacking facilities, that provision be made for community and education facilities.’
9. The Council’s Landscape Architect noted in response to a previous application submitted for this site stated that there was an underestimation of its visual presence especially within long distant views: “any development within the green wedge would extend Seaton’s suburban edge towards Colyford substantially and offer views from the wider area of an extended roofscape. It would reduce the travel time between Colyford and Seaton and change the gateway into and out of Seaton, giving it a suburban feel due to the visibility of the built form even with mitigation measures.” The photograph on page 14 of the applicants’ Design and Access Statement shows precisely how beautiful these views are; a housing estate in the middle of them will destroy them forever. The development is therefore contrary to Strategy 46 which proposes protection for landscapes of value, and since it will build right up to the boundary of the Coastal Preservation Area, it is contrary to Strategy 44 which states that development ‘will not be allowed if it would damage the undeveloped/open status of the designated area or where visually connected to any adjoining areas.’
10. This application proposes a new football pitch outside the Built Up Area Boundary, but as the Landscape Architect pointed out in relation to a previous application, EDDC’s Playing Pitch Strategy “identifies a need for minimum two adult football pitches and one youth (9v9) football pitch over-marking the second adult pitch for Seaton’s football provision.” Indeed, the Strategy also identifies a shortfall for cricket provision. It would be more appropriate for the adjacent land which is allocated for recreational and employment use in the plan to be used to meet the need for new pitches.
11. The application promises ’25 per cent affordable housing’ but since the development is outside the BUAB, 66 per cent should be offered. Moreover ‘affordable’ houses for sale are often out of reach of local people, and the main need is for social housing for rent near the centre of the town, for families priced out of by second-homeowners and holiday rentals. As the meeting on 21st February was reminded, at the Tesco site in Seaton, a promise of 40 per cent ‘affordable housing’ was reduced to 25 per cent and then to 0 per cent. The Council should not trade Seaton’s environment for such unreliable promises.

The applicants argue that while the proposal is outside existing planning policies, these are “out of date” because the Council can only demonstrate 4.68 years’ “housing supply” when the requirement is for 5 years’. Yet this is a minor projected shortfall and major harm to the local environment should not be perpetrated on this basis. As the Planning Appeal Inspector put it in 2015, when rejecting an appeal against a previous refusal for this site, “although EDDC’s housing shortfall was significant it was arguable relatively short term whereas the erosion of separation between Colyford and Seaton would be permanent and should not be acceded to lightly.”

In fact the applicants’ reliance on housing supply policies, which have led, as Cllr Arnott has put it, to “inflated housing need numbers” in East Devon, itself appears to be out of date. The Secretary of State for Levelling Up, Housing and Communities announced on 6 December 2022 that he was considering abolishing the obligation for local authorities to maintain a rolling five-year housing land supply where local plans are considered up-to-date. 

The applicants also argue that the existing Local Plan policies should be set aside because part of the site is provisionally allocated for housing in the emerging Local Plan 2020-2040 on which the Council has recently consulted. However the land allocations in this draft of the Plan have been included only to satisfy the outdated five-year housing land supply requirement. In this case, moreover, the Planning Committee cannot rely on the provisional allocation because it does not have the support of the local community, as the recent meeting convincingly demonstrated.

Since the government has recently indicated that housing need target policy will be modified, the Council’s Strategic Planning Committee has rightly resolved that no further discussions on potential sites take place until the Government makes its decision. In this situation, it would obviously be completely inappropriate for the Council to approve the present application.

Very similar applications have been rejected by EDDC after large-scale opposition from local residents, and the Council’s decisions have been upheld on appeal. People in the Seaton and Colyford area trust that EDDC will protect the Wetlands and the Green Wedge against this new proposal.