Liatris: Round One to Stand Up for Seaton!!!!!
Below is the text of a letter sent by Ms K Little, Head of Planning, EDDC to Mr Simon Chadwick who acts on behalf of Liatris. This letter is in the public domain and is printed in its entirety - read the red bits for highlights only.
I have been asked to make it clear that this was posted in my PRIVATE capacity and NOT in any other role. I am happy to do this. Also, it must be made clear that the "victory" is not that Liatris will NOT put forward their planning application to the EDDC Development Control Committee (they may well choose to do so, this is their right) and Kate Little's press release makes this clear. It is that others have now come to the same conclusions as those espoused by SU4S from the beginning - more (natural) water, less infill, community facilities, tourism opportunities, etc.
I do hope that this makes it clear that I am NOT speaking on behalf of any particular entity (not even SU4S) but only for myself in my private capacity.
The reference to "6f4 infill" is a special type of infill that is used for roads, etc and which the supermarket wants as its foundation - this fill has to be imported by road.
What can I say? To the HUNDREDS of people who made it possible for us to get this far - THOUSANDS of thanks. It is only winning a battle, not the war - but we here for the long haul:
24 July 2007
Dear Mr Chadwick
Re-development of land to include housing, retail, petrol filling station, leisure/tourist development with access and open space: Land adjoining
I refer to the above outline planning application and in particular our meeting on 12 July 2007 to discuss, amongst other things, the issue of fill and the raising of ground levels following the workshop arranged by this Council.
As you are fully aware, the reduction of fill is a key issue to the success of the scheme, not only to reduce traffic movements but also to produce a development that integrates better with this part of Seaton, particularly around the boundaries of the site. We are all agreed that the current proposals for the amount of fill are unacceptable and are unlikely to get support, especially from the Seaton community. The starting point for this Council is to fully support and encourage the regeneration of this part of Seaton, but it needs to be practical and have the support of the general community.
The aim of the workshop was to explore ways of making significant reductions in the amount of fill material needed whilst recognising that the Environment Agency (EA) requirement is to protect people and property from flooding. It is recognised that some fill will need to be brought onto the site, but that this should be reduced to a minimum subject, of course, to financial constraints. However, part of the concern with the current level of fill proposed is the cost and the implications this would have for providing community benefits and the requirements of policy for such aspects as affordable housing, open space, etc. Whilst I appreciate you understand the need to reduce fill, I got the distinct impression that you consider this would only be by a small amount (up to 10% maximum) and that few changes would be required to the planning application, notably the submitted ‘indicative master plan’ and the ‘land areas plan’. Indeed, you considered the current application could be amended whereas we expressed the view that to withdraw and a re-submission would be preferable.
The purpose of this letter is to re-iterate our view that significant reductions should be made in the amount of fill used, particularly being brought in by road, and that any planning application (whether outline or full) should provide adequate details of how this is going to be achieved. There is not one simple answer to this issue, rather it should be a range of firm proposals from you for identifying the minimum amount of fill, sourcing it from a more local and sustainable location (hopefully from the Seaton Marshes) and providing details of layout and design (including buildings). I think we have to accept that parts of site will flood on occasions, but plan for this in a more creative manner whilst providing adequate protection for people and property as required by the E.A. Otherwise, I fear that in 6 months’ time we would not have moved forward and community support will not have improved.
To adequately address the above concerns, and to do justice to the workshop, I consider that in addition to the other outstanding issues, any new submission must include a ‘Fill reduction strategy’ (FRS) document made up of a report with accompanying plans to form part of the application. This should, of course, make reference to the E.A. requirements. I would suggest it covers the following points, but you may wish to add or modify:-
Amount of fill
You have an existing site survey showing existing levels and you are aware of the E. A. required floor levels. It is accepted that habitable floor levels should be at this level but it was also clear from the workshop that other parts of the site need not be raised to this level such as gardens, open space, supermarket car park etc. The FRS needs to identify (including spatial layout information) detail of the proposed levels for the different land uses. Whilst this cannot at this stage indicate the level of every square meter of the site, it should nevertheless include the range of various levels over the site for the land uses with reference to a more detailed layout.
Source and type of fill
Further investigation is needed on the quality/amount of fill that can be obtained from the Seaton Marsh (and possibly on site) together with resolving legal issues and transport to the site. The quality/amount should be included in the FRS and what areas/uses this would be put to.
The amount of 6F4 needed for the site identified together with the source and transport to the site. 6F4 should only be used where absolutely necessary and full justification is provided.
Full assessment of other means to transport fill to the site. Issues should include cost, sustainability, environmental, health/amenity of Seaton/Axmouth residents.
Develop more compactly
This applies more to the residential element but the aim should be to develop more densely/intensively to allow more open spaces at lower ground levels. You submitted with the ‘Design and Access Statement’ a ‘Density Plan’ but this is extremely crude. This is a starting point but must be refined to identify:
1. Specific ranges of density e.g. 30 – 35 dph, 35 – 40 dph etc.
2. reference of the ranges to a spatial layout. This will require more detail than the basic land use block shown in your ‘Land Areas Plan’.
3. Through the use of ‘density ranges’, identify the lower and upper level of residential units.
Develop less of the site and use more landscaping and open space
This is related to the above. The aim is to provide more undeveloped space at a lower level for landscaping/POS and/or as water features/flood relief areas. This should not be as ‘engineered’ as your proposed flood relief channel but appear more natural. These areas should be shown in a layout/masterplan.
Focus fill material on strategic routes across the site
The aim is to raise ground levels along strategic routes so that they do not flood. This suggests some secondary routes could flood and will need agreement with the E.A. and Highway Authority. If agreement is reached, the strategic routes will need to be identified on a layout/master plan.
Voids under buildings
Identify which type of buildings they would be appropriate for; provide details/estimates of the volume of these voids for typical buildings to calculate volume of fill saved.
Design flood resilient buildings
Flood resilient buildings can be used provided the E. A. is confident that life is protected and the building can quickly be returned to use after the flood. Possible buildings suitable for flood resilience should be identified with their agreed floor levels with details to form part of a design code.
I trust the above comments will provide some guidance on the type of measures we feel are necessary to substantially reduce the fill and also allow everyone in the planning process to understand and control this issue at the outline stage.
You will be aware that the changes to the requirements for outline planning applications which came into force on
It is no longer appropriate to have a generalised DAS. They need to provide more detail and provide plentiful and accurate information for a clear understanding of the 3-dimensional form. I appreciate you have provided a limited number of cross sections, but these now need to be more comprehensive especially now the Council requires significantly more information on levels as part of the fill reduction exercise. Cross sections must be clear and accurate (scaled) and should extend across the whole site both north-south and east-west.
It is also clear that the masterplan needs to provide more detail and precision, again partly as a result of the information required as part of the fill reduction exercise.
It is not the purpose of this letter to be overly prescriptive as to the additional information the Council would require, but we would expect you to follow the new requirements and incorporate the information contained in Circular 01/2006 together with the recent Secretary of State decision in
The result of all this is that we consider you should withdraw the current application and resubmit once you have more comprehensive detail and have addressed the Council’s requirement to make significant reductions in fill and have investigated fully the alternative sourcing. The Council is not prepared to consider ‘tinkering’ with the current application and feel we are fully justified in requesting a more radical approach to this fill issue and requiring more comprehensive information and detail.
We also addressed the question of appropriate land uses on the site and we urged you to consider providing holiday/leisure uses. We hope that you will be able to come back with something positive on this. You will be aware how important this is to the Town Council and others.
In terms of the Section 106 Agreement requirements, whilst we did not discuss this in detail, clearly the standard requirements of affordable housing, open space and education infrastructure will be important as well as the requirements of the PCT. Beyond this the requirements will be discussed with District Council Members to agree the priorities.
I look forward to receiving your comments on the issues raised in this letter.
Head of Planning & Countryside Services
Special one off commemoration toon.....;0)
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