SeaChange has finally put in the planning application for its proposed new development on the North Queensway ‘Innovation Park’. And whilst SeaChange is keen to sell it as a great model of sustainable development, the reality is a little different. We need you to object, now, in order to stop this damaging new project. Scroll to the bottom to find out how.
‘Significant risk’ to SSSI
In November 2020, SeaChange put in an application to HBC for a scoping test in regard to North Queensway. A scoping test is a request for the planning authority to provide the applicant with information about what needs to be included in the Environmental Impact Assessment for the application.
As part of this process, HBC was required to contact Natural England about their views. And what Natural England said was potentially very bad news for SeaChange. In its response to HBC, Natural England says:
Natural England has considerable concerns regarding this application. We have provided substantive advice in numerous applications regarding the complex hydrogeological impact pathways that exist between the Queensway North site and the adjacent Marline Valley Woods Site of Special Scientific Interest (SSSI). The interest features of the SSSI include bryophytes which rely on the continuation of the existing hydrological regime (the quality and quantity of water flowing from the application site to the SSSI). The development of Queensway North is a significant risk to the SSSI’s interest features as the developments disrupt the hydrological regime by removing and altering existing permeable areas and introducing pollution risks. [emphasis added]
‘Development plot…should be omitted’
And as if that weren’t bad enough, the letter goes on to say:
In addition to advising on the impact of developing Queensway North to the SSSI we have consistently highlighted that the area covered by Development Plot 2.1 should be omitted from development as this is closest to the SSSI and contains permeable sandstone outcrops taking water directly to the SSSI. [emphasis added]
SeaChange has ignored Natural England’s concerns, and its application includes plans for three large units and 57 parking spaces in the north west plot. This alone should be enough to have the planning application rejected, because of the risk to Marline Valley nature reserve and SSSI.
SeaChange will claim that the site has long been allocated by Hastings Borough Council as an ’employment area’. This is true, but in HBC’s own scoping opinion (p3) for the planning application, the council states that:
The concerns raised by Natural England in respect of the development of Plot 2.1 should be noted. Whilst the entire site is allocated for employment purposes within the current Adopted Local Plan; this does not override the concerns of Natural England [emphasis added].
SeaChange claims in its business case for the project (p21) that leaving out plot 2.1 would ‘significantly diminish the returns to [SeaChange Sussex] that it expects from its investment’ and so ‘a reduced project option has been discounted’. Or to put it another way, it’s reasonable to put Marline Valley SSSI at risk in order to maximise SeaChange’s profits.
Contravention of planning policies
The proposal is potentially in contravention of planning policy EN5 (p70) of the Hastings Planning Strategy 2011-2028 (local nature reserves) which states that nature reserves should be preserved and protected, and developments affecting nature reserves will only be allowed if the need outweighs the importance of the site for nature conservation. It is hard to see how that could be the case.
In addition, policy DM6 (pollution and hazards) states that planning permission will only be granted for development providing ‘appropriate pollution control measures are incorporated where necessary to protect the quality of both ground and surface waters’. Clearly, Natural England thinks that there are no possible controls which could fully protect the SSSI, which is why it has said that development in plot 2.1 should be avoided.
Most of this application is speculative development. It includes the long-awaited car showroom for the business which is being forced to move to build the Queensway Gateway road, as well as 450m2 of ‘bespoke space for a local employer’. The remaining 4000m2 of space is speculative – SeaChange’s ‘build it and they will come’ philosophy.
SeaChange has included an ‘industrial supply and demand’ document as part of the application which claims that there is great demand for these types of unit, but Hastings Borough Council has not commissioned any independent survey of demand. In addition, there is no analysis of whether the demand for business space has been affected by covid.
It should be remembered that when the North Queensway site was first proposed as a ‘build it yourself’ site, SeaChange claimed that local businesses would flock to it, creating 700 jobs (p7). That was nearly nine years ago, and not a single brick has been laid nor a single job created. This current plan – build it and they will come – smells like a last desperate attempt to get more money (another £3.5m) out of the South East Local Enterprise Partnership to market what is perhaps unmarketable.
Loss of biodiversity
The ecology report for the site notes (p27) that the development will cause a 25% reduction in biodiversity on the site and gives no indication how that will be compensated for. This is in contravention of HBC policy HN8 – development should result in no net loss of biodiversity. In addition, in its scoping opinion for the site (p3), HBC states that:
The submitted scoping report does not include any Net Biodiversity Gain on the site. The net gains for biodiversity and the SSSI require to be clearly demonstrated to the satisfaction of Natural England and the Council and in line with Planning Policy and Legislation.
According to an objection to the proposal submitted by Energise Sussex Coast (ESS) – local experts in renewable power and energy saving – SeaChange’s sustainability statement ‘makes a number of misleading and inaccurate claims’. The most glaring of these, ESS says, ‘is the claim that gas heating is sustainable’.
In the sustainability statement, SeaChange’s consultants run through every type of renewable energy, dismissing them one by one, before deciding that gas boilers are the most sustainable way of heating the new units. ESS is unimpressed:
A statement like this at COP26* would make Hastings Council (and the UK’s zero-carbon commitment) a global laughing stock.
*COP26 is the UN’s annual climate summit, to be held this year in Glasgow.
‘Significant embarrassment to the council’
ESS makes a stinging attack on the SeaSpace (the precursor company to SeaChange, under the same director) ‘Enviro 21’ business park just a stone’s throw from North Queensway, pointing out the hollowness of SeaSpace’s claims to be creating a state-of-the-art ‘sustainable eco-technology park’. The reality was that the units were built in such a way that they could not house solar panels; the promised wind turbine was never built; the 500 green jobs did not materialise; and the overall energy efficiency rating of the park was D.
In conclusion, ESS says that:
If planning was granted and the [sustainability] statement made public, this would risk significant embarrassment to the council and its aim of becoming a pioneering low-carbon town.
Get there by car or not at all
The transport assessment for the site talks airily about sustainable transport. It claims that a ‘shared cycle footway on Queensway connects to the Hollington estate’, and that ‘residential speeds, wide roads and topography in the area make cycling a viable form of transport to/from the site’.
It’s not clear what the ‘Hollington estate’ is – there is no estate with that name in Hastings. And as for a ‘shared cycle footway on Queensway’: there is in fact no footway whatsoever on Queensway apart from a couple of hundred metres between the North Queensway site and Enviro 21 to the south. Other than that, cyclists have to risk their lives on the extremely busy and fast-moving road, whilst pedestrians have to fight their way along overgrown verges and past overhanging trees. It is an extremely dangerous road for non-motorised users and to suggest otherwise is simply misleading.
Shops nearby: really?
The nearest bus stop is 1.1km away, and is accessed, according to the report ‘via the existing footpath on Queensway and Ingleside’. Unbeknown, apparently, to the writer of the report, there is in fact no footpath whatsoever on Ingleside and pedestrians are forced to walk in a busy winding road.
Likewise, the report says that ‘staff…will be able to access shopping, health and community facilities, and education facilities, all within 1.6km of the site’. As an example of the ‘shopping facilities’, it gives the huge Tesco on Church Wood Drive – again, accessed for pedestrians by taking their lives in their hands on Ingleside.
The planning application proposes 107 car parking spaces, and 15 bike parking spaces. There is no plan for making it easier for people to travel to the site by walking, cycling or public transport. Hastings Borough Council policies for the site (designated as ‘LRA6’) state that development proposals should be accompanied by a travel plan – there is no such plan in the application. The reality is that this is a development in a highly unsustainable location, and jobs will only be available to those who have cars to get there. As with the proposal to heat the units entirely with gas boilers, it does not fit well with Hastings Borough Council’s declaration that we are in a climate emergency.
The proposal also appears to be in breach of Hastings Borough Council’s policy DM4 which states that developments should be able to show that ‘public transport provision, pedestrian and cycle access are promoted and enhanced, and where appropriate, pedestrian and cycle routes are incorporated into and through sites to aid connectivity and safety’, and that ‘provision for non-car based modes of transport have been shown to be considered and included as appropriate in the development of the site’.
In fact, SeaChange has done nothing more than offer an extremely misleading statement of the ‘non-car based modes of transport’ that are already available. This is not a transport plan, and the development should not be granted permission unless it can be shown that provision will be made to not only encourage the use of cycling, walking and public transport, but also to make it safe and easy.
Please object now to this application. Closing date is currently 10 June, although this may be extended if the application has to go to the planning committee, so do object even if this date is past – but the sooner the better!
Email firstname.lastname@example.org with your objection. Please bcc email@example.com so we know how many people have objected. You need to include your name and address (your address will not be published by the council). Or you can comment directly online – see here for how to do this. The planning application number is HS/FA/21/00327.
You can write your own objection (see here for more information) or can copy and paste ours. Either way, the important thing is that you do it!
I wish to object to planning application HS/FA/21/00327 (business park at North Queensway).
My reasons for objection are:
1. Natural England made it very clear in a letter dated 28 Jan 2021 (https://bit.ly/3oD6Bl1) that development should be avoided in the northwest plot in order to protect Marline Woods SSSI from runoff and pollution. Despite this, SeaChange’s proposal includes three large units and 57 parking spaces in the northwest plot. This proposal poses a very real risk to a very delicate SSSI and is in contravention of Local Plan policy EN3: Nature conservation and improvement of biodiversity.
2. The majority of the development (plots 1.1 and 2.1) is speculative. The applicant has provided an assessment of demand for business space locally but Hastings Borough Council has undertaken no independent assessment. It should be noted that the Enviro 21 business park, a stone’s throw from the proposed site, remains significantly underdeveloped over a decade since it was built. In addition, the proposals take no account of the changing needs of local businesses post-covid.
3. The application takes no account of HBC’s climate change action plan. It is in a highly unsustainable location, on a busy road with no pavement to the north, and only a short stretch of pavement to the south, and no nearby public transport. Local Plan policy T4 requires a travel plan for a development of this size: no such plan has been submitted.
4. The ecology report for the site notes that the development will cause a 25% reduction in biodiversity on the site and gives no indication how that will be compensated for. This is in contravention of HBC policy HN8 – development should result in no net loss of biodiversity.