Flood Zone and Green Belt, constraints on development? A Lesson in Technocracy for Task + Finish members!

The Castle Point draft Local Plan Task and Finish group meeting was held last evening on the topic of Housing Development constraints.

I was going to say to “consider” the constraints, but that appeared to be off agenda.

Last evening appeared to be the moment technocracy took over the democratic process.

In the public area I counted, what appeared to be, just 8 residents plus 1 developer. In the chamber were 5 of the committee members, and at the head table was a chairman with a team of officers united on the same agenda.

The purpose of the meeting was to EXPLAIN the constraints and how they had been applied to the draft Local Plan, rather than to debate and consider what the constraining total of new housing development is considered to be by our elected representatives, the Committee Members.

The Castle Point Objectively Assessed Housing Needs figure is between 310 and 320 dwellings per annum.
The Constrained housing figure is 200 dwellings per annum.

Constraints come in two forms, policy and physical.
It was explained for those who needed to know, that flood risk is, or should be, a physical constraint whilst Green Belt is a policy constraint.
The weighting of how the two categories of constraint are to be applied, was not defined.

An officer did explain that surface water flooding, such as that experienced on Canvey Island and other parts of the mainland during July, should not be considered a constraint!
The agencies responsible for maintaining the Canvey drainage network are expected to keep the drainage capacity in an efficient state so that flooding does not occur and housing development will continue.

The fact that our local planning authority has, and continue to, overload the drainage system with housing development, appears an irrelevance!

The fact that new development will not be guaranteed, or be covered within the FloodRE insurance scheme also, appears an irrelevance!

The fact that the contributing sources to the flooding have yet to be identified, likewise the extent of the problems, and the yet to be secured necessary funding to limit future flooding also, appears an irrelevance!

Whilst it may be the case that house insurance is not a reason for refusal of an individual planning application, surely Local Plan consideration stage is exactly the right time to apply some caution to developing in areas where the future ability to secure house insurance, and therefore mortgage insurance, casts doubt on the sustainability of such development.

One announcement, regarding the first 5 years housing supply, from an officer should ring some alarm bells.
Currently the 5 year housing supply is considered to be limited to just 1.7 years worth of housing.
Which sites will be added to the housing supply to make up for the missing 3.3 years worth?
These sites were not identified.

The officer announced that the first 5 year supply would be set at 200 dwellings per annum. The following years supply would adjust upwards to release sites to meet a 320 dwellings per annum figure.

No mention of the extra 20% worth of housing buffer, or the previous housing delivery shortfall that is generally expected to be recovered within the first 5 years of the Local Plan.

As I understand it, unless the first 5 year supply total identifies a realistic and achievable housing need, the Local Plan will fail.

At long last Master Planning was finally put out with the dish-water.
This policy attempted to sell large-scale Green Belt housing development to mainlanders and suggested that housing development would be low density with large green amenity areas.
Last night the proposal was that rather than sites being developed at the rate of 30 Dwellings per Hectare (dph), the density should be increased to 40 or even 50 (dph)!

In context, the proposal at 101 The Point, Canvey Island proposed a density of 52.9 dwellings per hectare (mainly flatted).

The Thorney Bay proposal is difficult to give as an accurate example, it considers there are 20 hectares of developable land at an average rate of 37.5 dwellings per hectare. The remainder of the site continuing as a residential caravan park.

On the mainland, proposals have been received since the “Master Planning” initiative was proposed by the Cabinet member and Task and Finish group chairman.

Glebelands proposed to deliver 140 dwellings at the rate of 18.7 dph.

The Jotmans proposal indicated 265 dwellings at the rate of 30.8 dph.

The Felstead / Bowers Road proposal indicated 178 dwellings at the rate of 20.5 dph.

Clearly if Canvey Island densities are to be imposed onto these mainland sites it would cause some very serious concerns.

Previously the Task and Finish chairman, during the meeting with the Canvey resident group under the old Council regime, displayed the skills of a “second hand” car dealer, attempting to “sell” us the Master Planning policy.


It is clear that lower housing densities mean that more Green Belt sites overall would be required for release.

And, there would also be less opportunity to realise a supply of affordable homes.

Throughout the meeting the Local Plan’s policy for the unsubstantiated possibility of new road infrastructure was maintained by officers.
Funding is not in place.

The Duty to Co-operate was touched upon.
It was clear that little or no work had been carried out up to this stage.
A request by a committee member was made that approaches should be made to local Councils to enquire whether they may take some of our housing need.
Evidence of these approaches should be identified and evidence in any case within Local Plan work.

Officers were adamant that Green Belt will be released in Castle Point to meet the housing need.
They implied that the Government are wrong to suggest that this need not happen for the Local Plan to be found “sound.”



Officers suggesting that the “reduced” initial 5 years housing supply, increasing in the following years, is a realistic way of satisfying demand will also likely be an unsound result.

By suggesting that 200 dwellings per annum is a realistic early rate of supply, will also create the opportunity for Canvey Island development sites to be required earlier than expected to overcome an invented shortfall.

A means of overcoming the Sequential Test for land at Risk of Flooding.

The draft Local Plan may have been written by officers however by the councillors voting to release it for consultation may well have started a process that prevents it’s alteration.

This may well explain the apathy displayed towards the local authority’s consultation processes.

An examining Planning Inspector will simply consider that if the Local Plan proposes to release Green Belt and Flood Risk land for housing development, then that is the Local Choice!
It is not an Inspector’s job to allocate and distribute housing sites and land.

We have been warned.

This particular Blog post is not intended to be read as statement of fact, simply observations and thoughts of the writer.


7 responses to “Flood Zone and Green Belt, constraints on development? A Lesson in Technocracy for Task + Finish members!

  1. This is a very accurate summary of what took place at the meeting last night

  2. Agenda Item No.7(C) presented to the Cabinet on the 15th October 2014 was the subject of a Government Consultation- Delivering Sustainable Drainage Systems.
    The proposals to be considered will have significant implications for planning and infrastructure delivery along with the sustainability of communities within Castle Point. In essence the consultation document is suggesting an alternative approach to the provision for the delivery and long term maintenance of Sustainable Drainage Systems (known as SuDS )
    The new approach will inevitably impose new responsibilities and duties upon Local Planning Authorities and have the effect that SuDS will become a material planning consideration in the determination of any proposal. The Consultation goes on to suggest that expert advice should be available to local planning authorities to assist them in dealing with these new responsibilities and duties. It suggest that advise could be provided independently from other public bodies and that Planning Guidance would also be amended to make clear that certain public bodies must be consulted on relevant planning applications.
    The recommendation from the reporting officer was that the Cabinet agreed to submit a response to the Governments Consultation Document. Its response sets out the implication for Castle Point Borough Council detailing how it will impact on the ability of the Council to achieve its objectives set out under the priority of Transforming our Community
    It is not unreasonable to conclude that the Planning Officers stance of continued development in an area subjected to surface water flooding, whilst it is not at this moment in time the Planning Authorities responsibility for surface water management that it remains acceptable to continue to do so. However if, as it is suggested within this consultation process, that local planning authorities will have responsibilities, it is no wonder that the alarm bells would ring causing the Cabinet to agree to the proposed submitted response.

  3. My understanding is that the Draft Local Plan is just that a “Draft” and therefore open to changes and it was agreed only to send out a consultation on the Draft Local Plan and was no way a sign of adoption of said Draft Local Plan.
    The draft Local Plan was an officers Local Plan .

  4. Thanks Simon,
    I also believe the draft was an officers plan but written with input from the “old” regime at CPBC.
    However the Plan appears to have developed its own inertia.
    The point will inevitably come when the draft plan (councillors appear to have no influence on any revisions) is presented to full Council to be voted upon.
    The choice for Councillors will be clear, either go with a Plan, distasteful as it may be, or risk the planning proposals at Appeal coming forward to become part of the first 5 Year Housing Supply.
    There was an opportunity to have forced a situation in chamber last night to have brought a halt to the process.
    The risk to the 5 year supply may have been the same, but unless decisive action is taken soon then I fear it does not matter whose Plan it is.

  5. Sharon Ainsley (Knight)

    Just so you know, I was unable to attend as I was at another meeting of Greenbelt Groups and Residents Associations based along the Thames Gateway.
    I made sure we had a representative at the Council Offices and have watched the Webcast in its entirety, as have many other Residents.
    A point which should be made about the mainland, in particular Jotmans Farm, is that Development on this site (H14 apparently has no constraints
    according to Officers. They refuse to acknowledge that its categorized “At Risk of Flooding” ; Surface Water Flooding ; the fact that it has been in the past and is now Grazing Land and the function it fulfils as Greenbelt) will adversely affect Islanders as the weight of increased traffic on the A130 will be entering ahead of them on the “New Link Road” (Over my dead body)
    It is also along the periphery of the Borough, that the Officers suggested building in High Density, not Canvey Island.
    It’s time we stopped referring to ourselves as Islanders and Mainlanders and joined forces. That’s not new, I’ve been saying it from the get go. So how about it Castle Point. United we stand!

  6. Thanks Sharon,
    The densities quoted are taken from the application proposals, Design and Access documents.

  7. Well the more housing we build the more we will need you know…you probably
    do but ‘they’ don’t……….the more housing available the more folk will
    move here because it’s cheaper I would stop this at source…seems sensible
    Chris. Canvey

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