Build on Green Belt, Sequentially you wouldn’t do it – Unless you are in Castle Point of course!

Housing and the supply of, in Castle Point is an ongoing contentious issue, the new Local Plan seeks to address this. Factors influencing the issue range from the objectively assessed need for housing, governed by demographic assessments, the factor that Castle Point is tightly constrained by Green Belt, the road and health service infrastructure and to a lesser degree the flood risk and hazardous industrial sites of Canvey Island. Some point to the historic levels of housing delivery as being a relevant factor, which may have some bearing as County have allocated no money for highway improvements specifically to support housing growth in the Borough.

In support of the Plan the local authority have published a document titled “New Local Plan Sequential and Exception tests for Housing Site Options” dated November 2013.

“This document sets out the sequential and exception tests for those sites that have been promoted to the Council for inclusion in the New Local Plan as housing sites. The National Planning Policy Framework (NPPF) requires local planning authorities to take account of the risk of flooding when preparing their local plans. The NPPF sets out a sequential, risk based approach to the location of development to avoid where possible flood risk to people and property, and to mange any residual risk. It is expected that the impacts of climate change are taken into account when considering flood risk, as properties built now are expected to last at least 100 years.”

“In order to direct development, where possible, away from areas at highest risk of flooding, the NPPF requires local planning authorities to carry out a ‘sequential test’ when preparing their local plans.”

The relevance of this process in relation to Canvey Island is four fold.

July 2014photo3

The Strategic Flood Risk Assessment indicates that Canvey is recognised as being at Actual Risk of Flooding from both over topping of the sea defence and from the residual risk in the event of the defence being breached.

The Environment Agency have highlighted the highly complex nature of the Island’s drainage system. This was the major aspect emerging from the investigations by Essex county Council and the Government Office of Science following the surface water flooding during 2013 and 2014. We still await the findings of the Castle Point Scrutiny Committee.

Lastly the local authority have, in response to criticism of inadequacies from the Planning Inspectorate, identified vast areas of land they consider either deliverable or developable during the Plan period outside of the Flood Zone.

Castle Point Council have identified land that could provide in the region of 3,400 dwellings discounting the long debated Town Centre Regeneration areas potentially provision of up to 300 dwellings.

This also discounts the potential provision of 1,000+ dwellings at the H18 site known as the Blinking Owl or North Thundersley extension.

The CPBC New Local Plan Sequential and Exception Tests document also identifies the approved proposal to develop 606 dwellings at Thorney Bay with a potential of a further 106 dwellings. There is also 99 dwellings proposed at The Point on Canvey.

These large Canvey sites are in addition to what is intended for the Dutch Village fields, East of Canvey Road, the old Castle View School site and the Industrial proposal off of Roscommon Way!

With this in mind it would take some explaining as to why the Green Belt sites on Canvey Island are so consistently promoted as being necessary to develop for either Housing or Industrial use within the local Plan!

The single factor that the local authority attempt to use to support this policy of development growth distribution is through the Exception Test’s element:

“Firstly, they must demonstrate that the development would provide wider sustainability benefits to the community that outweigh flood risk.”

Given the blight inflicted on residents following the surface water flooding of 2013 and 2014 and the potential of flooding from the sea, Canvey is now in a period of economic uncertainty. Uncertainty that insurance will be available to new houses built since 2009, this in turn may reflect upon the ability to secure mortgages and uncertainty what the Integrated Urban Drainage study may discover.

Canvey Town Centre regeneration and a huge amount of investment into the drainage system, in support of the current levels of residency, must be sought prior to looking beyond the urban area to release sites.

In their considerations, the Local Plan Task and Finish group should remember that, Green Belt is Green Belt, wherever it is situated, and that the Council seek to “maintain or reduce the number of residents living at Risk of Flooding.”

With the identification and promotion of the Blinking Owl site, dependent on local residents’ reaction, and the ability to provide the necessary infrastructure, it must be made clear whether this site is in addition to the sites already identified, or instead of.

The attempts being made by the local authority councillors to protect the Borough’s Green Belt is admirable however, they must take care in the relegation of some areas as being of less value ie contains some development, as these same areas may provide more of the function of the Green Belt purpose!

I would suggest that sites providing access to the public provide more value and are entitled to equal protection and consideration.


Either way the continued inclusion of the Canvey Green Belt sites for Housing and Industrial use is very poorly evidenced and accordingly indicates that “Local Factors” remain as the influence behind the local authority’s judgement!


4 responses to “Build on Green Belt, Sequentially you wouldn’t do it – Unless you are in Castle Point of course!

  1. The following extract from the Communities and Local Governments Planning Policy Statement 3 (PPS 3) :- Housing
    Would indicate that the New Local Plan housing strategy would be difficult to be accepted as being found sound by the Planning Inspectorate

    “Planning for housing policy objectives
    10. These housing policy objectives provide the context for planning for housing through development plans and planning decisions. The specific outcomes that the planning system should deliver are:-

    High quality housing that is well-designed and built to a high standard.
    – A mix of housing, both market and affordable, particularly in terms of tenure and price, to support a wide variety of households in all areas, both urban and rural.
    – A sufficient quantity of housing taking into account need and demand and seeking to improve choice.
    – Housing developments in suitable locations, which offer a good range of community facilities and with good access to jobs, key services and infrastructure.
    – A flexible, responsive supply of land – managed in a way that makes efficient and effective use of land, including re-use of previously-developed land, where appropriate.
    11. PPS3 sets out policies designed to achieve these outcomes, based upon the following concepts and principles:–

    Sustainable Development – PPS1 sets out the strategic role of planning in delivering sustainable development. Sustainability Appraisal is a key means of ensuring housing policies help to deliver sustainable development objectives, in particular, seeking to minimise environmental impact, taking account of climate change and flood risk.”

    Flood risk issues on Canvey Island should cause further large scale development to be questioned on the basis of the sustainability aspect of planning principles. Indeed the councils own scoping documents identified that the population of Canvey Island should not be increased and where possible remain the same, the idea being one would suggest, is that there are already a huge number of its population at risk of flooding events and to allow further development to increase this number would be irresponsible.

  2. I have been asked whether there is any Grade 1/2 land involved (Best & Most Versatile) as my contact over in Bristol has been enquiring.

    It’s all happening in Bristol at the moment, see

    • Afraid not Carole. Chiefly grazing land at best so probably down around the 4 -5.
      However this site is very close to the nearby SSSI site and RSPB reserve. Important for endangered habitat and vegetation. Developer surveys have been criticised and the EA have a holding objection. Canvey is a flat and low land, at or below sea level. It is imperative that the intention to “land raise” this and other new large development sites is not allowed.

  3. STW. Sorry STW your comment can’t be approved. Incorrect info, TB is part of a Flood Risk 3a area and any comment regarding irregular payments must be supported by proven evidence. Ed

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