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.
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!