Castle Point draft New local Plan, another change of direction under new Leadership?

You can fool all the people some of the time, and some of the people all the time, but you cannot fool all the people all the time.” – Abraham Lincoln

Following the General and local Elections how are the changes expected to impact Castle Point, its Local Plan and Green Belt?

We learn of a new Secretary of State at The Department for Communities and Local Government, a politician with a Planning background.

Locally we learn, through the Echo, that the CPBC Deputy Leader of the Council, cllr Sharp is to be replaced by the lead Group of councillors in favour of the previous incumbent, cllr Stanley.

Cllr Sharp, a “radical” politician had, through his work on the Local Plan, explored ways to protect more “sensitive” Green Belt sites in parts of the Borough, chiefly by utilising the degrees of virginity, or levels of previous  development, of areas of Green Belt in a form of weighting process.

This, alongside the NPPF Guidance, had raised expectations amongst residents that GB sites that campaign groups were most concerned about may be protected from development.

Cllr Sharp’s replacement is expected to be cllr Stanley, formerly in charge of the Borough’s finances.

This return to the “old guard” coincides with a conversation I had with a senior Lead group councillor on Election day in which it was suggested to me that the Green Belt sites “suggested” as deliverable for housing development within the draft, New Local Plan consultation document remain the sensible and likely options.

How long, post Election, will Green Belt campaigners wait to hear from councillors the reassuring phrase, “the Local Plan is only a draft voted to be sent for Consultation, it is not Approved”? Previously covered HERE.

Friends, we must be realistic, there are two Green Belt development Appeals scheduled for this Autumn.

Following the Glebelands Appeal it was considered;

Mr Justice Blake then goes on to say:..

“However, I would add this observation. The justification for building much needed housing on this GB strip is narrowly balanced. If the Secretary of State’s optimism proves unjustified and other GB or open land is not released for housing development by a new Local Plan, the balance may tip in favour of this development on future consideration. In the absence of concerted effort and effective progress, the outcome of the present process may prove to be more of a temporary reprieve than a durable future for the appeal site.

Mr Alun Aylesbury, the advocate who presented the (Castle Point) Council’s case at the original inquiry has been asked for his view on the judgment. His initial opinion is that there is an expectation that the Council will get on and deliver its New Local Plan.”

We are concerned for resident campaigners at Glebelands and Jotmans as the time remaining pre Appeals leaves little time for Council business. The obvious Appeal defence would be to ditch the Blinking Owl H18 option so that CPBC defence counsel may claim that much progress has been achieved with the Local Plan.

For this to be substantiated, considering that the efforts to progress the H18 option as the alternative to those sites listed within the draft new local Plan has been recorded on webcast, would be for the Council to progress the Local Plan in its current format.

Where would this leave the other sites listed as proposed Housing development within the document?

Where does this all leave the Canvey Island Green Belt sites given the previous Council preferences?

Following the withdrawal of the Core Strategy (CS) a councillors conference was held in September 2011. The intention of the meeting was to address the Core Strategy Inspector’s concerns on the housing distribution across the Borough.

A briefing paper was issued to councillors in which it was explained:

“The paper explains that the area of greatest concern for the Planning Inspector is the absence of suitable housing land; it then provides information regarding sites presently in the Green Belt but which could be allocated for housing purposes, which would be likely to address the Planning Inspector’s points.”

“He (the Inspector) also indicated that he was dissatisfied with the distribution of greenfield development between Canvey Island and the mainland towns. He indicated that the Council should review their assessment of sites in Green Belt locations in the mainland part of the Castle Point and identify land for 2.5 years worth of supply (around 500 homes) for the first five years of the plan, and a further 2.5 years worth of supply for years 6 to 15 (around 500 homes). He also indicated that the Council should give further consideration to identifying safeguarded land, to meet housing land requirements beyond the end of the plan period.”

“The primary focus of the work carried out over the summer of 2011 has been sites on the mainland. This was as a result of the Planning Inspector’s letter of the 11th May 2011. To this end, the sites on Canvey Island have not been the subject of this review, and no additional Green Belt sites have been identified for consideration on Canvey Island.”

So in effect the Green Belt sites on Canvey Island that previously were allotted for development remained in the new Local Plan whilst other sites off the Island were considered.

The preferred Local Plan development sites indicated always were, and remain on Canvey Island.

Making a total nonsense of the Sequential Test that “should” be applied Borough-wide in the case of areas within a Flood Zone!

It appears that consultation where Castle Point Council is concerned remains limited!

Should this scenario turn out to be the case, whatever the motive for progressing the Blinking Owl option to develop may have served a purpose, but has been hampered by, yet again, “Local Factors.”

Let us hope our fears are truly unfounded!

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2 responses to “Castle Point draft New local Plan, another change of direction under new Leadership?

  1. Steve Sawkins

    Editor:- It may be helpful to revisit the NPPF Guidance on flood risk, it will be for CPBC planning officers to explain, at the examination of the NLP, why they have decided to employ their own particular approach to flood risk constraint.

    Guidance Applying the Sequential Test in the preparation of a Local Plan

    What is the aim of the Sequential Test for the location of development?

    The Sequential Test ensures that a sequential approach is followed to steer new development to areas with the lowest probability of flooding. The flood zones as refined in the Strategic Flood Risk Assessment for the area provide the basis for applying the Test. The aim is to steer new development to Flood Zone 1 (areas with a low probability of river or sea flooding).
    Where lower flood risk may not be suitable for development for various reasons and therefore out of consideration, the Sequential Test should be applied to the whole local planning authority area to increase the possibilities of accommodating development which is not exposed to flood risk.

    More than one local planning authority may jointly review development options over a wider area where this could potentially broaden the scope for opportunities to render a range of options in the site allocation process, using the Strategic Flood Risk Assessment to apply the Sequential Test and the Exception Test where necessary. This can be undertaken directly or, ideally, as part of the sustainability appraisal.

    Where other sustainability criteria outweigh flood risk issues, the decision making process should be transparent with reasoned justifications for any decision to allocate land in areas at high flood risk (Flood Zones 2 and 3) and other areas affected by other sources of flooding where possible. Application of the sequential approach in the plan-making process, in particular application of the Sequential Test, will help ensure that development can be safely and sustainably delivered and developers do not waste their time promoting proposals which are inappropriate on flood risk grounds.

  2. Steve Sawkins

    It has been suggested that we all work together towards a sustainable NLP however we need to remember why we have stagnated to the position that we now find ourselves in.

    In responding to the Planning Inspector’s letter of the 11th May 2011, there were two options available to the Council.

    1) Consider the evidence presented in relation to suggested sites. This will
    require the identification of suitable Green Belt land in sustainable locations in Benfleet, Hadleigh and Thundersley to ensure that there is a sufficient supply of development sites for years 1 to 5, and a sufficient supply of sites that are likely to be developable in years 6 to 15. Additionally, the Council should consider safeguarding land for future housing need. If this option is pursued, the examination could continue, and there is a reasonable likelihood of receiving report identifying the Core Strategy as sound in the Spring of 2012.

    2) Withdraw the Core Strategy. The examination so far has cost approximately £90,000. This money would be lost, and there would need to be a substantial investment in refreshing background studies, undertaking further consultation and preparing new policy documents. During this period the Council would not have an up to date development plan, and would be open to the presumption in favour of sustainable development set out in the draft NPPF.
    There is no middle option, as the Planning Inspector’s letter is clear. Failing to follow either of these options would result in either the Core Strategy being found unsound, or the Council having no up-to-date plan in place.

    If only the Councils Planning Officers had taken up the Planning Inspectors generous offer of assistance to achieve option (1) we would have found ourselves in a much better place.
    Option 2 was the subsequent choice, it being unpalatable to have to consider other Green Belt sites is understandable, but to then take the action of actively searching for and identifying sites, including green belt, that could be developed was a fundamental error.

    The authority is running out of time, its reliance upon out of date evidence based documents and disregard of the less favourable consultants responses will be its undoing when the NLP is examined. Unsound, unsustainable site selection will not protect preferred sites but merely only puts the most valued sites at further risk.

    What could possibly go wrong.

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