Green Belt CAN be saved, but certain Castle Point Councillors remain unconvinced?

A meeting was held between Castle Point MP Rebecca Harris and invited Green Belt campaign groups on Sunday morning.

It is apparent that some Lead Group councillors and cabinet members do not buy into the message that has been conveyed from Ministerial level, and the Planning Inspectorate, culminating in the announcement published in our previous Post, LINK.

Minister, Brandon Lewis, apparently gave the definitive message that Green Belt need not be used for housing supply if the Local Authority chose not to. As long as they actively pursue all previously developed and brown field sites, then along with other evidence a defence can be argued.

The crux of the potential to protect Green Belt relies heavily on the Planning Guidance available via this LINK.


The Guidance states that objectively assessed housing needs should be met, unless any adverse impacts of so doing would significantly and demonstrably outweigh the benefits. These adverse impacts include land designated as Green Belt and locations at Risk of Flooding.

Rebecca Harris, as do some councillors, appears convinced that this level of protection is sufficient constraint to protect Green Belt.

This would allow Castle Point to commence work on a new, New Draft Local Plan, if they so wished.

Locally assessed housing need does not have to be met, if there are limiting constraints to doing so.

Whilst there is no doubting the MP’s passion and commitment to this opportunity, the sceptic in me acknowledges that the Planning Guidance also points out that the National Planning Policy Framework must be;

“read as a whole.” “Need alone is not the only factor to be considered when drawing up a Local Plan.”

This suggests to me that “need” is a major factor, or at least an important factor.

The Guidance goes on;

“ The Framework makes clear that, once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.”

This is exactly the position we are currently at.

It is clear that our authority have to assess its full housing needs. Once assessed;

“the local planning authority should prepare a Strategic Housing Land Availability Assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing.”

It is here that cllr Dick’s stance becomes interesting. Whilst it will be argued that his reference to previous housing completions this century have only once achieved the Local Plan’s target of 200, the Planners do not usually take into account historic numbers as being permissible to assist evidence of future numbers. This however may be arguable as large developers are reluctant to saturate a local area with housing for sale, due to this having the effect of squeezing house prices. They would sooner release new builds at a rate that will maintain or achieve the benefit of price rises. Probably the previous 10 – 15 year housing completion rate would suit developers. Alternatively it would be apparent that if developers argued for 200+ as the housing figure, land banking may be their aim, get their sites allocated and release builds as and when it suits the Market. No way to form a Local Plan.

Local needs may be able to take into account;  “The overall number of births (UK) was down compared with the previous year, continuing a downward trend seen since a peak in mid-2012.” (BBC News 25 June 2015).

Migration is the single largest factor affecting housing need, it is difficult to see how Castle Point could argue we should be immune to this change, and yet that appears to be what is being suggested. Bear in mind that it is considered that much of the population at Thorney Bay is transient (newcomers to the area) and their displacement during development may mean re-homing.

During our meeting, much was said about the constraint that is Green Belt, interesting to note that Planners and the CPBC Development Committee give little weight to the Actual Flood Risk facing Canvey Island as a constraint despite this should be an actual constraint, rather than just a Policy constraint. Their zeal should be equally, if not more so, applied to allow for this constraint, otherwise they may be judged parochial!

View of Canvey Island flooding from Police Helicopter July 2014

View of Canvey Island flooding from Police Helicopter July 2014

Castle Point Council have adopted a laissez faire attitude where the difficulties facing future home owners accessing flood insurance is concerned!

Very interesting times, Castle Point Borough Council we await your next move!


5 responses to “Green Belt CAN be saved, but certain Castle Point Councillors remain unconvinced?

  1. I understand Castle Point can build around 1800 on Brownfield – excluding any Windfall Allowance the Council choose to make (none at present I believe).

    This is the minimum you must build.

    One could argue that ‘morally’ you should at the least address your local needs – and this comes to 520, at the most, over the 20 year Plan Period.

  2. The New Local Plan needs to consider the following.

    Technical Guidance to the National Planning Policy Framework
    Zone 3a – Flood risk high probability
    This zone comprises land assessed as having a 1 in 100 or greater annual probability of river flooding (>1%), or a 1 in 200 or greater annual probability of flooding from the sea (>0.5%) in any year.
    Appropriate uses
    The water-compatible and less vulnerable uses of land (table 2) are appropriate in this zone. The highly vulnerable uses should not be permitted in this zone.
    The more vulnerable uses and essential infrastructure should only be permitted in this zone if the Exception Test is passed. Essential infrastructure permitted in this zone should be designed and constructed to remain operational and safe for users in times of flood.
    Flood risk assessment requirements
    All development proposals in this zone should be accompanied by a flood risk assessment.
    Policy aims
    In this zone, developers and local authorities should seek opportunities to: – reduce the overall level of flood risk in the area through the layout and form of the development and the appropriate application of sustainable drainage systems;

    The whole of Canvey Island is a Zone 3a Flood Plain.

    The community of Canvey Island are not being unreasonable when it asks its Local Planning Authority to consider that, flooding is a natural process that plays an important role in shaping the natural environment. However, flooding threatens life and causes substantial damage to property. The effects of weather events on the natural environment, life and property can be increased in severity, both as a consequence of decisions about the location, design and nature of settlement and land use, and as a potential consequence of future climate change. Although flooding cannot be wholly prevented, its adverse impacts can be avoided or reduced through good planning and management, to plan to put more people at risk to flooding events as recently experienced on Canvey Island is at best questionable.

  3. Steve Sawkins


    The process undertaken by CPBC Hazardous Substance Authority of preventing major accidents involving hazardous substances and limiting their consequences, may not be being full considered as a constraint in the land use planning process presently being adopted by CPBC.

    What may not be being fully considered is that all new developments in and around the vicinity of the existing large scale Calor Gas LPG storage establishments may amount to the introduction of new occupants at an unacceptable level of risk from the consequences of a major accident.

    Such developments includes locations where concentrations of population are likely to arise such as transport links; locations frequented by the public; and residential areas.

    Clearly land use planning policies and plans, and the procedures for implementing them, should ensure that appropriate distances are maintained between establishments where hazardous substances are present, therefore this issue should be identified as material constraint.

    Appropriate consultation procedures should be established to implement the policies and ensure that independent technical advice on risks is available when decisions are taken.

    Public involvement is important and the public must be able to give its opinion on development around existing establishments, with the accumulation of existing developments within consultation distance being given the appropriate consideration to be able to assess the cumulative tolerability of risk.

  4. I believe that in the 60s there was a 1 mile no building allowed in force for Thames Road, Canvey Island, is that correct ? if so, when did that change?

  5. Steve Sawkins

    You may have been mindful of the statement made by Sir Bernard Braine MP. when campaigning on behalf of his constituents on Canvey Island, when being subjected to proposals for the further storage of hazardous substances. His actions at that time brought about “The First and Second Canvey Island Reports” and the concept of societal risk rather than individual risk becoming the accepted risk ramification benchmark.

    The following is an extract from his speech made in the Houses of Parliament:-

    “In the United States, legislative controls are being imposed to ensure that any new liquefied gas terminal is built remote from population. For example, the criterion in California is that within one mile from any new terminal the population density should not be greater than 10 persons per square mile and within four miles not greater than 60 persons per square mile. In Holland, the new liquefied gas terminal at Eemshaven will be 4.3 miles from the nearest residences.

    All this must have been known to the HSE at the time of its investigation on Canvey. It was certainly aware of the dangers. In its report it conceded that if there were a major spillage of liquefied gas, leading to the explosion of a vapour cloud, it could have serious consequences, including death, but it could suggest no amelioration. Yet, knowing this, it still refused to recommend the removal of the hazard. Its proposals for a limited cordon sanitaire are therefore irresponsible.

    Worse than that, there appears to be no consistency whatsoever in the advice it is giving to authorities elsewhere which are faced with planning applications for the storage of liquefied gases”

    Sir Bernard’s efforts resulted in a huge risk reduction outcome being afforded the community of Canvey Island at that time. Since those days the activity in and around Hazardous Sites has been controlled by the use of Consultation Distances which endeavours to provide an acceptable scale of varying degree of aversion outcome, this system is known as the PADHI system.

    Authorities such as ours are heavily reliant upon the HSE advise when dealing with planning application in and around hazardous sites. The HSE are reliant upon the integrity of a planning authority to consider all other aspects, not required for consideration by the HSE, when applying this process. i.e. those numbers of persons subjected to Hazards and subsequent risks emanating from the granting of previous planning application, already within the consultation system boundaries of a hazardous site. The HSE expect the concept of residual risk, (the risk that remains regardless of the most stringent safety measures), never be underestimated by Local Authorities when they are considering planning applications.

    Jean I hope that this is helpful.

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