JUST 5 DAYS LEFT to OBJECT to PERSIMMONS PROPOSAL to DEVELOP DUTCH VILLAGE Green Belt Fields!

There are just 5 Days remaining to lodge your objection on Persimmons proposal to develop the Dutch Village Green Belt fields with Castle Point Council.

It is apparent, going by the number of objections received, that Canvey residents may be disengaged with local issues. This apathy is possibly due to a feeling that those in authority take little notice of Canvey residents views and opinions.

This is no reason to not make your views known, as so many of you did when we held our Referendum, when such a strong feeling in favour of preserving Canvey Green Belt was expressed.

We are told that the number of objections is important, please use your right to respond, it will take just 2 minutes!

This LINK will take you directly to the Castle Point Planning Portal, East of Canvey Road proposal. From here you simply need to click on ” Make a Public Comment” and enter your objection.

The Canvey Green belt Campaign have registered an objection and it appears below.
Yours does not need to be so long winded.

Application Number: 15/0496/OUT

Land East of Canvey Road

Canvey Green Belt Campaign Group

Objection to the Proposal

The proposal seeks to “Redevelop” the site. No buildings currently exist that are planned to be redeveloped within this proposal. Therefore this proposal must be considered to be development within the Green Belt and as such inappropriate.

Contents

1. Local Plan
2. Housing Need
3. Sequential Test
4. Green Belt
5. Amenity, Value and Loss Impact
6. Castle Point Green Belt Review
7. Castle Point Green Belt Functions Report
8. Castle Point Green Belt Landscape Assessment
9. Environmental Impact – 9a Ecology – 9b Wildlife
10. Very Special Circumstances
11. Ground Investigation Report
12. Transport
13. Flood Risk
14. Surface Water Flooding
15. Evacuation
16. Flood Warning
17. Insurance
18. Financial Contributions
19. Local Factors and Financial Influences
20. Public Opinion

1. Local Plan

The Adopted Castle Point Borough Local Plan Proposals Map indicates that the Land East of Canvey Road forms part of the Green Belt. The existence of the Green Belt in Castle Point has been tested and confirmed legally.

Whilst the New Local Plan has been a while in gathering evidence, carrying out of consultation and consideration of responses, there are clear signs that progress is being made, and having gone through the process so far, would be considered unreasonable if individual planning decisions were made that may not be Local Plan preferable, without allowing the LP process to first run its course.

An Approved planning decision on this particular application would by definition require the site to be included within the 1 – 5 or 6 – 10 Years Housing Supply, which would likely in itself render the Castle Point New Local Plan “unsound.”

Therefore this Application proposal can be considered Premature.

2. Housing Need

Objectively Assessed Housing needs are being calculated through the Local Plan process.   The intention then is to apply the relevant constraints to development that apply locally.

Planning Guidance has been addressed locally through sessions with Government Ministers and a senior Planning Inspector reassuring councillors that there is no compulsion to release Green Belt land for development. Whilst this argument may appear tenuous, the added weight of this site also being in a Flood Zone as well as being within the Green Belt, means that the East of Canvey Road is a less sustainable, therefore less suitable site than most others for development.

Historically, since the formation of Castle Point in 1974, Canvey Island has absorbed the vast majority of the large development carried out within the Borough. This is evidenced by the extraordinary rate of population growth.

The population on Canvey Island has grown by 42.6% since 1971-2011.                                                                                                                                       In comparison the UK population has grown by just 13.5% and the mainland population growth by around 2.4% over the same 40 year period!

The historical distribution of growth towards Canvey Island, given the development Constraints, requires addressing.

The developer suggests there is a “known demand for housing and employment in the area.”[1]

Regarding the developer’s reference to employment, two large business development areas on Canvey Island, set aside within the 1998 adopted Local Plan, remain undeveloped!

Regarding the developer’s reference to “known demand for housing”, whilst there may be some Local Need, being in Flood Zone 3A  and given the extraordinary population growth on Canvey Island since Castle Point was formed, the previous distribution of development brings into contention how the future housing need should be distributed.

The Castle Point Local Plan Sustainability Scoping Report states “Given the Risk to the population, various measures are required to deal with the concerns to human health and wellbeing.”           These measures include “The need to maintain the population living in the flood risk zone at current levels or lower.”[2]

The developer appears prepared to ignore this Risk to the existing population’s safety, by seeking to continue adding to the population at Risk, contrary to CPBC Sustainability Scoping Report’s recommendation.

3. Sequential Test

Within the Core Strategy, the Land East of Canvey Road was included as the sole large Green Belt development site proposed within the Borough for the whole Plan period, despite being Green Belt within a Flood Risk Zone 3A area.

Through the New Local Plan (NLP) the Sequential Test should be applied Borough-wide.                   CPBC appear to apply the Test specifically to Canvey Island, despite Castle Point being one of the smallest UK Boroughs.

 The draft New Local Plan states at 17.27 “The NPPF sets out a sequential test that seeks for development to be located to avoid flood risk. Canvey Island comprises of around 40% of the borough’s area and is home to around 40,000 people. It is not therefore always possible to avoid development. This community will have development needs that change over time”

 It goes on to refer to the TE2100 scheme  stating; “proposals that meet local needs and re-use land within the existing urban area will need to be permitted, despite the sequential approach, in order to ensure the wellbeing of Canvey residents.”
This appears to be in conflict with Government Planning Guidance: “Applying the Sequential Test in the preparation of a Local Plan”
The failure to apply the Sequential Test Borough-wide is specifically evidenced at New Local Plan Policy CC2d

This method of application of the Sequential Test will result in an un-necessary addition to the population put at Risk of Flooding. The correct approach to the development in a Flood Zone would see small development, and those seeking to add additional storeys to single storey dwellings.

Large development, especially within Canvey Island Green Belt, will see an inward migration adding disproportionately to the numbers at Risk of Flood.

The Local Authority applies the Sequential Test when considering previous applications as a means of preventing social and economic deprivation.

This is contradicted by the developer’s Planning Statement, in which it states, “Canvey is well-equipped in terms of its facilities and has a range of eating and drinking establishments, library, post offices, supermarkets, GP surgeries, dentists and a variety of employment.” It continues “Other facilities in the town include Concord Rangers Football Club, Canvey Island Football Club, Island Yacht Club and various areas of public open space including Canvey Heights Country Park.”[3]

Academically Canvey Island is very well supported with two new “state of the art” Senior Schools and a New Skills College on the site of the old Castle View School supporting the development of trade based education.

We would suggest that within the current Urban area of Canvey Island there remains enough development land potential to support the Town’s population and its Local Needs without altering the Green Belt boundary and releasing Green Belt land un-necessarily.

Furthermore, the Developer points out that Castle Point Borough Council, within its SHLAA 2013 Update, has “identified 38 Green Belt sites.”[4]

It appears illogical in the light of there having been identified 38 Green Belt sites within the SHLAA to then promote this site located within Flood Zone 3A as being appropriate for development within the New Local Plan period.

It further appears only correct on this evidence, to claim that justification exists for Castle Point Council to  re-apply the Sequential Test, Borough-wide in line with Planning Policy prior to a decision on this proposal, through the Local Plan.

4. Green Belt

The Developer concedes: “The nature of development is not listed as appropriate and therefore the proposal represents inappropriate development in the Green Belt.”[5]

The Land East of Canvey Road site, according to the CPBC Green Belt Review, fulfils the Purposes of checking the unrestricted Sprawl of West Canvey and assists the countryside from Encroachment.

 Additionally the site in its current state provides an invaluable contribution that supports:

• opportunities for access to the open countryside for the urban population;

• opportunities for outdoor sport and outdoor recreation near urban areas;

• helps retain attractive landscapes, and enhance landscapes, near to where people live;

• and supports opportunity to improve damaged and derelict land around towns.

The two schools mentioned within the Developer’s Planning Statement, Cornelius Vermuyden and Northwick Park do not detract from the openness and character of the countryside.

The Developer claims that the proposed development “effectively infills an area of land between existing built development to create a more logical edge to the open land to the north of the proposed area of development.”[6]

This claim is disputable as the diagram at 3.41 of the Planning Statement illustrates the introduction of a 4 sided Green Belt boundary, with two northern most sides plus an eastern side.

Diagram 3.1 of the developer’s Planning Statement further illustrates that the development, rather than, as claimed, would allow the Green Belt to continue to fulfil its functions, would actually weaken this ability and encourage further  development, Northward to Waterside and to its far Eastern boundary at Church Parade.

The existing Southern and Eastern boundaries are far more clearly and logically defined and defensible, that being the existing line of the Hill Hall Dyke.

5. Amenity Value and Loss Impact

The amenity value this Green Belt site has provided over many, many decades, prior to Persimmon “inheriting” the ownership, remains invaluable to local residents well being.

The developer states that the site “is not a formal area of public open space that the public are permitted to use.”[7]

And “The Application Site contains a Public Right of Way (PRoW) which forms the southern boundary. This is the only public access to the site.”[8]

This we dispute.

There have never been signs erected instructing people to Keep Off of the Land.

There are two formal access entrances, at Dyke Crescent and the bridge across Hill Hall Dyke near the Avenues estate, which are maintained. To the North there is complete open access from the Waterside area.

Apart from the Council Highway barrier alongside Canvey Road and back garden fencing of existing housing to the west and south, the East of Canvey Road site is generally open.

The local authority, maintain a large grass area on the site near the Dyke Crescent entrance, allowed as a play / recreation amenity presumably with agreement from the owner. Other areas are used for rambling, dog walking and horse riding, this is clearly evidenced by the worn pathway tracks across the site. Generally the Land East of Canvey Road provides a valuable area used for informal activities.

The nature of the land generally, grassland with hedgerows and an area of woodland, provides an outlet for occasional delinquent behaviour and vandalism.

Without this outlet this behaviour will likely be transferred to the nearby RSPB site across Canvey Road and the nearby Benfleet Marshes RAMSAR and SPA area where damage would have far greater consequences. The onsite Scheduled Ancient Monument, the Roman Saltern will also likely be impacted upon by the urban fringe being moved to its close vicinity.

The resulting Post Development Sprawl will result in an increase in urban vandalism simply due to the loss of a large open area that may have previously taken this type of behaviour away from the urban neighbourhoods and sensitive Ecological Impact Risk Zones.

There is an area abutting the site, known as the Avenues Estate, that is considered by the LA to be a somewhat deprived area.

To areas of deprivation access to Open Space is of the utmost importance. This is recognised by the Urban Spaces initiative. The Urban Habitats initiative is a cross border co-operation between the Netherlands, the United Kingdom and Flanders.

Castle Point is not a member of the initiative, however that does not mean that the aspirations of the initiative are not relevant. The initiative recognises that as a result of growing economic activity and population levels there is increasing pressure on the sparsely available natural space. And that this space is essential for the quality of the urban living environment, offering recreation possibilities and contributing to conservation of nature and biodiversity in urbanised areas.

6. Castle Point Green Belt Review

This is an in-house produced review. The fact that this site is rated Amber can be given little weight as so many other sites within the Borough are also Amber rated, sequentially that should require this site being delayed for, or Refused for, Release.

7. Castle Point Green Belt Functions Report

This is an in-house produced report. The function of “Regeneration” should be added to the East of Canvey Road site. The Canvey Town Centre is only 1.8 miles away just a 34 minute walk.[9]

Little progress’ beyond aspiration level’ has emerged as far as the Canvey Town Centre regeneration is concerned.

The new Castle View School, in the Town Centre, was funded by Government bodies. Little interest has been evidenced that leads residents to believe the regeneration scheme will make progress in the near future.

The approval of this East of Canvey Road proposal will potentially hamper the development of town centre housing, creating doubt over its immediate viability.

8. Castle Point Green Belt Landscape Assessment.

This document has been compiled by an outside source, Essex Landscape Design.

Of East of Canvey Road it considers:

The area lies within the Canvey Marshes Historic Character Area, which has the following historic landscape character: 

‘This zone is bounded to the north by Benfleet Creek and to the west by East Haven Creek. Although the north of the zone, bordering Benfleet Creek, retains its saltmarsh, the zone consists mostly of reclaimed marshland, the central and western part of which has EU-designated Ancient Land status. This is an area of grazing marsh, comprising blocks of regular and irregular fields bounded by drainage ditches with often sinuous boundaries reflecting their origins in marshland creeks. The boundaries are mainly of medieval/post medieval origin resulting from the creation of grazing marsh.”

“Cultural Factors are recorded as: Retained historical field pattern and boundaries, currently well-used for formal and informal recreation.

Aesthetic Factors recorded as: The apparent character is extensive, open and distinctive.

Landscape sensitivity High

Visual sensitivity: High

 There are constraints on development due to the high landscape and visual sensitivities and the designation of the Coastal Protection Belt.”

9. Environmental Impact

The proposed site is situated at the nearest single entry point the “Gateway” to Canvey Island.

Currently the green area sets the scene for Canvey as being a semi rural coastal area.

The developer’s proposal will reduce the “village” feel of this “Gateway” area and introduce Urban Sprawl.

Canvey Island already being the most densely urbanised town in the Borough.

The intention to site 2.5 – 3 storey dwellings fronting Canvey Road and opposite the open-space RSPB site will create a totally out of character street scene at this part of Canvey Island.

The developer’s reference, within “No development Alternative,” to demand for housing, whilst there may be some Local Need, being in a Flood Zone and given the extraordinary population growth on Canvey Island since Castle Point was formed, the previous distribution of development, should also be used to inform how the future housing need should be distributed.[10]

The Castle Point Local Plan Sustainability Scoping Report states “Given the Risk to the population, various measures are required to deal with the concerns to human health and wellbeing.”           These measures include “The need to maintain the population living in the flood risk zone at current levels or lower.”[11]

The developer lists the Constraints affecting developing the site, yet fails to mention the Green Belt.[12]

The developer appears to be relying on Castle Point Borough Council removing East of Canvey Road area from the Green Belt, this must be considered initially Sequentially, and secondly through an Examination in Public of a Local Plan, once it has been finalised.

A further constraint, at 4.2.2, is shown as the “need to protect and enhance the location on site of the scheduled ancient monument.” 

This may prove difficult given the intention to Land Raise by approximately 1 metre an area already susceptible to high water table around the Roman Saltern mound.

The developer also proposes “The provision of new community facilities for the benefit of existing and future resident.”[13]

Given the difficulties in realizing the affordable housing promise on other far more financially viable local development sites, the necessity for a maintained pumped drainage system, the new access roundabout, the flood risk mitigation measures and the generally lower priced housing market in this part of the Borough, the provision of these new community facilities may be considered simply aspirational.

9a Ecology:

The developer’s Environmental Statement’s (ES) Ecology section, notes the site having suffered from some vandalism, by way of burnt fields.

The East of Canvey Road site is indicated as being within the “SSSI Impact Risk Zones – to assess planning applications for likely impacts on SSSIs/SACs/SPAs & Ramsar sites (England)” according to the Magic Map service managed by Natural England.

The developer’s ES report at 6.3.4 refers to the site’s close vicinity to the areas Designated Sites those being: Southend and Benfleet Marshes Special Protection Area (SPA), Site of Special Scientific Interest (SSSI) and Ramsar, (0.7km), Thames Estuary Marshes SPA, SSSI and Ramsar (3.3km), Canvey Wick SSSI (0.9km), Holehaven Creek SSSI (1.2km), Canvey Lake Local Nature Reserve (LNR)(0.9km).

Non statutory sites within 2km of the Application Site Include: West Canvey Marshes Local Wildlife Site (LWS) (0.7km), The Lake LWS (0.8km), Canvey Village Marsh LWS (1km), Thorneycreek Fleet LWS (1.8km).

The close vicinity of the proposed development and the loss of the “vandalism buffer zone” the East of Canvey Road site appears to offer, suggest the impact on the SSI Impact Risk Zones, including the SPA and Ramar and RSPB sites cannot be disregarded!

9b Wildlife:

The developer’s proposal to increase the Urban Sprawl by developing this site will remove an outlet for low impact vandalism and increase the opportunity to take this behaviour further afield.

Already there have been reports of such problems at the RSPB Canvey Marsh site.

The Environmental Statement refers to Canvey West Marsh, separated from the site by just the Canvey Road, and lists the area supporting:

at 6.3.7 Ringed Plover Charadrius hiaticula (on passage), Dark-bellied Goose Bernicla bernicla, Grey Plover Pluvialis squatarola, Knot Calidris canutus. Assemblage qualification: A wetland of international importance, the area qualifies under article 4.2 of directive (79/409/EEC) by regularly supporting at least 20,000 water fowl. Over winter, the area regularly supports over 30,000 individual water fowl including Dunlin Calidris alpine alpine, Ringed Plover, Oystercatcher Haematopus ostralegus, Knot, Grey Plover, Dark- bellied Brent Goose, populations of European importance.

The close proximity of these sensitive areas will lead them to be impacted upon by the problems of urban development.

The loss of the East of Canvey Road Green Belt site will affect loss of habitat for: Butterflies, Marble whites, Common Blue, Hollie Blue, Small Copper, Meadow Brown, Essex Skipper, Tortoiseshell, Peacock, 5 Spotted Burnet. Grass snakes, Adders (both protected), birds include Corn and Reed Bunting, Chaffinch, Goldfinch, Greenfinch, Robin, Whithroat, Skylarks, Meadow Pippit, Wren, Dunnock, House Sparrows, Jay, Kestrel, Swift.

The developer claims “The proposed project is not therefore expected to produce likely significantly effects upon the integrity of the Canvey Wick SSSI or the conservation status of its important invertebrates. The confidence in these predications is near – certain”[14]

Whilst with “Local Knowledge,” and in direct contrast to the developer’s claims, the loss of this site to development will demonstrate a squeeze on the habitat area that is Canvey Marsh, and the “bigger picture” would likely result in, should this development be given approval, an impact upon the close-by sites at Canvey Marsh, Canvey Wick and Benfleet Marsh to a serious extent.

A little land management would see an improvement to the East of Canvey Road site.

The developer Environmental Statement claims “6.7.4 The proposed development at the land east of Canvey Road will provide an opportunity to achieve positive outcomes for notable species and biodiversity in general securing, creating and managing habitats in the long term. This mosaic of habitats and species will provide a living sustainable landscape which will be enjoyed by the local residents and allow wildlife to thrive. The future of the green infrastructure onsite will be secured through the ongoing revision of the sites management plan as conditions on site change.               The biodiversity of the landscape will also provide a valuable educational resource to local residents, in particular school children who can learn about Great British wildlife and even become involved in the management of habitats that will provide improved environments for a multitude of species including amphibians, reptiles, birds, invertebrates and small mammals (including bats).”

The developer’s claim is quite simply “aspirational nonsense,” given the current lack of general funding for essential local maintenance.

10. Very Special Circumstances.

This site is an inappropriate development in the Green Belt.

Planning Guidance suggests that Housing Need does not in itself amount to Very Special Circumstances for the release of this site.

Openess.   The loss of Land East of Canvey Road as Green Belt will impact upon the Openess of the area, viewed both from the neighbouring area and especially from the higher ground at Benfleet.

The site is at the “Gateway to Canvey” and as such “sets the scene” that Canvey was originally a green, rural marsh area, rather than the densely urban area it has become.

Sprawl.   The site prevents Urban Sprawl. The site is the last large green field area, within the Canvey road network. It is generally unaltered from the ancient landscape that formed the Canvey marshland reclaimed by the Dutch in the 17^th Century.

Encroachment.   The site forms an important buffer between the urban area, and both the RSPB site to the west and the Benfleet Marsh to the north.

Using the Government Secretary of State’s accumalitive methodology, as in his decision of the Castle Point versus Glebelands Appeal CPT/7/12/OUT, the resultant loss of Openess, harm in respect of Urban Sprawl and harm by way of Encroachment, posed by the East of Canvey Road site proposal, we consider the resultant effect amounts to causing Considerable Harm to the Green Belt.

We suggest site selection is considered Sequentially flawed, and that therefore the very Special Circumstances required to allow for development do not exist.

11. Ground Investigation Report

Indicate negative readings, and also state that they are incomplete despite having been published in 2012.

• The Hydrological report indicates a High Water Table that is affected by the tidal flow.
• The Geological report indicates a potential health hazard by the leakage of methane.

12. Transport

The effects of the proposed importation of 100,000cubic metres of Land Raising material, estimated 10,000 lorry movements and the construction vehicles appears to be underestimated.

Highway surveys appear out of line with residents commuting experiences.

These large slow vehicles cannot fail to impact upon Canvey Way, Waterside Farm, Somnes Avenue and Sadlers Farm junctions especially during Peak Periods.

The possibility that Dyke Crescent, currently offering the only vehicular access to the East of Canvey Road site, being used by delivery lorries ahead of what will be a difficult planning, financing and development exercise to introduce the site’s new access Canvey Road Roundabout, cannot be dismissed.

13. Flood Risk

The proposal indicates an intention to Land Raise the site. The developer recognises this will increase off site flooding,

This is unacceptable as it will inevitably create an increase in off-site Flood Risk, the amount is irrelevant, to neighbouring property and land, contrary to NPPF Paragraph 102.

The Strategic Flood Risk Assessment indicates that Canvey Island, including the development site, is at Actual Risk of Flooding. This document states: “It is strongly recommended that the information in these Chapters is used to inform planning policy with respect to development control decisions across the borough.”

Should a breach in the sea defence occur the site would experience flooding.

Should the Benfleet barrier be left open, as has occurred on two known occasions the potential exists for the site to flood.

Should a breach of the sea defence occur, whilst the possibility is rated as low, the effects could be catastrophic.

The development of the site, if permitted, will dramatically channel the flood water flow paths in and around the existing dykes increasing the level of danger to existing residents.

The Canvey Island drainage system is incapable of coping with the resultant flood water should a Breach of the sea defence occur.[15]

14. Surface Water Flooding

The CPBC Surface Water Management Plan is not relevant to Canvey Island, the methodology is reliant upon undulating land. Canvey Island being mainly flat, at or below sea level, relies on gravity and a network drainage system, recognised as “complicated” by the Environment Agency, supplying the drainage pumps.

The developer’s proposal indicates the instalment of an additional pumping station to assist drainage.

These plans were evolved prior to the Canvey Island surface water flooding events of 2013 and 2014.[16]

The experience of these flooding events exposed the likely failures of pumping stations during storm events, those being cuts in electrical power, over heating of the drainage pumps and debris blocking filters preventing drainage water flow.

Maintenance levels to drainage assets were specifically highlighted as being reasons for the level of flooding during the 2014 event.

There can be no guarantee that future maintenance regimes will be kept to the necessary levels.

The developer references the Atkins Study of 2007 within the Flood Risk Assessment.

Canvey Island is currently the subject of an Integrated Urban Drainage study, development proposals should use the resultant IUD study report as the basis of all Surface Water flood assessments.

Foul Water Effluent: “The Proposed Development will create foul water effluent flows from both residential and community centre uses. The unmitigated flow will be a fundamental change from the baseline conditions, with the sensitivity of the surrounding area being high. Prior to mitigation features this foul water effluent flow would have a major adverse effect on water quality for the site and surrounding area.” (Agent’s emphasis)  [18]

Increase Run off:  “The Application Site is proposed to be developed as a primarily residential development. The change in impermeable area across the Application Site will increase the rate and volume of surface water runoff from the Application Site. The unmitigated change in runoff rate and volume is a fundamental change, with effects on the local scale. The increase in runoff and volume for the Application Site will have a major adverse effect on the existing surface water drainage system, due to discharge limits set to the existing pumping station at the Hill Hall Dyke.”   (Agent’s emphasis)  [19] 

 EA Letter from Robertson, Graham to Purcell Simon cc Knowles, Stephanie; Geary, Adrian dated 19^th May 2011.                                                                                                                                                               States; “The pumping stations and their upstream arterial feeding drainage channels perform for operating standards that are less than the current day 1 in 100yr (significantly less in most circumstances) storm event.”

“The upshot of these constraints is that conventional solutions for surface water control/attenuation at source are problematic, particularly if you are looking at site volumetric control measures in excess of the calculated greenfield rate of discharge for the site.

Similarly, unconstrained discharges into the open watercourse system upstream of the EA’s Dutch Village Pumping Station will lower the existing standard of protection that this system provides, possibly to the detriment of existing development close to the pumping station and the Hill House Dyke.”

“I think that the solution to this dilemma may be to look at the potential for a bespoke pumping station arrangement to serve the site efficiently and rather than looking at significant attenuation on the site, look to move water with significant flow capacity away from the site (perhaps there may be potential “on-paper” options to discharge to the wide marsh catchment to the west of Canvey Way”[20]                                            

This solution has since been rejected by the RSPB.[21]

Of further concern is the Diagram of Anglian Water Assets, mapping the neighbouring Dutch Village drainage system.

This existing neighbourhood, known as the Dutch Village Estate, would be sandwiched between the developer’s site and Canvey Road.                                                                                                                                        The Dutch Village Estate is, in parts, below the level of the Canvey Road and, should Land Raising be employed as a means of mitigating the developer’s site flood risk and drainage issues, in effect become a basin between the road and new development. The two elements of Canvey Road and the new development would likely create flow paths through the Dutch Village Estate in the event of an extreme flood event.

The Flood Risk Assessment Map of the Dutch Village Estate indicates the limitations of the neighbouring Dutch Village Estates drainage system.

Large parts of the estate are unmade roads and as such are not served by drainage gulleys. The northern part of Limburg Road and eastern part of Holland Avenue in part appears to be served by drainage unconnected to the main system (marked blue).[22]

Overall Flood Risk casts a Viability issue on this proposal.

Adverse Run off and Foul Water Effluent contamination levels must be considered unacceptable in a sensitive estuarian area given the drainage methods.

15. Evacuation

The proposal’s paperwork indicates introducing an unacceptable level of confusion for the safety of new residents and existing residents in the event of a flood event. The proposal to introduce an evacuation point, contradicts the CPBC emergency advice of “Go in, stay in, tune in” which in itself may be endangering to residents in single storey dwellings.[23]

The provision of a Refuge point within the Community facilities requires some consideration.

A health and safety hazard may be introduced should residents attempt to reach this facility during a flood event. Routes may be considered extremely onerous to cross, given the likely lifting of  drainage covers and the introduction of swales etc as a SUDs regime, alongside other storm event hazards.

Evacuation has a questionable success potential. The estimated time to evacuate Canvey Island in the event of an Emergency could take up to 19.7 hours.[24]

The CPBC “Be aware, be prepared, be resilient,” has achieved little awareness amongst Canvey Island residents.

The proposed site is situated at the nearest single entry point to Canvey Island. As such, should an Flood or other Emergency event occur, the site’s new residents, being nearest the entry to Canvey Island, would likely receive priority attention ahead of the existing population of 38,459 residents.

Those new site residents who are able to, may become some of the first to evacuate, leaving those existing residents to the South and East part of Canvey Island, those  in single storey dwellings and the most vulnerable, being delayed longer than necessary during what already appears a potentially dangerous and complex evacuation / rescue operation.

Thus effectively increasing the level of Risk to others contrary to NPPF Guidance.

16. Flood Warning

The Flood Warning scheme operated by the Environment Agency is effective in only one of the three possible flood scenarios.

In the event of a breach of the sea defence, the EA would be reliant themselves of being made aware by local residents.

In the event of surface water flooding through a storm event, the EA would only be able to give a general potential warning.

It is likely that only in the event of a surge tide, the EA would be able to give Canvey residents advance warning of flooding caused by “over topping” of the sea defence.

17. Insurance

The Environment Agency continue to recommend that Castle Point Council consider whether new Canvey Island properties can obtain Insurance against Flood during the lifetime of the dwelling.

Insurance specialists are more specific;

“The ABI strongly believes that unwise development in flood risk areas should not take place, and has made it clear that such developments may struggle to access property insurance.”

O.Thoreson ABI Director General.

“Flood Re will exclude developments since 2009 – just as the Statement of Principles did. This is because we do not want Flood Re to become an incentive for inappropriate development in areas at risk of flooding.”

Aidan Kerr ABI Head of Property.

Quite clearly Flood Insurance cannot be guaranteed over the lifetime of new property, thereby questioning the financial Sustainability of future dwellings.

18. Financial Contributions

Within the Planning Paperwork there appears to be no offer of developer contributions toward the necessary future improvement of the sea defences.

19. Local Factors and Financial Influences

Within the Core Strategy process this site, known as Land East of Canvey Road, was included as the Borough’s sole large Green Belt development.

Leaked information disclosed that this situation came about by way of a private Lead Group of Councillors meeting with CPBC officers.

During the meeting an attempt was made to negate a stalemate and move the Core Strategy Plan forward. Allegedly  it was suggested, by an officer (now ex-officer), that the Lead Group may wish to consider supporting the Plan if mainland Green Belt sites were omitted, whilst the East of Canvey Road, Canvey Island site was included.

The Lead Group of councillors pressurised by the mainland “Hands of Our Green Belt” campaign group, agreed to this proposal and the Core Strategy was duly published.

During the Core Strategy Examination in Public this information was put to the Planning Inspector Mr P.Crysell. He made further enquiries and was able to confirm how the site selection had been influenced, later referring to this as “”Local Factors” being given too much weight,” and “inconsistent and inappropriate site selection.”[25]

It would not therefore be unreasonable to presume that those members, who had been in attendance at that private Lead Group of Councillors meeting with Officers, may have effectively prejudged the principle of this proposal.

The possibility that an element of predetermination exists, cannot be discounted during the CPBC Development Committee’s consideration of the East of Canvey Road proposal.

Financial Influences:

Following the presentation to Cabinet June 2015, CPBC’s financial situation may be considered being a possible influence on future Planning decisions.

The seriousness of the Local Authority’s current financial situation is clearly highlighted in the Officers Report:

7.3 The position with regard to Council reserves is also serious.

7.8 To clarify the position regarding reserves – No funds have been set aside to fight appeals. All that has been done is to quantify a financial risk that may materialise as a consequence of not having a local plan.

The Council does not receive any New Homes Bonus for any new houses allowed on appeal.

The East of Canvey Road application coming forward at this time, may be considered by the Local Authority as “timely.”

Given the current Appeal Inquiries expenses that CPBC are faced with, it would be of some concern if this were to influence its approach towards timely development applications.

It cannot have gone un-noticed the developer’s suggestion that;

“A development of 300 houses will deliver to the Borough in excess of £2,100,000. Essex County Council receive £422,298.”[26]

These sums must not perpetuate into a material consideration.

20. Public Opinion

 The Canvey Green Belt Campaign group carried out a Referendum widely across Canvey Island.

The Referendum paper read “Should there be any further development of Canvey Green Belt Land?”

And included clear “Yes” and “No” Boxes to place a tick, and a space for the respondent’s signature.

This involved a group of volunteers visiting as many homes as possible over a two week period between 25^th May and 10^th June 2009, offering residents the opportunity to register their opinion.

Collectors were issued with a list of streets to visit, so that duplications were kept to an absolute minimum.

The outcome revealed Six Thousand five Hundred and thirty four residents indicated there opinion by secretly marking a ballot paper, signing and placing in a sealed jar.

The results indicated that:-

Total Votes recorded 6,534

No votes 6,437,

Yes votes 56,

Spoiled papers 41

This indicated a majority of  99.13% of residents polled, were Against further Green Belt development on Canvey Island.

The sealed jars were opened and counted under the adjudication and verification of: R.Howard ECC and CPBC Councillor, David Blackwell ECC and CPBC Councillor, D.Williams ex CPBC Mayor, and G.Whatley resident.

Voting papers .

[1] Developer’s Environmental Statement 4.2.2

[2] CPBC Sustainability Appraisal and Strategic Environmental Assessment Scoping Report New Local Plan p27

[3] Pegasus Planning Statement

[4] Pegasus Planning Statement 3.10

[5] Pegasus Planning Statement 6.3

[6] Pegasus Planning Statement 6.14

[7] Planning Statement 5.4

[8] Developer’s Environmental Statement 2.14

[9] Pegasus Planning Statement 2.12

[10] Developer’s Environmental Statement 4.2.2

[11] CPBC Sustainability Appraisal and Strategic Environmental Assessment Scoping Report New Local Plan p27

[12] Environmental Statement 4.2.4

[13] Environmental Statement 4.2.4 Opportunities

[14] Developer’s Environmental Statement Conclusion 6.4.17

[15] CPBC CEO D.Marchant Essex County Council Flood Report

[16] Developers FRA page 23

[17] CPBC Scrutiny meeting Evidence of ECC Highways maintenance representative (webcast).

[18] Developer’s  Environmental Statement 12.4.17

[19] Developer’s Environmental Statement 12.4.15

[20] Developers FRA Included as EA correspondence following Page 36

[22] Developer’s FRA Appendix C

[23] Developers Planning Statement 6.26

[24] Floodsite “Evacuation and Traffic Management” T17-07-02 March 2008

[25] Planning Inspector Mr P.Crysell’s letter to CPBC Mr S.Rogers dated 11^th May 2011

[26] Developer’s Planning Statement Appendix 2