Leaving no Stone unturned except where Safety Reports and Urban Drainage Study are concerned!

Castle Point Council’s Local Plan is an “officer Plan!” Is the response from many councillors attempting to distance themselves from the unpopular version under review.

The Task and Finish group of council members considering the consultation responses, are in the words of their chairman leaving “no stone unturned” in their work. During the meetings the process appeared to be to listen to various comments selected by officers, consider their written responses on whether, and how, the draft Plan should / has been altered and the members to pass comment on their views. What appeared a “tick box” exercise.

This caused some unease and the process widened to cover optional housing sites and a re-visit of the Housing Constraints and Housing Need topics.

The Constraints issue is affected by Green Belt, Flood Risk, Infrastructure and Hazardous Industries. Up until the August meeting little emphasis had been placed on the Hazardous Industries as a Constraint, especially considering the subject had been covered by the task and Finish group previously just before their work ceased ahead of the Elections in May. The meeting was covered by this Blog and the very relevant video of the Buncefield incident is available within the POST.

Across the Borough Green Belt is being admirably defended with interventions by our MP, leading councillors, Planning Inspectors and leading Government members.

On Canvey the Local Plan has identified intended Housing sites within the Island’s Green Belt boundary, the Plan showing clear intent to remove these areas from the Green Belt by labelling them prematurely as “green field.”

This identifies a weakness in the Constraints issue, in that co-incidentally these Canvey GB sites are also within the Flood Risk 3A zone!

The allocation of Thorney Bay as a housing site, capable of supplying over 600 dwellings to the Local Plan housing numbers, is achieved by the intention of siting the recommended maximum percentages within the “middle” and “outer” Hazard zones whilst none are intended within the “inner” zone. All rubber stamped by officers as the proposal had successfully passed the HSE online generic PADHI+, tick box test.

It would therefore be excusable for Canvey residents to feel puzzled by the application of constraints upon the Castle Point Objectively Assessed Housing Needs, with Canvey allotted housing sites being within both a Flood Risk Zone and the Green Belt and near Hazardous Industries.

Worse still comes the revelation of the Calor Gas sites’s Safety Report revealing the extent of the potential Hazard Range of a worse case scenario incident.

Councillors, including those on the Task and Finish group claimed to be “in the dark” as far as knowing of such a document. Canvey councillors requested that the Safety Report be made available for their research work, however, apparently, Castle Point Council do not  have a copy!

This led to the Castle Point Chief Executive to inform the local press that;

“The reports requested are not relevant to the work of the local plan task and finish group which has been established specifically to consider the responses to consultation on the draft local plan.”

This appears somewhat strange as the next scheduled “public,” as opposed to “private,” meetings of the Task and Finish group are to discuss the allocated Housing Sites and how the constraints apply to each site!


The CEO and officers appear to be implying that outside of the limited Consultation Distances, councillors need not worry themselves.

Mainland campaign groups should not dismiss the situation, for if officers, and no doubt those councillors in a decision making position, feel that Green Belt within a Flood Risk zone 3A is not considered enough of a Constraint on Housing, then they should be concerned as whether Green Belt as a lone Constraint will protect their areas against development!

Introduce the Hazard Ranges illustrated in Calor’s Safety Report then it may well appear further questionable why Castle Point Council appear intent on increasing the numbers at Risk on Canvey Island by proposing large Housing Site Developments!

If the draft Local Plan is an officer’s Plan, and the final Local Plan is to be a councillors Local Plan, councillors will have to, at some stage, take the initiative.

Hidden Reports are unacceptable. The process should be stopped now, until ALL evidence is made available. For officers to be treating the residents of Canvey Island as they are, is unacceptable.

The T + F chairman said “no stone will be left unturned,” well so far the few stones that have been turned have revealed things that are fairly unpalatable.

What are officers and cabinet concerned about that prevents the Canvey Island Integrated Urban Drainage Study Report from being made available, even if its in a draft form?

This brings back memories of the Strategic Flood Risk Assessment being withheld from the Inspector, Examining the Core Strategy, whilst a more palatable version emerged from under the editor’s knife.

We consider it taken that Infrastructure is of equal concern across the whole Borough where Housing Constraints are concerned, ahead of the Canvey Island Integrated Urban drainage study. Apparently another Report that may well be unavailable to Task and Finish group members ahead of their Housing Site deliberation meetings! What are officers and cabinet concerned about that prevents the Safety Reports from being made available?

The process of identifying Constraints in one part of the Borough, and then applying them across the whole Borough’s housing numbers requires highlighting. Canvey residents are becoming aware!

One response to “Leaving no Stone unturned except where Safety Reports and Urban Drainage Study are concerned!

  1. The sequential approach should be being applied Borough wide as the appropriate method in dealing with risk. The NPPG (National Planning Policy Guidance) uses a sequential approach when matching land uses to the risk of flooding. This could prove a very useful additional model for dealing with land use and development in areas where there are Major Hazardous Sites when providing CPBC evidence base to support Its constraints objective.

    Having Major COMAH Top Tier Petroleum and LPG Hazard Storage installations sited within a Zone 3 Flood plain is an exceptional circumstance as to why further large scale housing development should not be permitted within the already heavily populated environment of Canvey Island.

    The National Planning Policy Framework is quite specific in that such development proposals should be directed firstly to sites that are available with less risk of flooding within the Borough.

    The matching of land use versus risk, needs to be recognised as a tool to be used when identifying with the issue of constraints. It would still be possible to include an ‘exceptions’ test to allow flexibility where exceptional local needs circumstance can be justifiably seen to out weigh the risk.

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