Castle Point Local Plan – confusing Outside Assistance with Outside Interference!

Blog Post 500!

So our councillor Letchford (according to Echo letters Oct 16th) suggests taking the Castle Point Local Plan out of politicians’ hands! He suggests the possibility of a “revenge vote” next year against Conservative councillors perceived to surrendered mainland sites to developers could give control of the council to the CIIP.” (?)

Also that the plan has taken six years to get to its current position. We suggest that many more years than six, have resources been spent during this saga.

Cllr Letchford continues “Whilst the task and finish group is made up of councillors with one eye on next year’s elections there is unlikely to be agreement on where houses should be built. This conflict of interest could result in the council having a plan imposed on it by the Government and £11 million will be lost.”

By introducing outside professionals who would take into account government requirements, the housing needs of the Borough, the local infrastructure etc a Plan would be conceived and the £11 million would accrue.

Cllr Letchford tells us that “I can live with future development based on good professional advice. What I cannot stomach is more development in one area just because councillors elsewhere were afraid of losing their seats and political power.”

Well during the process of the Core strategy much outside professional advice was commissioned, and much was ignored, including the Sustainability Appraisal and the Strategic Flood Risk Assessment.

The Sustainability Appraisal saw CPBC being questioned why no evidence was illustrated why the borough’s most sustainable development site was totally rejected.

The much delayed, embarrassingly so, Strategic Flood Risk Assessment was used in order to support development within the 3a Flood Zone.

Through the application of the Sequential Test the Flood Zone 3a should have the “more vulnerable” development directed away, onto Zones 1 and 2.

The area that the Sequential Test should be applied across should not be contentious, through a Local Plan it should be Borough-wide, especially in the case of Castle Point being such a small Borough.

The authors, Scott Wilson, of the Castle Point Flood Risk Assessment appeared to have their work under-mined on at least one occasion.

The Environment Agency wrote to Scott Wilson to request;

“Once again we would ask that reference to an agreement made between us and SOS BC (Southend on Sea Borough Council) regarding the area of application for the Sequential Test is removed. We are not aware of a formal agreement on this matter and such an agreement falls outside of our remit. However, as previously stated the LPA are entitled to reduce the area of ST (Sequential Test) application as per Paragraph 4.18 of the Practice Guide – this is their decision and something they should justify. We would not agree the detail of the Sequential Test, just ensure the correct methodology is applied.”

So, some unusual constraining of the area that the Sequential Test has been applied within the Borough by the local authority, has been clearly identified and the detail of the Sequential Test is identified the sole responsibility of CPBC.

The justification continually offered by CPBC being;

“the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement.”

Some recent Canvey residents exposed to the surface water flooding and the increase in insurance charges may disagree with that sentiment!

Recent Planning Guidance gives some indication that Castle Point Council may be applying the Sequential Test in an “unusual” method;

“As some areas at 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 reduce flood risk and put the most vulnerable development in lower flood risk areas.”

This Guidance clearly suggests that a Borough-wide application of the Sequential Test is expected, alternatively an even wider application would be correctly justified, as opposed to the Castle Point Council’s micro application of the Sequential Test.


“A local planning authority should demonstrate through evidence that it has considered 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 in the sustainability appraisal report. The Sequential Test can also be demonstrated in a free-standing document, or as part of strategic housing land or employment land availability assessments.”

You may have noted, although it has received less focus than other issues, that;

  • Flood Risk is a Constraint on housing development.
  • That the Sequential Test may be applied across more than one local planning authority.

And yet Castle Point Council select to apply the Sequential Test to a limited area, that of Canvey Island.

This despite the CPBC Sustainability Scoping Report identifying;

“Given the risk to the population(from the Risk of Flood), various measures are required to deal with the concerns to human health and wellbeing.

These include:

The need to maintain the population living in the flood risk zone at current levels or lower;”

As attractive as having the £11 million “enticement” for completing the Local Plan and the possibility of retaining positions as ward councillors, the influence on the Local Plan by influential council members may be quite considerably misplaced, and officers input maybe seriously questionable.


One response to “Castle Point Local Plan – confusing Outside Assistance with Outside Interference!

  1. The Planning Inspector Mr Paul Crysell when conducting his examination of the abandoned Core Strategy posed these questions to the Council when dealing with the following issues.


    1. Is the Council’s approach to flood risk comprehensive, practicable and consistent with PPS25?
    2. Does the policy approach adequately reflect the SFRA findings? Will flood risk be satisfactorily managed?
    3. Have reasonable alternative and sequential preferable development locations in lower flood risk locations been fully considered?
    4. Does the Environment Agency have any concerns over the future protection of Canvey Island from flooding?
    5. Any there any issues arising from the change from PPG25 to PPS25 and the provisions of the Flood and Water Management Bill?
    6. Will adequate water resources be available to deliver the planned jobs and homes?
    7. Does the CS pay sufficient attention to the implications arising from climate change?
    8. Will the Core Strategy provide adequate protection to the quality of the area’s water courses?

    Seemingly unconvinced that the Core Strategy presented a sound approach the inspector concluded amongst other concerns, that:-

    “The Council’s desire to protect its Green Belt areas is understandable but its approach has also had a considerable bearing on the overall distribution of growth promoted in the Core Strategy. In this respect, I consider it would be difficult to endorse a strategy which commits to Green Belt release in an area of potential high flood risk at Canvey Island yet fails to identify more than a token amount of land on the mainland where flooding is not a significant issue. While I accept some development at Canvey Island may be required to meet local needs and to support services, I am not convinced that maintaining the current distribution of development across the Borough is justified given the existing constraints”

    It would not be unreasonable to conclude that flood risk once again has not been given the weight seemingly identified within the NPPF .
    Most of the issues identified by the inspector still exist and indeed there has been a considerable amount of development on Canvey Island since he expressed his concerns.

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