Castle Point Council’s Local Plan2016, read by an outsider or even a Planning Inspector in conjunction with the daft New local Plan (2014 version), may be considered to have identified almost ALL of Castle Point’s Green Belt and green field land as being available for both Housing, and in the case of Canvey Island, Industrial Development as well!
It is not unusual to expect developers to attack the Castle Point Local Plan 2016, as they have attacked each previous version.
Developers Consultation submission comments / criticisms include:
The New Local Plan concludes that “The draft Local Plan is generally sustainable”, that “It is therefore appropriate to move forward with the plan-making process on the basis of this plan” and that draft Policy H1 (Housing Policy) “strikes an appropriate balance between the different sustainability objectives.”
However, the SA/SEA has not been amended since 2014 which in respect of the Draft New Local Plan (2014) that the then proposed Policy H1 that:
“The draft policy makes provision for 200 homes per annum, which is less than objectively assessed need, and based on the capacity of the borough to accommodate growth having undertaken a Green Belt Review. Harm to the strategic purpose of the Green Belt is therefore avoided. The level of growth required by this approach will not entirely avoid harm to biodiversity and the risk of flooding; however there was sufficient capacity to accommodate mitigation at this level of growth. Harm to important areas of landscape value is however avoided through this approach.” (para 3.6.3).
The Sustainability Assessment of the current NLP (2016) now concludes that:
“When these changes to the draft policies are compared to those proposals originally prepared (the recommended policies) there has been a negative impact on the sustainability of the plan. The reduction of housing sites will result in insufficient capacity to address housing needs”.
“Overall, the draft New Local Plan 2016 has become less sustainable as a result of these changes, and it is recommended that the submission New Local Plan 2016 is amended to reflect these sustainability concerns.”
This is not consistent with the NPPF which seeks to significantly boost Housing supply and ensure that housing needs are met in full (para 47). Furthermore, the Members approach to protecting Green Belt is a false statement as the GBBR (Green Belt Review)(2013) Evidence Base sets out a robust and strong case for areas of Green Belt release that were supported by the Council in the DNLP consultation in 2014.
It is evident that the Council is not prepared to proactively meet its housing need and is artificially using the Green Belt as justification to resist meeting this need.
Notwithstanding this clear contradiction, Professional Planning Officers of the Council have stated on record that they do not endorse the current NLP (2016) document and will not act as advocates at Examination. This was confirmed in the Committee Report to Ordinary Council on 23 March 2016 (Appendix 2) which states that Officers consider that to support this plan would be a breach of the RTPI professional Code of Conduct and that ‘ Members must not make or subscribe to any statements or reports which are contrary to their own bona fide professional opinions, nor knowingly enter into any contract or agreement which requires them to do so’ .
This is clear evidence that the Plan is unsound as the Council’s own Planning Officers deem it so.
It is considered that Members, in pursuit of their political objective to protect Green Belt land, have unjustifiably elected to set aside its own evidence and lower its housing requirement.
Another developer points out that the Local Plan must consider;
“…. Spatial implications of economic, social and environmental change.”
this is particularly interesting as all iterations of the Local Plan, the Core Strategy the daft New Local Plan and the latest version, Local Plan2016 seek to increase the population of Canvey Island through development, thereby increasing the numbers of People at Risk of Flooding and at Risk of a Hazardous Industrial Accident.
As has been mentioned above, it is not unusual to expect developers to attack the Castle Point Local Plan 2016 but for a neighbouring local authority to join in by “helpfully” pointing out;
“However, in doing so the New Local Plan ignores the recommendations of its own evidence base which advises that it is in fact possible for development to occur in some parts of the current extent of the Green Belt in Castle Point without diminishing its purpose.”
Another neighbouring local authority makes comments using terms such as “strongly objects to” and “needs to ensure” and they “remain very concerned about..” all far too emotive terminology than is required to be viewed as being helpful in the Castle Point Plan making process.
The local authority concerned also requested that all mentions of a link road between Canvey Island and Manor Way Thurrock is removed from the CPBC Local Plan!
Very Duty to Cooperate neighbourliness indeed!
Furthermore the author, a “professional” officer, has requested to participate in the oral examination of the Castle Point Local Plan.
I don’t recall this particular local authority’s representative requesting permission to attend the CPBC Core Strategy examination back in early 2010, a far more Unsound and Unsustainable planning document than the current version!
More recently clearer Government Guidance has been issued to accompany the NPPF to assist local authorities in the Local Plan making process with areas constrained by Green Belt land.
The CPBC Local Plan 2016 has evolved from less popular versions and follows activity by leading councillors and indeed the Castle Point MP, who has gone to efforts to arrange training sessions for councillors and officers with Ministers and advisory Planning Inspectors.
Government Guidance includes:
Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity;
The CPBC Local Plan2016 evidence base is undermined by containing many reports and assessments which are seemingly out of date, such as the Green Belt Boundary Review 2013 – published prior to the Government issuing clear Planning Guidance on Green Belt and yet contained within the current Evidence Base of the Local Plan.
For a Local Plan to be successful both the content and the presentation will need to be impeccable. From the comments of both developers and neighbouring authorities it appears that Castle Point officers are unprepared to give the Local Plan 2016 their full commitment. Officers participation at the Examination of the Plan will make interesting watching.
Photo courtesy of: Echo Newspapers