“Dear John” Letter from the HSE to Castle Point Council spells a loss of Trust over Thorney Bay!

“WOULD NOT ADVISE AGAINST” Is a phrase that is akin to music to Castle Point Planners ears!

So often does it extinguish any questioning by planning committee members of the extra conditional advice from the HSE, or the Environment Agency, or the Lead Local Flood Authority, when the committee consider Canvey planning applications!

At the Risk of being accused of Scare-mongering, and unlike some that “run with the fox AND hunt with the hounds”,  we prefer to refer to our approach to development as being Cautious, when we refer to Canvey’s constraint issues.

The proposal for the first phase of the Thorney Bay Housing development, cpbc planning application No: 14/0620/FUL, to sit alongside existing caravans is progressing, albeit in an apparently unusual sequence. Given the obvious issue of the neighbouring Calor, Top Tier Comah site, one would have thought that Castle point planners would have made early use of the Health and Safety Executive’s online planning advice app.

It appears however that despite cpbc receiving the planning proposal on the 6th November 2014, no such enquiry was made to the HSE, until the 12th January 2017!

Whilst an initial use of the HSE planning app was made for the original “proposal in principle,” cpbc planning application No: CPT/707/11/OUT, of 600 dwellings plus residential care homes, lodged with cpbc as long ago as 2011, this resulted in an acceptance that 10%, or 60, of the total number of dwellings could be developed within what is labelled the hazardous “middle zone”.

The more “recent” application, for 113 dwellings, sought to use a proportion of the 60 dwellings allowed, sited in the “middle zone,” BUT at a much higher proportion, in relation to the latest planning application, of over 26% !

Rather surprisingly this did not appear to occur to OUR local authority that they might just possibly feel they should refer this percentage level to the HSE!

The developer may indicate the future development phases will have a much lower level of percentage dwellings in the hazardous “middle zone”.

They MAY also find in future these development phases prove unviable without similar high percentage rates, 26%, within the “middle zone,” and having set a precedent within the first phase who could argue?

This seeks higher density development across the whole site, something that would suit developer and the cpbc Local Plan authors equally!

It is somewhat reassuring that the Health and Safety Executive appear to have lost faith in castle point council and with their policy approach towards increasing new residents risk to the exposure to the Hazardous Site.

The HSE have dictated to cpbc that they no longer can take advantage of the HSE’s online Planning Advice App, they have decreed that in future, NOT ONLY ALL future Thorney Bay planning applications which propose development in the “middle zone” must be referred directly to the HSE, but that the 30 dwellings proposed within the current application, is the TOTAL number they will permit!

It appears that Castle Point Council have, at least where the HSE is concerned, used the “Canvey is a Special Case” card once too often!

For those with a more sceptical attitude, we suggest the same may also have led to the problems at Buncefield which led to the events recorded in this resident’s video recording below.

Hindsight can be a wonderful thing, but in the meantime Caution may be the better option and it will be interesting to learn how the cpbc Local Plan Inspector views this approach, should the Plan reach the Examination stage and of course to observe the cpbc development committee’s consideration of the proposal.

 Grateful thanks go to Ian Silverstein for use of his video.

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2 responses to ““Dear John” Letter from the HSE to Castle Point Council spells a loss of Trust over Thorney Bay!

  1. Editor
    I think that it may be necessary to highlight some background documentation from which the principles and methodologies of the HSE are based.

    HSE’s Land Use Planning Methodology is based on the following principles:

    The risk considered is the residual risk which remains after all reasonably practicable preventative measures have been taken to ensure compliance with the requirements of the Health and Safety at Work etc. Act 1974 and its relevant statutory provisions.

    Where it is beneficial to do so, advice takes account of risk as well as hazard, that is the likelihood of an accident as well as its consequences.

    Account is taken of the size and nature of the proposed development, the inherent vulnerability of the exposed population and the ease of evacuation or other emergency procedures for the type of development proposed. Some categories of development (e.g. schools and hospitals) are regarded as more sensitive than others (e.g. light industrial) and advice is weighted accordingly.

    Consideration of the risk of serious injury, including that of fatality, attaching weight to the risk where a proposed development might result in a large number of casualties in the event of an accident.

    At the risk of repeating myself most of the required information can be gained from the Calor Gas LPG “SAFETY REPORT”. Safety Reports are required to be prepared so as to consider the following and to assist Local Planning Authorities with their Emergency Planning strategy :-

    “The number of fatalities and individuals with severe burns from fires and explosions should be determined. The effect of blast should also be quantified in terms of the number of buildings in each of several damage categories and the envelope of a flash fire should be superimposed on a map so that the effect of wind direction on the number of casualties can be assessed. The accident analysis should address the effect of other variables such as time of year, time of day and day of the week if they have a significant effect on the off-site possibly by way of unconfined vapour cloud explosion”.

    There are a number of aspects of HSE’s land use planning and major hazards work that HSE’s methodology and HSE’s Planning Advice Web App does not deal with, such as Incremental development around major hazard sites and major accident hazard pipelines

    Where HSE has previously advised against a development (particularly where there is a history of incremental development), or where there has already been a Planning Inquiry into a development, the HSE Planning Advice Web App cannot take account of such matters and it is expected that PAs will take this additional information into account when deciding whether or not to grant planning permission.

    It is therefore imperative that the CPBCs Planning Officers and Committee take into considerations not only the existing level of occupation of static caravans within the middle zone of the Calor Gas LPG storage installation, but also the intention of the Thorney Bay Site operators to remain with the occupation of the whole site post further housing development.

  2. I would presume global warming is all fiction as there is no mention of the scientific data regarding rising sea levels and the greater risk of severe storms in the future years. Then again money before common-sense.Who will take the blame when it all goes wrong.

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