Thorney Question of Over-developing a Small Island in Castle Point!

Given that there is a possibility Canvey Island may suffer another Tidal Flood, given that we may again suffer from Surface Water Flooding as in 2013 and 2014, given that there may be another leak of LPG from Calor Gas, given that OIKOS have been granted permission by CPBC to increase activities in the importation, storage and blending of butane, and however small the risks, should not the Distribution of Housing Growth as imposed by Castle Point Borough Council (cpbc) be called into serious Question? *

Already there are over 38,500 residents on Canvey Island. If there were to be a major incident from just one of these four sources, an Evacuation of the Island, given the population level, the lack of access / egress routes and there being No Means of Warning, would be an impossibility. Is it time to cap the population level? We believe it is!

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Rather than accepting these “dangers” the powers that be at cpbc, appear to have their eyes and ears covered to blot out the concerns of the population on Canvey Island exposed to possible incidents in the desire to offset Housing and Business development away from the controlling mainland part of the Borough. Little wonder there is an active group hoping to convince the Boundary Commission to leave the Borough’s borders alone!

The denial of Climate Change, the absolute faith in our sea defence, the faith in the “hard work” undertaken to “maintain” the Island’s drainage system and the assurances from the two Top Tier COMAH sites, amount to little more than roll off the tongue Platitudes!

We stand accused of scare-mongering, then so be it!

We call it living in the Real World and “facing” realities. Fore-warned is Fore-armed.

Canvey’s highway infrastructure is restrictive, all routes converging at Waterside Roundabout, meaning evacuation is impossible and our limited Fire and Rescue cover means response times for assistance are likely to be prolonged.*

Green Belt is protected in planning terms by the Very Special Circumstances needed before the consideration of any development proposal.

Consider that, against a development proposal within a Flood Risk Zone and within the Consultation Distance of a Major Hazard site!

This is what requires not only for planning considerations, but also leading council members and officers to consider their consciences, with the proposal to develop 113 dwellings at Thorney Bay, Canvey Island.

This is only the first phase of a major development consisting of “approximately 600 dwellings” plus “Park Homes.”

The cpbc planning portal indicates that the developer may have overcome, to cpbc’s satisfaction, the requirements of the HSE, the Environment Agency and Essex County Council, the surface water drainage experts.

However these agencies lifting of Objections should not be seen as them giving their Approval!

In fact their concerns indicate that they Do Not Rule Out the Possibility of one or other Incidents occurring in the Future!

Within their comments they give very distinct warnings and concerns and indicate quite clearly the final decision and the Responsibility is Castle Point council’s ALONE!

Below are a few of the consultee agencies points of concern over the Thorney Bay proposal and further below are links to some previous incidents etc of some interest.

The Environment Agency state;

Our role is to provide you with our assessment of the risk for matters within our remit so that you can make an informed decision

“The FRA (flood risk assessment) proposes no detriment in off-site flood hazard for the design and extreme floods and manages this via a proposed embankment, subject to condition.”  Approval of the design of the proposed embankment is therefore necessary as a pre commencement condition, as the embankment is essential to safeguard against the offsite impacts. Without the construction of the embankment off site impacts would be seen

Provided you consider the development meets the requirements set out in the NPPF, including that it is safe for its lifetime and does not increase the risk of flood risk off site, we request that the following conditions are appended to any permission granted. Without these conditions our objection will be maintained.

Flood Risk Responsibilities for your Council    

We have not considered the following issues as part of this planning application as they are not within our direct remit; nevertheless these are all very important considerations for managing flood risk for this development, and determining the safety and acceptability of the proposal. Prior to deciding this application you should give due consideration to the issues below. It may be that you need to consult relevant experts outside your planning team.     

Safety of the building 

 Safety of People (including the provision and adequacy of an emergency plan, temporary refuge and  rescue or evacuation arrangements) 

Flood recovery measures (including flood proofing and other building level resistance and resilience measures) 

Whether insurance can be gained or not

Sustainability of the development – we advise you consider the sustainability of the development over its lifetime.

Your attention is brought to the proposed Roscommon Way Extension that is likely to pass immediately to the south of this proposed development site. Consideration is required of residual tidal flood risk at a master planning level to evaluate if further proposed phases of the Thorney Bay caravan park development could become less deliverable, unless suitable mitigation measures are identified and designed, with regards to breach characteristics – mainly depth, time to inundation and hazard ratings. Future proposed Flood Risk Vulnerability Classification will need to be considered alongside the residual tidal flood risks to ensure a sequential approach to future site layout is maintained.

 

ECC Lead Local Flood Authority position;

Having reviewed the Flood Risk Assessment and the associated documents which accompanied the planning application, do not object to the granting of planning permission.

Condition 1

 No works shall take place until a detailed surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development, has been submitted to and approved in writing by the local planning authority. The scheme should include but not be limited to:

  • Final modelling and calculations for all areas of the drainage system.
  • A final drainage plan which details exceedance and conveyance routes, FFL and ground levels, and location and sizing of any drainage features.

Reason:

  • To prevent flooding by ensuring the satisfactory storage of/disposal of surface water from the site.
  • To ensure the effective operation of SuDS features over the lifetime of the development.                 
  • To provide mitigation of any environmental harm which may be caused to the local water environment                                                                                                                                                            
  • Failure to provide the above required information before commencement of works may result in a system being installed that is not sufficient to deal with surface water occurring during rainfall events and may lead to increased flood risk and pollution hazard from the site.

Condition 2

 No works shall take place until a scheme to minimise the risk of offsite flooding caused by surface water run-off and groundwater during construction works and prevent pollution has been submitted to, and approved in writing by, the local planning authority.

Reason

 The National Planning Policy Framework paragraph 103 and paragraph 109 state that local planning authorities should ensure development does not increase flood risk elsewhere and does not contribute to water pollution.

 Construction may lead to excess water being discharged from the site. If dewatering takes place to allow for construction to take place below groundwater level, this will cause additional water to be discharged. Furthermore the removal of topsoils during construction may limit the ability of the site to intercept rainfall and may lead to increased runoff rates

Health and Safety Executive state;

More than 10%of the housing development lies within the middle zone, – through the HSE Planning Advice Web App advised Against the granting of Planning Permission.

However, having given more detailed consideration, HSE has concluded that it is appropriate for HSE to provide case-specific advice on this proposal outside of the codified planning methodology provided.

The layout indicates that a total of 30 dwellings at a housing density of 38 dwellings per hectare within the middle zone.

HSE’s advice is that significant housing should be prevented from being built in the inner zone and only a limited number of houses at a low density.

The overall objective is to maintain the separation of incompatible development from the Major Hazard.

HSE would advise Against any planning application which seeks to locate any additional dwellings within the middle zone of Calor Gas Ltd.

Instead of using the HSE Planning Advice Web App, Castle Point Borough Council should therefore consult HSE directly for advice on any future planning applications which propose further residential development at Thorney Bay Park within the middle zone of Calor Gas Ltd.

*Below are links to;

*Reduction in Essex Fire and Rescue Service cover view HERE

*Calor Gas Leak court decision view HERE

*OIKOS permission granted view HERE

Editor. It should be pointed out that any emphasis included in the text is the author’s.

 

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One response to “Thorney Question of Over-developing a Small Island in Castle Point!

  1. What is Residual Risk?

    Residual risk is that remaining 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, which 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.

    Consideration needs to be taken 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.

    Everyone can make errors no matter how well trained and motivated they are, however in the workplace, the consequences of such human failure can be severe. Analysis of accidents and incidents shows that human failure contributes towards almost all accidents
    .
    Many major accidents e.g. Texas City, Piper Alpha, Chernobyl, were initiated by human failure
    .
    There is no guidance from the courts as to whether societal concerns should be taken into account by duty holders when deciding what is grossly disproportionate when considering their safety regimes.

    It is imperative that Hazardous Substance Authorities (HSA) when deciding whether to propose regulations, or in setting enforcement priorities, prior to granting Hazardous Substance Consent (HSC) considers that risk and consequence must be assessed in its social context.

    The (HSA) as well as taking account of societal risk, should also prior to granting HSC consider its societal concerns
    .
    The contents of Major Hazardous sites Safety Reports would go some considerable way to assisting Local Authorities, such as CPBC, when considering the appropriateness of developments by knowing the possible consequences of a major accident.

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