May Avenue, Canvey Island – Flooding Lessons Never Learned by CPBC- or were they never meant to be?

The controversial proposal to develop on a narrow green space in May Avenue, Canvey Island, returned for cpbc development Control committee consideration.

The previous application had been Rejected and on Appeal was upheld by the Planning Inspector.

The problem with cpbc being taken to Appeal over development is the crazy system of officers demanding Reasons for a development’s Rejection immediately the vote has been taken. There should be a process whereby the officers Report including Reasons for Objection is given further consideration before the officers are allowed to sign off their reports.

It is these Reports that stand as the Borough’s case during a written Appeal considered by the Planning Inspectorate and they appear to be practically made up on the hoof!

This time around some members voiced continued concerns, whilst the officer warned against the consequences of again Rejecting the proposal.

In the end a Motion to Defer the decision was Agreed.

One of the main issues MUST be that of the principle of Flood Risk.

No Objection from the Environment Agency, and the Developer indicated that the famed Canvey Integrated Urban Drainage study showed flooding, similar to that of the summer of 2014 would leave the proposed development dry.

Shame the same thing cannot be guaranteed for the Neighbouring Existing May Avenue Properties!

There is an agreed guidance between the Environment Agency and castle point council for small development sites.

Part of this guidance states;

“The National Planning Policy Framework (NPPF) and its supporting Technical Guidance Document set out the Government’s national policy on development in areas at risk of flooding. It seeks, wherever possible, to avoid inappropriate development in areas at risk of flooding. Where it can be demonstrated that development is required in these areas, the NPPF seeks to ensure it will be safe over the lifetime of the development and will not increase flood risk elsewhere and where possible, reduce flood risk”

Developing what is a narrow greensward area between two properties can only add to the pressures on the Canvey Island drainage system.

Replacing a greensward with a bricks and mortar dwelling and driveway will likely increase the Flood Risk to Neighbouring properties, against NPPF requirement.

The cpbc planning officer was dismissive of these concerns stating that the local authority’s position regarding Sequential Testing (where development should take place in less Flood Liable Zones) falls within the usual mantra;

“With regard to the sequential test, the proposal seeks to provide dwellings on Canvey Island. For residential development to serve the community of Canvey Island it is considered that it would need to be located within, or immediately adjacent to, that settlement.
Since the settlement of Canvey Island is located entirely within Flood Zone 3 it is not considered that there are reasonably available alternative sites within the area with a lower probability of flooding that could accommodate the proposed development. Under the circumstances it is considered that the proposal passes the sequential test.”

This is ambiguous! The first paragraph implies that the community of Canvey Island should remain where it is, no migration allowed! Castle Point is one of the smallest Boroughs in England however, no similar concerns are applied to Benfleet, Hadleigh nor Thundersley.

These mainland towns have populations that are barely increasing, and yet they face no similar Flood Risks.

The cpbc New Local Plan Sequential Test for Housing Site Options states;

In order to deliver 200 homes per annum for the period 2011 to 2031 (4,000 homes in total), it is necessary to identify developable sites with a further capacity to accommodate 2,400 homes. Approximately, 500 of these homes will be secured at Thorney Bay Caravan Park, and 99 at the 101 Point Road, Canvey Island. It is expected that redevelopment within the existing residential areas of the borough will secure approximately 380 additional homes in this period also. Therefore, the sequential test will be seeking to identify developable sites with a capacity of 1,421 homes.

Quite clearly, development on Canvey Island is in support of the Borough’s Housing Needs! Therefore this isolationist application of the Sequential Test by castle point council, to Canvey Island alone, has No Justification!

It should be remembered that the National Planning Policy Framework gives Equal Protection to Green Belt land and Land at risk of Flooding;

specific policies in this Framework indicate development should be restricted.9

9 For example, those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion.”

Committee members concerns whether surface water flooding could be prevented by Attenuation Tanks were wide of the mark. Canvey Island has a notoriously High Water Table, create space for a tank below ground simply pushes flood waters higher and wider!

See if these extracts ring any bells, you should all, Canvey Islanders anyway, recognise where these words come from and relate to;

“pumps are the final element of a long, incredibly complex and interlinked surface water drainage system comprising of drains, culverts, sewers, open watercourses, main rivers, pumps and storage areas all with varying capacity, which need to be operating efficiently in order to drain the island. Rainfall on the island may flow a substantial distance before reaching the pumps, through infrastructure owned or managed by a large number of different organisations and individuals and in some cases without a clear understanding of ownership. Any constriction on flow either due to blockage or insufficient capacity for the rainfall event can affect the effective operation of the entire drainage system”

“The pressure on the drainage system on Canvey Island has intensified over the last 50 years due to further development, and it is evident that in some locations some drainage infrastructure is no longer at the necessary capacity to provide sufficient drainage”

” Given the unique nature of the drainage system and the scale of investment needed, to achieve significant results in Canvey Island will require that special support be provided by DEFRA. With this understanding, multiagency cooperation and additional Central Government funding it may be possible to make necessary and feasible improvements to the drainage system and effectively reduce flood risk in some areas.

The population of Canvey Island consisted of 38,459 people back in 2011, and yet cpbc position is that unless the population continues to grow, the Island will become unsustainable.

What utter Tosh!

There are 38,500 people at Risk of Flooding, local agencies have proven they cannot cope should we suffer from Surface Water Flooding, and yet the Local Plan proposal is to put more and more people at Risk!

If that is not what unsustainable development means then I don’t know what does!

The Sequential Test, as adopted by CPBC, is out of date!

The Strategic Flood Risk Assessment is out of date!

The agreement between the Environment Agency allowing Castle Point Council to decide (take responsibility for) the safety of new development over its Lifetime is out of date!

That Canvey is a “Special Case” where development is concerned, is out of date!

The £24,500,000 required to mend the Canvey Island “Broken” Drainage System has never materialised!

The Canvey Green Belt Campaign group maintain the position that the Island’s population should be maintained at the current levels or lower. All planned development on Canvey should be the subject of the Local Plan alone!

The infrastructure cannot cope with more, whilst the Island’s economy is reasonable given the UK’s circumstances. Whilst the Town Centre may be showing some signs of struggling in the more expensive locations, this is not helped by out of town commercial development in the pipeline.

Lessons clearly are not being learned despite assurances from senior officers!

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2 responses to “May Avenue, Canvey Island – Flooding Lessons Never Learned by CPBC- or were they never meant to be?

  1. Zone 3a Flood Plain
    Castle Point Borough Council decision to remove restriction of developing the Zone 3 flood plain of Canvey Island.

    PLANNING COMMITTEE MINUTES
    6TH FEBRUAURY 2007
    PRESENT:

    Councillors Smith (Vice-Chairman who chaired the meeting), Anderson, Cole, Cross, Dixie, E. Egan, Mrs Goodwin, R.C. Howard, Riley and B.S. Wood

    Councillors Mrs Challis Mrs B. Egan, Ladzrie and Mrs Liddiard

    Apologies for absence were received from Councillors Blackwell, Mrs Iles, Sharp and Mrs J.Govier.

    73. PLANNING POLICY STATEMENT 25: DEVELOPMENT & FLOOD RISK

    The Committee was informed and discussed the new amended national policy on development and flood risk set out in Planning Policy Statement 25, published in December 2006 which contained new and amended planning policies to mitigate and avoid the impact of flooding through good planning and flood risk management.

    The Committee had previously commented on the consultation on the draft PPS 25 at the meeting on 7.2.2006.

    The report before the Committee described the structure of PPS 25 which contained five sections covering background; key planning objectives; decision making principles; risk based approach and responsibilities; supported by a further eight annexes.

    Members considered the implications for Castle Point arising from PPS25. The new PPS would have a particular bearing on the work for the Local Development Frame work and on the consideration of planning applications.

    In terms of planning policy work, a strategic flood risk assessment had been prepared for Thames Gateway South Essex authorities and was to be published by Spring 2007. This would help inform the preparation of the Core Strategy by identifying broad locations within Castle Point and other authorities that would be appropriate locations for development.

    In development control and for the purposes of PPS25, Canvey Island was located in Flood Zone 3 (High Probability), because the PPS ignored the presence of existing defences (acknowledged to be some of the most comprehensive in the country). Accordingly the requirement for flood risk assessments to accompany planning applications had also been in place for some time and in particular the application of both the sequential test and the exceptions test.
    Planning Committee – 6th February 2007

    This initially caused difficulties, particularly for smaller scale development, because of the uncertainty over requirements for these assessments and their relevance and applicability to such schemes. However experience had suggested that through discussion with the Environment Agency, developers, agents and landowners were now clearer about, first the requirements of the these tests, but more importantly, secondly, how to carry out development whilst at the same time mitigating the risk associated with flooding through careful design at the application stage.

    Resolved –

    1. That the Committee notes the policy guidance and advice of PPS 25.

    2. That the Committee have regard to the guidance and advice in the preparation of the Local Development Documents and in the consideration of relevant planning applications, in order to achieve the Council’s community priorities and deliver sustainable development.
    Chairman.

    However the Insurance Industry does not share the Councils optimism

    The short term solution Flood Re is a scheme funded by a levy on insurers that reinsures their customers’ flood risk, allowing them to offer flood insurance to those homes at risk at a more affordable price.
    One of the most important aspects of Flood Re is that it provides time for insurers, the government and homeowners to address deficiencies in planning policy, invest in flood defences and improve the resilience of housing stock. The scheme is intended to be operational for 25 years, during which time there will be a role for central and local government, the insurance industry, environmental organisations, housing providers and homeowners in tackling flood risk. After this 25 year period, the Flood Re scheme assumes that improvements in flood resilience, as well as more sophisticated and readily available flood data will leave the insurance industry in a position to offer more affordable cover in a risk-reflective free market.
    Properties built since 2009 are not eligible for Flood Re, which in theory should introduce pressure on planners to fully consider flood risk before new homes are built. However there remains a challenge in ensuring that a new property’s flood risk is properly communicated both to the buyer and the insurance industry, so that both parties can avoid any shocks further down the line.
    As well as providing a period of breathing space for industry and policymakers, Flood Re also intends to provide a point of focus for the next 25 years, to continue the debate about addressing the root of the environmental and planning issues. But the inescapable realities of climate change, coupled with a seeming lack of a long-term approach to investment in flood defence measures means that the success of these ambitious plans is far from guaranteed.

  2. Hate to say it ‘told you so”. Despite refusal for the development at Canvey Supply because the developer couldn’t fulfill the regulations required for development 99 properties are still in the Borough plan. So what has changed since the refusal? The conditions will still have to be met or will they? As this article shows it seems Castle Point Council will do anything to support developers on Canvey, but throw their full weight behind objecting to development on the mainland finding every possible legal reason to oppose it. Time and time again Castle Point Councilors and officers treat the Borough as two separate Boroughs constantly supporting opposition to major development on the mainland, but patently failing to recognise the reasons why major development should not take place on Canvey. Our Councillors have always opposed inappropriate development on the mainland, but seemingly not recipricated by mainland Councillors and in the case of Canvey Supply even let down by two of our East Ward Councillors who voted in favour of it’s development. One has subsequently gone, but Councillor Mumford remains. Canvey East residents should take note.

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