Hypocrisy, the Use of Substitutes, a Deciding Vote and a Divided Borough? Sequentially Unsound!

It appeared that what can only be described as a level of Hypocrisy was displayed by certain Castle Point Development Committee members towards a view suggested by the opposition group at the 5th September’s meeting!

The suggestion appeared that Canvey was, put simplistically, being targeted for development so as to protect the mainland areas. It was expressed that Canvey should not be portrayed as an individual area, rather than an equal part of the whole Borough of Castle Point.

However the whole basis of the Flood Risk Sequential Test, as interpreted by Castle Point Council, is to treat Canvey Island in isolation!

“it is considered that continued development is necessary in order that the settlement of Canvey can continue to thrive economically and socially.”

” Canvey needs continued development if it is to continue to thrive economically. A lack of housebuilding on the island could mean that the island stagnates in economic terms which is likely to affect opportunities for employment. “

Indeed the Thorney Bay proposal for 600+ dwellings  was subject to a CPBC Planning Policy statement stating that “the site was identified as having the potential to contribute towards the 5 Year Housing Supply (of the Borough)”!

Regardless of the application being considered, whether for a single unit or a proposal for over 600 dwellings on Canvey Island, it is fairly clear that using this interpretation of the Sequential Test to support development proposals, there is no likelihood of any planning proposal Failing the Test!

It is a convenient and flimsy argument to accuse Islanders of focussing on cpbc’s apparent approach to Canvey development, whilst the Sequential Test is used to do precisely that!

It should be of concern, that since Canvey land was designated for the use of Housing in the 1998 Local Plan, and that since the Sequential Test approach towards its application on Canvey development proposals was adopted by CPBC in 2007, these events have occurred and these Reports have been published;

  • The Pitt Review-Learning Lessons from the 2007 floods. (Published 2008) !!!
  • The CPBC Strategic Flood Risk Assessment published in 2010. (In itself due an Update.)
  • Surface Water Flooding has occurred on Canvey Island during 2013.
  • Surface Water Flooding has occurred on Canvey Island during 2014.
  • Government Office for Science – Canvey Island Section 19 Report
  • The requested Drainage Improvement / Upgrade funding has not materialised.
  • We learned that the land on Canvey Island has a High Water Table, subject to influence by the Tidal Water encroaching Under the Sea Defences. (Land East of Canvey Road document).
  • The Integrated Urban Drainage Study was published, which challenged the credibility of the CPBC Surface Water Management Plan published 2012.

Quite clearly the Castle Point Council approach to the application of the Sequential Test on Canvey Island in isolation, is Obsolete and Unjustified!

Attenuation Tanks were discussed as a means of a suitable drainage system. Had the committee not considered that Canvey has a High Water Table, now known to be subject to Tidal influence? In this case the Tank would be sunk into the application site property, how efficient would this system of drainage be?

Photo Police helicopter 2014

The focus of the drainage system needs to be to prevent off-site flooding of neighbouring property and land. Without going through the exercise of producing a Practical Model on Canvey island and monitoring over an extended period councillors should not be in a position to simply go by unsubstantiated opinion in their decision making!

Whilst the protection of Green Belt, which is admirable, is at the forefront of councillors minds, it must be borne in mind that Paragraph 14 of the national Planning Policy Framework contains Footnote 9, which indicates;

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

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.

Whilst this specifically relates to Plan making, it is clear that, if the concern is present amongst decision makers development in a Flood Zone and in a Critical Drainage Area, in which Canvey Island falls into both categories, caution should be the operative position to adopt.

Residents suffering the Canvey Island Flooding of 2013 and 2014 may well feel appalled at the rigid Rejection of development applications on Green Belt, whilst a less than cautious approach appears to be adopted where Flood Risk is concerned, by certain cpbc development committee members.

The cpbc officer appeared unaware that the whole of Canvey Island is a Critical Drainage Area.

The questionable use of Substitute councillors to replace two absentees at the meeting, bearing in mind the technical issues highlighted in this planning proposal, proved to be decisive, as 1 voted to Approve and 1 voted to Abstain.

With the votes recorded as 5 to Approve and 5 Against, with 2 Abstentions, the Chairman chose to use his Casting Vote, and consequently rather than holding further deliberations on the subjects contained within this post and others not mentioned, the Application was Approved!


3 responses to “Hypocrisy, the Use of Substitutes, a Deciding Vote and a Divided Borough? Sequentially Unsound!

  1. Extract from the Essex County Council Flood Investigation Report for Roggel Road Canvey Island.

    Roggle Road is in the same location of the May Avenue planning application .

    “The location for the flood investigation falls within an area identified by the South Essex SWMP as a Critical Drainage Area which may suffer flooding in severe weather. Figure 2 demonstrates the predicted locations of flooding during a 3.3%, 1% and 0.1% probability storm events. The modelling indicates that some areas of Roggel Road and the surrounding roads may experience significant and widespread flooding in all events and the overall area has a high level of underlying flood risk”.

    SWMP – Surface Water Management Plan.

    Apparently this has no bearing on planning applications in this area.

    CPBC Emergency Response Plan September 2017 tells us that:-

    Castle Point Borough Council does not currently have an emergency plan for responding to severe weather
    And that;
    The Council does not provide sandbags to privately owned properties

    Castle Point Borough Council has a specific Flood Response Plan which details how the Council monitors and responds to flooding incidents that affect the borough.

    There is also a Multi-Agency Flood Plan, owned by Essex County Council, which details how different emergency responders will work together in response to flooding anywhere within Essex.

    Council resources and personnel would be required to assist in the clear-up operation including, clearing debris from roads, disposing of household waste and provide emergency shelter and accommodation for those made homeless.

    The spirit of the NPPF is to prevent development on flood plain. CPBC Sequential Test application achieve exactly the opposite when actually supporting putting people and property at risk.

  2. Editor
    Although from the outdated Surface Water Management Plan still being used by CPBC for New Local Plan evidence, this seems a reasonable workable process from which to base the updated version.

    Ongoing Monitoring

    “The partnership arrangements established as part of the South Essex SWMP process (e.g. the SWMP working group of Basildon Borough Council, Castle Point Borough Council, Rochford District Council, Essex County Council, Environment Agency, and Anglian Water working in collaboration) should continue beyond the completion of the SWMP in order to discuss the implementation of the proposed actions, review opportunities for operational efficiency and to review any legislative changes.

    The draft Action Plan should be reviewed and updated once annually as a minimum, but there may be circumstances which might trigger a review and/or an update of the Action Plan in the interim, for example:

    x occurrence of a surface water flood event;
    x additional data or modelling becoming available, which may alter the understanding of risk within the study area;
    x if the outcome of an investment decision by partners is different to the preferred option, which may require a revision to the action plan,
    x additional (major) development or other changes in the catchment which may affect the surface water flood risk”

    This all sounds good on paper unfortunately never acted upon so that the CPBC Sequential Test approach could remain unchallenged.
    The fear of appealing a planning application based on flood risk if lost could leave the council facing costs of up to £10,000.
    However the fear of winning a planning appeal based on flood risk is that CPBC planning authorities strategy for saving its Green Belt by developing flood plain, would be seriously questioned.

  3. Can somebody please explain to me how given that approvals should only be given on class 3 flood plain when there are no other sites available does this council continue to do so on Canvey Island when there are clearly sites available on the mainland that satisfy the crtieria. How can CPBC get away with only taking Canvey into consideration when they are the Planning Authority for the whole borough and should therefore consider the whole of Castle Point when deliberating on planning applications. They have no remit and no right to make judgement on individual geographical elements that lie within their jurisdiction.

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