Castle Point Council face Testicular Examination Ahead! Whilst Nuneaton Council act as Local Plan Pathfinders?

Having promised to stand firm over Infrastructure before more Housing, the new Castle Point Borough Council regime will now have their resolve fully tested by the Government’s team sent into the Borough to oversee progress on the Local Plan.

Riley+marchant

Residents, having shown confidence in the Lead group of councillors by giving them an increased majority at the May 2018 local elections, will be expecting them to be able to revive the latest withdrawn Local Plan following 12 months of intensive and “tireless” Duty to Cooperate work following the Examination inspector’s criticisms.

The protection of Green Belt was paramount to Residents concerns, and any backing away from the local authorities position will be open to criticism!

This may be particularly so in the light of promises to overturn the Borough Plan made in another area, Nuneaton, where the successful Conservative group promised to:

“Protect existing communities and deliver the roads, health and school services we need.
 Reduce the housing numbers based on new government guideline figures.
 Withdraw from Labour’s secret agreement to take Coventry’s overspill.” 

“Distribute housing more fairly around the Borough to enhance not destroy existing communities.”
 “Ensure our communities finally receive the much needed road improvements, schools, GPs, shops and essential facilities they deserve, 
 Prioritise Brownfield sites first, protecting our existing communities by removing unsuitable and unsustainable sites from Labour’s broken Borough plan.”

Andrew Lainton, of Decisions Decisions, Decisions blog suggests:

“However the Borough Plan is mid examination with initial findings due to be published this month.

As the inspectors findings are binding the only alternative to fulfill the manifesto would be to withdraw the local plan.

This would put the Council in special measures.” 

The Nuneaton Tory Group’s reference to Unsuitable and Unsustainable sites is interesting and should, but doubtfully will, provoke examination at Castle Point.

The wholesale blanket application of the Sequential Test across Canvey Island would, elsewhere, be expected to be deemed Unsustainable.

In effect despite being a flood Zone 3a, any Housing Development proposed for Canvey Island is deemed appropriate!

This is evidenced in each and every Application paperwork by officers, following councillors instruction, having “persuaded” the Environment Agency that Canvey Island is a Special Case!

An illustration of this, taken from the cpbc Annual Monitoring Report 2016-17 states; “It should be noted that there is no specific policy on flood risk included within the Local Plan (1998 adopted version) and therefore the Council relies on national policy set out in the National Planning Policy Framework and its technical guidance in respect of such matters.

Of course since then the Strategic Flood Risk Assessment has recognised that Canvey Island is at Actual Risk of Tidal Flooding and the Integrated Urban Drainage Study was researched and published following the 2014 Summer Flooding of Canvey Island!

Castle Point councillors, those involved on the development committee at least, appear willing to accept responsibility for future Flooding of housing and danger to residents, whether from Surface Water or Tidal.

So far that has paid handsomely. Over time and following Flood events, that may prove less so, as Housing built since the 1st January 2009 is not eligible for the Flood Re Insurance Protection that makes available affordable insurance.

Should this problem emerge mortgages on “new” builds may well be denied due to insurance issues. New Canvey Island House Buyers may well be walking into this trap unaware.

The development of Canvey Island both Industrial and Housing continues unabated, this will intensify the pressures on the already broken drainage system, and road and health service infrastructures.

The cpbc Annual Monitoring Report also states, “the proportion of new homes provided on previously developed land to remain lower than in earlier years.”

and that, even more worryingly; 

“16 affordable housing units were delivered in Castle Point in 2016/17, representing 14% of total housing provision (114 dwellings). This level of provision is an improvement on the annual average provision for the period 2001 to 2016 of 11.5%,”

An example of the inadequacy of our local authority is illustrated within the cpbc Sequential test documentation to support the first of the local plans, the Core Strategy, in which it was admitted “The Environment Agency met with the Council in 2007 to identify criteria under which they would allow development to proceed on Canvey Island. The final criterion was the need to ensure that the Emergency Planners and Emergency Services were satisfied with the measures in place to ensure safety in the event of a flood.

These services had not been consulted in the preparation of PPS25, and as such this requirement was a surprise to them, for which they were not prepared.

A typical approach by developers to overcome the Constraint on Housing by Flood Risk on Canvey Island and acceptable to CPBC is demonstrated here;

  • “The application site is located on Canvey Island, which is situated entirely within Flood Risk Zone 3a,
  • The Council has undertaken an annual review of Strategic Housing Land Availability (SHLAA) since 2011. This process has consistently indicated the need for a greater supply of housing land to meet the objectively assessed housing needs of the borough.
  • When applying a sequential test it is important to have regard to the local context. Canvey Island is a distinctive community, accommodating 43% of the borough’s population. It has specific identified needs in terms of social, economic and physical regeneration, as well as housing.
  • In order for residential development to serve the community of Canvey Island it is considered that it needs to be located within that settlement.”

The Level of delivery of Affordable Housing and the continued influx of new Residents from outside of the Area onto Canvey Island suggest that “residential development to serve the community of Canvey Island” is simply too broad a sweeping statement intended to be a means of simply granting Planning Permission to bolster the BOROUGH’s Housing Supply in an Unsuitable Location!

It would appear unusual, if not unreasonable, for a local authority to seek to increase the Urban Density by developing Green field land and intensifying Brownfield development,  supposedly under the guise of satisfying the Need of the Canvey Island Community, when in effect it simply intensifies Inward Migration, in an area specifically under the threat of both Tidal and Surface Water Flood Risk!

We eagerly look forward to learn what Resolve, Metal, Determination and hopefully Fairness, the new administration at Castle Point council are able to apply to the ongoing Local Plan process in the shadow of Government Intervention!

local plan.jpg-pwrt3

Like a bad Smell, this just will not Go Away!

The full Decisions Decisions, Decisions post may be read HERE.

Advertisements

2 responses to “Castle Point Council face Testicular Examination Ahead! Whilst Nuneaton Council act as Local Plan Pathfinders?

  1. Steve Sawkins

    Editor.
    What makes CPBC confident that its surface water management plan and present detailed modelling is suitably functional when no revision has been made to consider the significant land raising undertaking on parts of Canvey Island?

    The Planning Authority needs to be confident when passing planning application on a flood zone 3a plus with critical drainage issues, that there will be no further increased flooding elsewhere, for the lifetime of the development.

    The planning committee will also need to be totally confident that new developments are flood resilient and resistant, including safe access and escape routes where required.

    As mentioned residual risk needs to be safely managed including by emergency planning, all of which are key aspects of paragraphs 102 and 103 of the NPPF.

    Planning Guidance clearly identify that Local Authority Planning Committees take full responsibility for flood risk matters and it is assumed that new and old members will be undertaking the appropriate training associated with such matters.

    Planning Guidance warns us:-
    “Proposals that are likely to increase the number of people living or working in areas of flood risk require particularly careful consideration, as they could increase the scale of any evacuation required. To mitigate this impact it is especially important to look at ways in which the development could help to reduce the overall consequences of flooding in the locality, either through its design (recognising that some forms of development may be more resistant or resilient to floods than others) or through off-site works that benefit the area more generally”.

    • Thank you for your comment Steve, however I must query why you feel that “The Planning Authority needs to be confident when passing planning application on a flood zone 3a plus with critical drainage issues, that there will be no further increased flooding elsewhere, for the lifetime of the development”?
      On an Island affected by a High Water Table, made worse by Tidal Waters leeching UNDER the Sea Wall defences, very little is known about the effects of continued Housing and Business Development on Off Site Flood Risk.
      Little Evidence exists and little time is spent discussing and examining the effects development may have during Development Committee meetings!
      The only serious study of the Ground Water situation was not by Castle Point Council, but a Developer!
      Whilst the cpbc Sequential Test remains out dated, pre 2010 cpbc Strategic Flood Risk Assessment AND Canvey island Integrated Urban Drainage study, the development committee have complete freedom to approve ALL development on Canvey Island carte blanche!
      The “professional” officers enforce this approach with a “the Environment Agency have no objection” despite so many of the potential Flooding conditions being the Responsibility of Castle Point councillors!

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google+ photo

You are commenting using your Google+ account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

w

Connecting to %s