Smallgains, the next Canvey Green Space Land Grab! Back Office decision highlights Flood Risk Denial in Support of targeting Housing developments onto the Island!

Despite officer reassurances that a Precedent had not been set, when a small grass “walkway” on Canvey Island was handed over to a “developer”,  CPBC planning portal reveals that a similar proposal, adjacent to 96 Smallgains Avenue, Applic. No. 18/0475/FUL,  has also been approved, this time via a delegated decision by Castle Point officers.

Why this never came before the development committee to discuss we can only wonder, especially as the proposal is for a miserably small 3 bedroomed dwelling!

The officer report describes the land, “The application site is a ‘green road’, examples of which are found across Canvey Island. These are former roads which have been closed to vehicular traffic, usually in the 60s and 70s.
Although long since closed to vehicular traffic, the land provides a pedestrian link between Giffhorn Road and Smallgains Avenue.”

This delegated decision is based on the “precedent” that all similar plots on Canvey Island are now available for Land Grabbing, first in gets First Dibs. What a wonderful Freebie for potential developers.

The officer report also discloses another anomaly, that of the way that Castle Point council “apply” the Sequential Test, in regard to Flood Risk, within the Borough.

I use the terms “apply” and “test” in the most loosest sense of the word!

In reality Castle point council’s approach to the application of the Sequential Test on Canvey Island development proposals, really does warrant some close examination.

The local authority’s position on the application of the Sequential Test is clearly politically motivated. The position was adopted, not by Full Council, but as a small item during a Development Committee meeting.

This meeting and the adoption of the approach to Sequential Testing for Flood Risk, was also, prior to the Strategic Flood risk Assessment 2010, the 2013 and 2014 Summer Floods, and has not been reviewed since!



In fact even more development is considered to be required, to actually sustain Canvey Island from so called “social and economic blight”.

This approach leads to carte blanche development approval by officers and the Lead Group on the development committee, whether the development proposal is for a single dwelling, a medium sized development or a large development!

Let’s consider what the NPPF and Government Guidance informs and instructs:

Applying the Sequential Test in the preparation of a Local Plan.

As some areas at lower flood risk may not be suitable for development for various reasons and therefore out of consideration, the Sequential Test should be applied to the whole local planning authority area to increase the possibilities of accommodating development which is not exposed to flood risk.

More than one local planning authority may jointly review development options over a wider area where this could potentially broaden the scope for opportunities to reduce flood risk and put the most vulnerable development in lower flood risk areas.


Paragraph 158. The aim of the sequential test is to steer new development to areas with the lowest risk of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding. The strategic flood risk assessment will provide the basis for applying this test. The sequential approach should be used in areas known to be at risk now or in the future from any form of flooding.

And yet whether an application for development is Miniscule or Large, Sequential Testing on Flood Risk grounds on Canvey Island by Castle Point council reveals the same Approval Result!

Take these Applications as examples of the decidedly unscrupulous means that development on Canvey Island is promoted, pursued and decided!

Land Adjacent 96 Smallgains Avenue 18/0475/FUL  1 Dwelling House

8.29. The whole of Canvey Island is located in Flood Zone 3A. As Canvey Island is a self contained community with continued development needs, it is considered that there are no sequentially preferable sites available, and the proposal passes the sequential test

Application for 27 Dwellings, Canvey Island

“Since the settlement of Canvey Island is located entirely within Flood Zone 3 it is not considered that there are reasonably available 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.”

Application for 600 Dwellings and Residential Institution, Canvey Island

Regarding the Sequential Test, “The wider sustainability benefits to the community of Canvey Island have been discussed, as part of the Sequential Test. Its continued development is necessary to sustain the local community and prevent the social and economic blight of this settlement.”

With regard to Sequential Testing of Business premises across the Roscommon Way area, in support of the expansion of Charfleets estate and Morrisons and the new Business Park sites etc, despite the unknown effects of built development on the drainage issues in this and across the rest of Canvey Island, the Sequential Test is considered to have been passed.

Despite the identification, through cpbc’s own Local Plan report evidence, of Business premises need and the better siting of such facilities being in the northern parts of the Borough.

The cpbc Sequential Test methodology is leading to population “Growth” for “Growths” sake, and Housing to offset the Borough’s Needs.

There is absolutely no evidence, nor remote chance, that cpbc and local Responders would be able to tend to the current population of Canvey Island in an Emergency. Proof of which was exposed during the 2014 Summer Floods failure to respond by the local authority and their “agencies”!




5 responses to “Smallgains, the next Canvey Green Space Land Grab! Back Office decision highlights Flood Risk Denial in Support of targeting Housing developments onto the Island!

  1. With this seemingly irrefutable evidence of total incompetence has this group not considered an official complaint to the ombudsman?

    • Stan, Thanks for your input. CPBC work carefully within Gov. guidance and can point to the fact that all decisions are made democratically. Any complaint to the LG Ombudsman would likely end in failure.

      • Even though the sequential test should be applied to the whole borough of Castle Point and not just Canvey as is shown to be their want in the statements you have highlighted?Plus if planning applications are being approved under delegated powers by the officers how can that be a democratic decision?

  2. Editor
    Viable concerns of local residents and the Canvey Island Town Council, highlighted below, were just dismissed by the Planning Case Officer when using his delegated powers.

    Exactly:- How did this planning application fail to be “called in” for the consideration of the Planning Committee.? So that these issues could be discussed.

    “Overdevelopment of the site.
    Over dominance to the adjacent properties.
    Existing drainage issues along the entire length of Smallgains Avenue.
    Adverse impact on the existing residential area due to insufficient parking provision
    Members raised concerns that the current use of site as indicated in section 14 of the application was no longer allocated as a public right of way for Highway from the 14th September 1970 and has remained a grass area with bollards either end”.

    Astonishingly CPBC have refused to use flood risk evidence to support its argument, for not delivering its Objectively Assessed Housing needs. The compelling fact is that development on Canvey Island in the longer term is, without intervention, completely unsustainable.

    The Environment Agencies status as a statutory consultee is quite restrictive, however seemingly having concerns as to how CPBCs planning process considers flood risk and without the statutory duty to do so the agency has constantly warned CP of pending flood risk issues.

    The following is an example of some of the EAs response to this application :-

    “The below issues are not within our remit, and therefore must be considered by yourself before determining the application.

    TE2100 Plan
    The Thames Estuary 2100 (TE2100) Plan was published in November 2012, setting out our recommendations for flood risk management for London and the Thames Estuary through to the end of the century and beyond.
    This site is located within the Canvey Island unit, which has a policy of “P4”. Policy P4 is to take further action to keep up with climate and land use change so that flood risk does not increase (Page 44 of TE2100 Plan).

    The TE2100 Plan is an aspirational document, rather than a definitive policy, so whether the defences are raised in the future will be dependent on a cost benefit analysis and the required funding becoming available.

    If the defences are able to be raised, the proposed development will be protected from flooding during the 1 in 1000 annual probability event in line with climate change.

    When determining the safety of the proposed development, you should take this uncertainty over the future flood defences and level of flood protection into account.

    This may require consideration of whether obtaining the funds necessary to enable the defences to be raised in line with climate change is achievable”

    (Why is this warning being ignored as a material consideration for the boroughs Local Plan )
    Reason :- It does not protect the mainland from development.

    “Other Sources of Flooding”

    “In addition to the above flood risk, the site may be within an area at risk of flooding from surface water, reservoirs, sewer and/or groundwater. We have not considered these risks in any detail, but you should ensure these risks are all considered fully before determining the application”

    (Where is the funding for the resolution of Critical Drainage problems )

  3. Editor
    The Fire Authority are statutory consultees that consult with Local Authority Building Control with regards to access and water supplies.
    I notice that CPBC planning officers are reluctant to ask for a comment on planning applications with regards to emergency planning for Canvey Island. Given the following probably explains why.

    A previous response from the Essex County Fire & Rescue Service to a planning application mentioned that it was committed to protecting people of Essex and always endeavour to respond to flooding emergency based on risk assessed approach.
    The comment went onto say that due to limited availability of specialist water rescue resources during flooding incidents, on recent previous occasions had to limit operational response to life threatening situation only.
    It would therefore be difficult for the ECFRS to support a planning proposals that are likely to increase a flood risk situation or add to the volume of calls received.

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