Category Archives: Flooding

Essex County Council Community Resilience Plans + Persons at Risk Register = Canvey Island, Do it Yourself!

Essex County Council website appear keen that residents and Parish councils should compile their own Community Resilience Plans.

Following the example of the failure of Essex County Council, Castle Point Council and the Environment Agency to respond adequately during the 2014 summer Flooding on Canvey Island, perhaps ECC have a point!

However as a group, we have long suggested that a local Persons at Risk Register should be compiled.

The logistics of forming such a Register is, no doubt, a daunting prospect, however  opportunities are available, either during the 10 year Census or the annual mailing of the Council Tax demands, when an extra questionnaire could be distributed.

Responses could be compiled to give an idea of the numbers and locations of those people less able and most in need of assistance during an Emergency on Canvey.

With the high number of population residing on Canvey Island, and the possibility of an Emergency situation arising from either the 2 Hazardous Industrial sites, Surface Water Flooding or Tidal Flooding, any Persons at Risk Register would prove to be an asset in the right hands!

Essex County Council suggest that this is not about doing the job of the Emergency Services or Local Authorities, nor should it be, given the Local Authorities abject failure during 2014!

However this level of buck passing onto local communities misses a couple of points. Local Authorities and associated agencies are either paid for, or elected by, the same local communities. Individual actions should not take the place of the joint action force that is expected to be better prepared and be better able to carry out a planned and practiced for emergency operation to protect residents.

It may be viewed by some that, should such local community information data base be collated by resident groups, the personal information required could breach confidentiality limits.

So on the one hand we have Local Authority agency partners who have still Lessons to be Learned and failing us, and on the other hand an ageing population.

Whilst looking out for the frail, elderly and less able in our neighbourhoods should be a natural course to undertake,  something on the scale suggested should be organised on a far larger scale by an authority with better resources.

Still at least Canvey has one of the closer communities compared with some parts of the Country, a First Responders group and a Town Council, which should mean that once this initiative is exposed as simply a compliance paper exercise by ECC to fulfil their obligations, should anything untoward occur, given the three potential sources of Emergency on the Island, help may be at hand!

Essex County Council have posted on their website;

Why should my community have an Emergency Plan? 

Emergencies are rare, but they can happen.  In the last few years, Essex has experienced severe winter weather, flooding, travel disruption, fuel shortages and a flu outbreak.  Challenges like these can affect our daily lives.

The good news is that communities can prepare themselves for emergencies and it can make a big difference to how people can cope.  When we talk about communities, it can be any group of people, a parish or ward, area or any other group of people.

More resilient communities:

  • Are aware of the risks that may affect them and how vulnerable they are to those risks
  • Use their existing skills, knowledge and resources to prepare for, and deal with, the consequences of an emergency
  • Understand who are the most vulnerable people within their community, who may need extra assistance
  • Can work together to complement the work of the emergency services and Local Authorities before, during and after an emergency

This isn’t about doing the job of the emergency services and Local Authorities.  It’s about supporting your community, and those in it, by making sensible preparations and using the skills and knowledge that the community has.

Castle Point Borough Council’s Emergency Advice can be found HERE.

Canvey Island, the Development “Special Case” and Castle Point Council Failings!

Of late there have been reasons enough to query the sense in planning to over populate Canvey Island!

Following the “disputed” moratorium of housing development on Canvey, blamed upon the Environment Agency, a successful bid for Canvey Island to be viewed as a “Special Case” was launched.

Below follows the Castle Point committee meeting minutes whereby this cautious approach was over-turned and afterwards comes comment on the possibility of people investing in new properties with the danger of experiencing extremely high flood risk premiums or even finding themselves unable to secure flood risk cover at all.

We conclude with some Planning guidance that may suggest that development on Flood Zones and indeed in the Green Belt could, indeed should, be avoided.

We hope you find this locally enlightening.

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

PLANNING COMMITTEE MINUTES
6TH FEBRUARY 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.

Planning Guidance tells us that when :

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”.
The latest Castle Point Local Plan failed the Duty to Cooperate requirement. The Examining Planning Inspector noted in his failure Report:

Indeed, the officer report of July 2014 which set out the full document representations on the draft New Local Plan (CP/05/008) includes the following as an action point:

Given that the Council has not been able to identify a sufficient supply of housing to meet its objectively assessed needs, it is also necessary to engage with neighbouring authorities under the auspices of the Duty to Cooperate in order to determine how the objectively assessed need for housing, and other strategic matters, will be addressed within the housing market area.

However, notwithstanding the lengthy and detailed engagement across south Essex there is no formal mechanism in place to distribute unmet housing need.

The problem is that this is once again only guidance and we have often been reminded by CPBC planning officers of this fact when they deliberate on planning proposal for Canvey Island.
It would seem that any guidance that has not been fulfilled can be ignored, as far as Canvey Island is concerned, as it is only for consideration purposes.

Perhaps Canvey Islanders should also be prepared to “Get their Feet Wet”!

Canvey Islanders may be interested to note that Castle point Council are not the only local authority with councillors happy to Risk their residents safety and well-being by “chancing” future Flooding Event possibilities.

The myth of Canvey residents having webbed feet may be useful, should there be an inter-breeding programme organised with the Weymouth and Portland residents!

With the type of decision making, reported below, the possibilities for Castle Point councillors, with their Canvey Island is a “Special Case” attitude, Flood Zone development could be taken to a completely different level of Housing Delivery!

Floods 2014 eastways

Caroline Lewis reported for the Dorset Echo;

Councillors have voted against recommendations and granted the build of eight new homes – despite major flood concerns.

Weymouth and Portland Borough Council’s planning committee voted to approve the build of eight ‘chalet style’ bungalows on a site on Littlemoor Road despite the Environment Agency (EA) recommending it to be refused.

The EA recommended rejection based on flood risk to prospective occupiers and insufficient proof the build would not worsen flooding elsewhere.

Councillors have voted against recommendations and granted the build of eight new homes – despite major flood concerns.
Weymouth and Portland Borough Council’s planning committee voted to approve the build of eight ‘chalet style’ bungalows on a site on Littlemoor Road despite the Environment Agency (EA) recommending it to be refused.
The EA recommended rejection based on flood risk to prospective occupiers and insufficient proof the build would not worsen flooding elsewhere.

He said that if the committee rejected this build, they would have to reject any other developments in the area.
He added: “It might be that people in a hundred years will have to get their feet wet. I am sure they will be able to wade through the half a meter of water to get to safety.”
Cllr Colin Huckle said he would be quite happy to put his vote behind the project subject to conditions.
He added that he would be surprised if the site flooded as it had not flooded before.
Mr Holme said the agencies flood predications accounted for climate change and although the site had not yet flooded it was not safe to say that it would not in the future.
Cllr Kevin Brookes raised concerns that the rejection of the application would stop anything in the area being changed in the future.
The committee voted to grant the application with conditions with only Cllr Mark Tewkesbury voting against.

Conditions set included a permeable car park, raised electric sockets and usual flood resilience measures be put in place.

They also agreed that the ground floor level would be elevated to 300mm above the highest anticipated flood level in the next century to fall in line with environment agency rules.

Cllr Wheller stated the committee believed because the properties were chalets, in the event of a flood there were adequate escape routes.

After the meeting Raymond McIntyre chairman of Devon and Dorset Properties said: “We hear councillors saying, ‘oh not another block of flats on Preston Road’. We are trying to do something different and imaginative.”

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!

RECOMMENDATION, – CAUTION! No, the Continued Development of Canvey is Necessary!

In March, this year, Castle Point Borough council cabinet addressed what at the time was one of the hottest topics facing the UK. Termed by our own government as our “broken housing market” invitations went out to consultation on the white paper.

Little can be found, via a general internet search, of castle point council’s response.

Following the “successful” approval of 113 dwellings on Canvey Island, 30% of which fall within what is known as the Calor Gas Hazardous middle zone by the development committee, we were soon all feeling appalled at the scenes of disaster at Grenfell House in Kensington.

Whether it is correct to connect any possible similarity between poorly located housing and a disaster through whatever reasons that come to fruition in a tower block, may be arguable.

However an early suggestion as to the tragedy at Grenfell House suggests “the organisations responsible for maintaining standards in the building industry have been advising contractors not to take the regulations too literally.”  *

Whilst this claim requires some substantiation, the application of the Environment Agency and the Health and Safety Executive’s advice where Canvey Island development is concerned, as applied by Castle point council, equally is in need of some serious scrutiny!

We, ourselves are used to being called scaremongers, but quite possibly so were some concerned residents near Buncefield, and those users reliant of the rail line through Dawlish, where the section of sea wall collapsed under the rail track in 2014, may have also been grateful of a more cautious approach to safety.

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Damage to the railway at Dawlish in Devon

The lack of brownfield land in Castle Point is obvious. It is also reasonable to expect Green Belt to be protected.

However Canvey Island is subject to perverse considerations by Planning Officers, no doubt instructed from above, or to put another way, from back offices and corridors!

Housing on Canvey Island must pass the Sequential and Exception Test (Look it Up yourself!)

This allows development in areas that NOBODY can guarantee safe for the development’s lifetime. You would have to be Psychic!

The excuse, sorry, reason, given is:

“In a very broad sense the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement.”

Strange, I have never heard or seen any concern of social and economic blight used to support a Reason to Support development where the mainland is concerned! Remember Deanes School??

But Canvey, don’t forget, is a “Special Case!”

Soon a Brownfield site list of local authority owned land will be compiled, just imagine it; the Paddocks, Canvey police Station, the old council building now Health Centre Long Road etc etc.

It is clear why Canvey is so often selected for development over mainland.

The Island is unsustainable as it is, so to it will be argued is the mainland, but Canvey is the council’s preferred choice.

On 7th February 2017, the Government published a White Paper concerning housing related matters, entitled “Fixing our broken housing market”.

Cabinet Agenda Item7a March 2017:

CPBC intention to respond to “Fixing our broken housing market” Government Consultation on Housing White Paper

The report identifies the problem as threefold – first, not enough local authorities plan for the homes needed, secondly house building is too slow, and thirdly the house building industry is too reliant on a small number of large concerns.

4.4 The report then analyses these issues and brings forward proposals to address them in four chapters;

  1. Planning for the right homes in the right places
  2. Building homes faster
  3. Diversifying the market
  4. Helping people now

Chapter 1 – Planning for the right homes in the right places – brings forward eight proposals;

“Maintaining existing strong protections for the Green Belt, and clarifying that Green Belt boundaries should be amended only in exceptional circumstances when local authorities can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirements;”

“Giving communities a stronger voice in the design of new housing to drive up the quality and character of new development, building on the success of neighbourhood planning”

“Making more land available for homes in the right places, by maximising the contribution from brownfield and surplus public land, regenerating estates, releasing more small and mediumsized sites, allowing rural communities to grow and making it easier to build new settlements;”

In addition to those general comments the Cabinet is recommended to allow more detailed responses to the 38 questions posed by the White Paper to be issued by the Chief Executive in consultation with the Leader of the Council by the deadline of Tuesday 2nd May 2017.                        (abridged version)

Given cpbc’s previous History where development is concerned, we are left to wonder how seriously the government will take our local authority’s consultation responses. As I have said previously, a quick search for cpbc’s official response fails to be found.

*BBC Newsnight Policy Editor Chris Cook.

Photo: Network Rail Media Centre

Wake Up Canvey Islanders, decision making by those unaffected, could cost you Dear!

“You may wish to pretend that rising seas are a hoax perpetrated by scientists and a gullible news media.

Or you can build barriers galore.

But in the end, neither will provide adequate defence, the Dutch say.”

During a time when it has never been made more clear of the responsibilities poorly thought out advice and decision making by local authorities will eventually lead to the scrutiny such decision making deserves, a clear message, during this dry warm spell is issued via an article in the New York Times. So, those cpbc decision-makers claiming to be “living in the Real World,” climate change denyers, bent on over-crowding Canvey Island, take note of those living behind THE best sea defences in the World!

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“From a Dutch mind-set, climate change is not a hypothetical or a drag on the economy, but an opportunity. While the Trump administration withdraws from the Paris accord, the Dutch are pioneering a singular way forward

It is, in essence, to let water in, where possible, not hope to subdue Mother Nature: to live with the water, rather than struggle to defeat it. The Dutch devise lakes, garages, parks and plazas that are a boon to daily life but also double as enormous reservoirs for when the seas and rivers spill over. You may wish to pretend that rising seas are a hoax perpetrated by scientists and a gullible news media. Or you can build barriers galore. But in the end, neither will provide adequate defence, the Dutch say.

And what holds true for managing climate change applies to the social fabric, too. Environmental and social resilience should go hand in hand, officials here believe, improving neighbourhoods, spreading equity and taming water during catastrophes. Climate adaptation, if addressed head-on and properly, ought to yield a stronger, richer state.

This is the message the Dutch have been taking out into the world. Dutch consultants advising the Bangladeshi authorities about emergency shelters and evacuation routes recently helped reduce the numbers of deaths suffered in recent floods to “hundreds instead of thousands,” according to Mr. Ovink. Mr. Ovink is the country’s globe-trotting salesman in chief for Dutch expertise on rising water and climate change.

“That’s what we’re trying to do,” he said. “You can say we are marketing our expertise, but thousands of people die every year because of rising water, and the world is failing collectively to deal with the crisis, losing money and lives.” He ticks off the latest findings: 2016 was the warmest year on record; global sea levels rose to new highs.

He proudly shows off the new rowing course just outside Rotterdam, where the World Rowing Championships were staged last summer. The course forms part of an area called the Eendragtspolder, a 22-acre patchwork of reclaimed fields and canals — a prime example of a site built as a public amenity that collects floodwater in emergencies. It is near the lowest point in the Netherlands, about 20 feet below sea level. With its bike paths and water sports, the Eendragtspolder has become a popular retreat. Now it also serves as a reservoir for the Rotte River Basin when the nearby Rhine overflows, which, because of climate change, it’s expected to do every decade.

The project is among dozens in a nationwide program, years in the making, called Room for the River, which overturned centuries-old strategies of seizing territory from rivers and canals to build dams and dikes. The Netherlands effectively occupies the gutter of Europe, a lowlands bounded on one end by the North Sea, into which immense rivers like the Rhine and the Meuse flow from Germany and France. Dutch thinking changed after floods forced hundreds of thousands to evacuate during the 1990s. The floods “were a wake-up call to give back to the rivers some of the room we had taken,” as Harold van Waveren, a senior government adviser, recently explained.”

“We can’t just keep building higher levees, because we will end up living behind 10-meter walls,” he said.

“We need to give the rivers more places to flow.

Protection against climate change is only as strong as the weakest link in the chain, and the chain in our case includes not just the big gates and dams at the sea but a whole philosophy of spatial planning, crisis management, children’s education, online apps and public spaces.”

Extract from New York Times. Link to complete article;  https://www.nytimes.com/interactive/2017/06/15/world/europe/climate-change-rotterdam.html?_r=0

Fair Play for Canvey Island in the light of the Jotmans Decision or are we still a “Special Case”?

And the Necessity for Castle Point Borough Council to produce a Local Plan is?

“National planning policy places Local Plans at the heart of the planning system,”

Even so, the National Planning Policy Framework states as early as Paragraph 14;

“Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

– any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole;

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

Paragraph 14, Footnote 9 Reads; “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.”

“so it is essential that they are in place and kept up to date. Local Plans set out a vision and a framework for the future development of the area, addressing needs and opportunities in relation to housing, the economy, community facilities and infrastructure – as well as a basis for safeguarding the environment, adapting to climate change and securing good design.”

The Secretary of State’s decision to dismiss the Jotmans Farm Appeal in the light of the Inspector’s recommendation, raises some questions.

Is the Planning Inspectorate’s reading of the NPPF and Guidance similar to that of the Government’s?

There was agreement between the SoS and the Inspector that, Castle Point Council are only able to identify 0.4 years worth of the required 5 Year deliverable Housing Supply, this is an even worse supply than in 2013 when the SoS considered cpbc had a realistic housing supply of just 0.7 years!

In the case of the Glebelands 2013 Inquiry the SoS used a “totting-up” method of measuring harm to the Green Belt;

“the Secretary of State has identified moderate harm in respect of urban sprawl, moderate harm in respect of the merging of neighbouring settlements, and moderate harm to the visual appearance of this part of the GB.  The Secretary of State considers that together this represents a considerable level of harm. ”

” He also wishes to emphasise that national policy is very clear that GB reviews should be undertaken as part of the Local Plan process.”

So we appear to be in a situation where, as long as Castle Point council are in an apparent perpetual process of Local Plan making, the whole of the local Green Belt can be considered safe from development!

Residents should now be looking for a new, up to date cpbc Green Belt Review, based on the SoS’ guidance and embracing the protection afforded by Footnote 9 of the NPPF.

As was pointed out earlier in this post;

“Local Plans should meet objectively assessed needs, … unless: – ….  specific policies in this Framework indicate development should be restricted – For example, those policies relating to …. land designated as Green Belt, Local Green Space, … and locations at risk of flooding.”

This appears to be the clear desire of the Secretary of State’s interpretation of planning direction. The archived cpbc Green Belt Review was dated 2013 and produced in-house in support of the rejected daft New Local Plan, and clearly out of line with the Secretary of State’s consideration of  levels of “harm.” A new GB Review should be commissioned urgently, indicating the protection available through NPPF Policies and Guidance!

It would appear that the Castle Point council’s Local Plan2016, despite their failure to comply with the Duty to Cooperate with neighbouring local authorities, may have been more in tune with the Secretary of State’s interpretation of what is possible with Local Plan-making and stood a chance of being considered adoptable. Whilst an Inspector may feel the Local Plan2016 was worthy of withdrawal, seeking intervention via the Secretary of State, may supply a different decision, once the Duty to Cooperate has been complied.

More importantly, with Canvey Island in mind, is that NPPF Footnote 9 offers no  difference in the weight and importance that should be applied when considering whether a site is appropriate for development between that of Green Belt or Flood Risk!

Only in the minds of those in Control of Decision-making within Castle Point council, is Canvey Island deemed a “special case”!

If not now, then I do not know when, given the position of the cpbc Local Plan, and the direction given by the SoS, it would be more Timely and more Appropriate for Canvey Island Town Council to undertake a Neighbourhood Plan!

The Secretary of State is clear Footnote 9 should be applied to protect Green Belt from Harm.

It is obvious that an area within a Flood Risk Zone and with unresolved Surface Water Flooding issues, can expect that same level of protection using Neighbourhood Plan Policies under-pinned by that same Footnote 9!

Quite simply Canvey Island is thought to be unlikely to Flood. This is supported by no factual Evidence, simply that it is “unlikely”. The continual loss of Green Space to development on Canvey that serves as potential displacement for flood water, fails to register any concern to the planning decision makers!

The FloodRe insurance scheme is limited, limited so that it specifically discourages development in Flood Risk areas.

The list of properties excluded from the remit of Flood Re has been subject to significant debate however it has been agreed that the following properties will not be covered:

  • All commercial property
  • All residential property constructed since 1 January 2009
  • All purpose-built apartment blocks

Who will weigh this against Financial Sustainability? It appears nobody at Castle Point council!

It is time for the reservations contained within the NPPF Footnote 9 to be considered appropriately and evenly across the whole of Castle Point!

” ” All quotations lifted from the NPPF, Planning Guidance, Glebelands Inquiry and the Jotmans Farm Inquiry.