Category Archives: New Local Plan

A Housing Gift Horse, Golf Course! Mainlanders can breath a sigh of Relief? Canvey Island to be flooded with a Sea of Concrete?

Following the Castle Point Golf Club (Canvey Island) operators issuing a message on social media, see below, the possibility for EVEN more Housing to be allocated to Canvey Island, through the Local Plan2018, becomes a distinct possibility!

The Golf Course, indicated as being within the Green Belt, has previously been mooted as yet another area that developers would like to see allocated for Housing. Despite it being next to the environmentally and ecologically sensitive Benfleet Creek area, and of course close by to one of the parts of the Sea Defence likely to be over-topped by Tidal Flood water!

The CPBC Local Plan2018 Technical Evidence summary document states only;

Golf courses
5.8 Both golfing facilities in the borough should be supported to ensure that sites are able to retain current members and users as well as, whereas appropriate, assisting them in capitalising on any untapped demand plus future demand generated from housing growth and population increases.

The possibility of the Golf Course capitalising on Housing Growth in other ways, had “apparently” not occurred to cpbc officers nor members.

Let the same business argument used by the owners of the King Canute and the Admiral Jellicoe public houses, of if the business and property are not viable, then other uses must be found, be a Warning!

Yet another Blot on the Canvey Island landscape beckons?

Golf Course

 

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Castle Point Local Plan, who is Playing whom? Time for a little more Openess and Transparency?

Castle Point Local Plan has been, and remains a Mess!

During March 2018, in Parliament regarding CPBC and the apparent need to Intervene in the Castle Point council Local Plan process, the Parliamentary Under Secretary of State for Ministry of Housing, Communities and Local Government announced;

“In three areas, Castle Point, Thanet and Wirral, I am now particularly concerned at the consistent failure and lack of progress to get a plan in place and have not been persuaded by the exceptional circumstances set out by the Council or the proposals they have put forward to get a plan in place. We will therefore step up the intervention process in these three areas. I will be sending in a team of planning experts, led by the Government’s Chief Planner, into these three areas to advise me on the next steps in my intervention.
I have a number of intervention options available to me which I will now actively examine. As it may prove necessary to take over plan production, subject to decisions taken after the expert advice I have commissioned, my Department has started the procurement process to secure planning consultants and specialists to undertake that work so it can commence as quickly as possible.”

Given the apparent strait jacket position that the Government have clamped council members into, as they strive to avoid Intervention and handing the cpbc Local plan over to our less than sympathetic neighbours to produce for us, it could be expected that the Government’s hands would be more than spotless.

But no, complications have arisen by the admittance that the Office of National Statistics (ONS) have found fault with the methodology of predicting Household Projection numbers and Population estimates.

Andrew Lainton on his Decisions Blog suggests;

“And now what will happen till at least March 2019, nothing, no one in their right mind will consult or submit, a local plan or JSP.”

Well, Castle Point are threatened with the wrath of the Secretary of State Ministry of Housing, Communities and Local Government (MCHLG), should the Gov. Chief Planner find that cpbc are falling behind with the Local Plan timetable!

As recently as the 19th September the cpbc chief executive gave stern warning;

4.5 Ministry officials and their consultants visited the Borough Council in May to complete a “diagnostic check” of the position with local plan work. As a consequence of that visit and subsequent advice Castle Point Borough Council agreed a new Local Development Scheme (LDS) in June 2018, committing the Council to the preparation of a new Local Plan for the Borough on an accelerated timetable, as well as continuing to support the preparation of the JSP.

4.6 The accelerated timetable described in the LDS committed the Council to a Regulation 18 consultation in July and August, which has now been completed. Publication of the Local Plan for Regulation 19 purposes will take place in January 2019.

4.8 Whilst the Borough Council is on course to meet the milestones in the LDS, as discussed with the Ministry, it is at this stage timely to draw the Cabinet’s attention to the potential consequences should there be any deviation from those milestones or the agreed programme.

5.1 Intervention by Government in any area of local government business is a last resort and follows poor decision making and failure to follow Government direction and advice. We have been reminded by Government that intervention is a sanction and should not be considered as an alternative mechanism to deliver a Local Plan.

The Castle Point Local Development Scheme (LDS) stipulates the tight timetable to comply with the SoS’ Intervention requirements requires the cpbc Local Plan to be published by January 2019!

AND YET:

Andrew Lainton stated;

“And now what will happen till at least March 2019, nothing, no one in their right mind will consult or submit, a local plan or JSP.”

Perhaps in the light of the Chinese Whispers that are going around the mainland, regarding secret Local Plan meetings at Castle Point council, a little Openess and Transparency is Long Overdue from officers and councillors as to where they are with OUR Local Plan 2018 and whether the recent Household Projection and Population revelations will affect the cpbc LDS timetable and the Local Plan’s Objectively Assessed Housing Needs!

Councillors, officers feel free to Update your Residents!

Bewildered PIC

 

Residents in Castle Point wait to hear the Up Side of retaining the Local Plan In-House, rather than facing Government Intervention! Oh and how much Green Belt to be Released!

The latest public “announcement” on the Castle Point council Local Plan will be made during the cpbc cabinet meeting on Wednesday 19th September.

Residents will learn exactly what cpbc spokespeople actually meant when they stated they must keep the Local Plan within the council’s grasp, rather than face Government Intervention and all that that entailed!

In a report compiled by the ceo D Marchant, that may more aptly be delivered by wearing the cloak of the Grim Reaper, members will hear in clear terms the penalties that will befall residents of Castle Point, if they were not to fall in line and endorse whatever local plan messrs Smith, Marchant and Rogers enforce into publication.

Obviously there will be the intention to release more Green Belt land than was previously agreed, otherwise there would have been little need to delay progress of the 2016 local plan.

Instead Bureaucratic measures by this miserable triumvirate have taken over what should have been a democratic and public exercise!

“Intervention by Government in any area of local government business is a last resort and follows poor decision making and failure to follow Government direction and advice.

We have been reminded by Government that intervention is a sanction and should not be considered as an alternative mechanism to deliver a Local Plan.

We are aware that the Secretary of State is still considering whether to intervene in the local plan process.”

There then follows a further threat to Cabinet members, and other council members in attendance;

“In terms of decision-taking, the Government will wish to make certain after intervention that the statutory development plan and policies for the Borough will be implemented and will not allow the local plan once agreed to be frustrated by the Development Control process.

Consequently as the Borough Council had no role in the preparation of the plan, indications from the MHCLG are that the Secretary of State will exercise powers available to him to direct that any strategic planning applications submitted pursuant to the plan will be referred to the Planning Inspectorate directly rather than the Borough Council,”

“As one of the very few planning authorities under intense scrutiny by MHCLG* the Council remains at great risk of intervention and this will lead to considerable reputational damage on a national scale.”

*Ministry of Housing, Communities & Local Government

BUT what if, this likely release of Green Belt and denser Urbanisation of previously developed land, fails to see Developers and Builders deliver the required Housing Needs of London and Castle Point?

It would be naíve to think that developers would build at a rate that would jeopardise the Market Price of Housing. What if the Governor of the Bank of England’s worse projection, a 30% fall in house prices following a bad Brexit, comes to fruition?

Will more land be required to be released because other developers have put forward alternative proposals to those in the Local Plan, which they suggest they are more able to deliver?

Government and local authorities cannot manipulate the market. previous delivery rates ARE relevant, especially when you remember that only Glebelands and part of Jotmans Farm have seen applications lodged and rejected in Castle Point for, a Total of 405 dwellings since 2010!

A cpbc Local Plan that proposes to Release anymore than the 100 Dwellings per Annum agreed by the local council in the 2016 local plan, will not only see protests by residents but will also likely lead to Polling day reaction.

We were promised Localism as the way forward in Plan making.

Instead we will likely see a Bureaucratic plan delivered by the leader of cpbc intended to satisfy the national government.

A Local Plan padded out with aspirational and undeliverable infrastructure and Sea Defence improvements AND a Plan that is Sequentially corrupt!

A new Report by  Lichfields warns of difficulties for local authorities in satisfying the Housing Delivery Test.

Lichfields write;

The housing delivery test (HDT) will become increasingly difficult to satisfy

“The HDT is a monitoring tool the Government will use to demonstrate whether local areas are building enough homes to meet their housing need. Based on the outcome of this monitoring, councils may be required to undertake further action in the near future.”

“In November 2018, the test will compare housing delivery (net additional dwellings plus communal housing) to housing need (the lower of the three years in an up-to-date local plan or household projections plus unmet neighbours’ need).”

The full Lichfield report may be read via this LINK.
maco

Canvey Island Flood Event “Cover Up”? CPBC willing to withhold information, so as to develop Canvey Island!

A recent addition to the Castle Point Borough council’s Local Plan Evidence Base is the Strategic Flood Risk Assessment 2018 Update covering South Essex.

The document, apparently is too large to be downloaded from the cpbc Local Plan website, so we downloaded from the Rochford council website instead!

Of note, and the Canvey Green Belt Campaign did make it known to councillors, Canvey Island had no Historic Flood Events, up until 2011, recorded by Castle Point council except the 1953 Tidal Flood. This despite local knowledge confirmed that there is a Surface Water Drainage issue across Canvey Island!

This information we made available whilst the cpbc cabinet discussed and adopted the Surface Water Management Plan during 2012. Little wonder then that cpbc and their partners, were totally unprepared for the Canvey Island Floods of 2013 and, worse still, 2014!

Those living on Canvey Island at the time would have been well aware of a serious Surface Water Flooding Event during 1968. Previous localised Flooding causing more regular problems had also taken place on the Island on more frequent occasions.

None of this was recorded, nor recollections sought, when cpbc gave information to URS Scott Wilson as they compiled the 2011 Surface Water Management Plan for South Essex.

Now it is evident that cpbc have allowed, one can only think for convenience sake, the South Essex Strategic Flood Risk Assessment to be published and adopted for inclusion in the cpbc 2018 Local Plan evidence base, with the same Flooding Event omitted!

The South Essex SWMP (2012) states that there are 26 recorded flood events from Castle Point Borough Council, the Essex Fire and Rescue Service, Parish Councils and the Highways Agency. The source of flooding is unknown and these records are shown in Appendix A Figure 5.3. Where available, updated flood incident records held by the project stakeholders, including Castle Point Borough Council, ECC, the Environment Agency and AWS, have been provided to support this Level 1 SFRA update.

Records of Flooding included within the document indicate:

1968 “Fluvial flooding from the Benfleet Sewer” Following this event, structural flood mitigation measures were undertaken along the watercourse to improve the standard of protection against flooding including the construction of the bunded washlands area.

Again in 1987 Flood recorded in Hadleigh

For Canvey Island, during these decades, Nothing Recorded!

So despite the Canvey Green Belt Campaign making it known to cpbc that Canvey Island had suffered Flooding incidents and that the 2011 Surface Water Management Plan incorrectly omitted a record of these events, Castle Point Borough council have allowed a new Assessment to be undertaken without correcting these errors!

Not only that, but the Canvey Island Integrated Urban Drainage Study, undertaken following Government departmental advice, was not used as an informative for the South Essex Strategic Flood Risk Assessment, despite being signed off in April 2018!

5.4.2 Canvey Island Integrated Urban Drainage Study
The Canvey Island Integrated Urban Drainage Study (IUD) has been undertaken setting out how surface water drainage should be managed and maintained on the island. The study was not available for inclusion in the Level 1 SFRA; however, the study should be used to inform the Level 2 SFRA and site specific FRAs.

We can only conclude that these omissions and flaws can only be explained by them being deliberate to support the desires of  Castle Point Borough Council to distribute a large level of Housing Development onto the Flood Risk Zone and Critical Drainage Area of Canvey Island within their latest 2018 Local Plan process!

The 1968 Canvey Island flooding was not an insignificant event as much as cpbc may wish it was. These photographs act as proof:

Sandra Davis Photo

copyright: Sandra Davis

Jacksons Photos

Copyright: Jacksons Photos

More information on the 1968 Flooding has been collected, along with many interesting photographs that can be found on the Canvey Island Community Archive. Their website can be found via this LINK.

 

 

Predetermination – Interference and Planning Matters, Castle Point Council style. The Need Outweighs the Inappropriateness in our Green Belt?

Castle Point council appear to have been rattled into some inconsistency where the Local Plan and Planning matters are concerned.

Intervention over the Local Plan appears a realistic possibility, whilst Housing Need and Green Belt concerns dominate decisions.

A follower of this Blog and of Local Issues sent in this comment;

“The Government has used the Localism Act to clarify the rules on ‘predetermination’.
These rules were developed to ensure that councillors came to council discussions – on, for example, planning applications – with an open mind.
In practice, however, these rules had been interpreted in such a way as to reduce the quality of local debate and stifle valid discussion.
In some cases councillors were warned off doing such things as campaigning, talking with constituents, or publicly expressing views on local issues, for fear of being accused of bias or facing legal challenge.
The Localism Act makes it clear that it is proper for councillors to play an active part in local discussions, and that they should not be liable to legal challenge as a result.
This will help them better represent their constituents and enrich local democratic debate. People can elect their councillor confident in the knowledge that they will be able to act on the issues they care about and have campaigned on”.
I am not so sure that the Governments intention has become a reality, there is very little evidence that democratic debate is exercised at CPBC, particularly where planning on Canvey Island is concerned.

It will be imperative, or it should be, that a consistent approach is followed through Planning Policy, especially while the Government Chief Planner is taking a close interest in cpbc Local Plan affairs. One would expect this consistency to come from the top down.

Recently there have been two planning applications received that may hint at a less than consistent approach.

Firstly the proposal for the 57 bedroom Care Home at Canvey Way, Approved against Officer advice. Officers stated that amongst other reasons “the proposal constitutes inappropriate development in the Green Belt” and that “The application is presented to the Development Control Committee as the applicant is related to a Member of this Council”.

Unusually just ahead of the development committee meeting to consider the application, the Castle Point council leader, cllr Smith was quoted in the Echo as saying;

“The committee may think the need is enough for the plans to be passed.”

And that

“The people will only lose out if the plans are refused.”

There is a recorded need for facilities of this type in the Borough, however there is also a recorded Housing Need in the Borough.

It appears that the desire locally is to develop on Previously Developed land. This is where the cpbc leader may be indicating some inconsistency.

Residents on the mainland appear concerned with the possibility of 12 Apartments, being built on the Wheelers restaurant site at Bread and Cheese Hill. This is also Green Belt and previously developed with a far more permanent structure than that exists at the Garden Centre site at Canvey Road.

As yet there has been no officer advice issued, however cpbc leader cllr Smith has himself “called in” the application, on the Grounds of Inappropriate Development in the Green Belt, so that the Development Committee can make the final decision whether to approve.

This might appear contradictory in that having publicly stated “The people will only lose out if the plans are refused.”, on the Canvey Road application, to then personally call in another application, that maybe far less likely to be considered as inappropriate development in the Green Belt, just may be viewed as suggesting to his colleagues on the development committee that they should Refuse the Bread and Cheese Hill proposal.

Surely the evidence suggests that in both the case of Care Home facilities AND Housing, the need may well be “enough for the Plans to be passed.”

Policy makers may do well to set a better example if they kept their views private at crucial times for the cpbc Local Plan, and the Echo Newspaper may do well to go back to their more investigative style of journalism to add clarity to these topics.

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Images Copyright: Google Earth

Residents almost Total Disengagement with Castle Point Borough Council! Local Plan Consultation a Major Turn Off!

The CPBC Local Plan Consultation formally closed to submissions on the 15th August.

Alarmingly indications are that less than 0.7% of Castle Point residents took part in the process that will shape the future of the Borough!

“The Council invited comments on the contents of a new Local Plan…. Responses are yet to be analysed but initial indications show that more than 1100 comments were received  from over 630 individuals and organisations.”

We say that less than 0.7% of the 89,000+ Castle Point residents made their views known, as the total number of responses included those of neighbouring Councils and Developers!

There can be no doubt, that there is a disengagement with our local authority by residents!

That residents views are ignored, is a view challenged by councillors, but a view that, going by the number of responders, must be recognised!

This disengagement contrasts starkly from the Canvey Green Belt Campaign Referendum that managed to visit and ask residents their thoughts on Green Belt development on Canvey Island, and engaged with over 6,500 residents.

Also the Canvey Ladies who compiled a Petition against development on the Island and achieved over 10,000 signatures.

Not a week goes by without complaints on traffic congestion, and over stacked GP surgery lists. Flats and Houses being developed to more denser and higher designs. Industrial premises taking over important Green Spaces. Flooding becoming more frequent.

With latent feelings running high, why would residents NOT take part in the Local Plan consultation?

0.7% Response is a admittedly a paltry figure considering the number of campaign groups within the Borough.

However, what IS important is the content of the answers given and the documentation in support of what the Local Plan should and should not contain.

Despite this, going by previous experiences, Castle Point council will likely continue to do whatever it suits the current administration.

This is probably why so many attempts to achieve a Local Plan have been forced into withdrawal and fallen by the wayside, and the Government through the Chief Planner, are keeping a very close watch on cpbc’s Local Plan process.

This may be why such a small response was achieved through the Consultation.

 

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Tonight’s the Night – for Canvey Island’s new 57 Bedroomed Residential Care Home? “However”!

The Castle Point borough council Development Committee will tonight consider the proposal for the development of a 57 bedroomed Care Home at the junction of Canvey Road and Northwick Road.

Screenshot (11)

This proposal, within Canvey Island’s depleted Green Belt may present a few contradictory issues during debate.

“Consideration of the proposal under the provisions of the NPPF and adopted Local Plan identifies that the proposal constitutes inappropriate development in the Green Belt, which could only be justified if Very Special Circumstances could be identified,”

“The need for specialist residential accommodation has been identified as a circumstance to which consideration should be given; however, there has been no demonstration that this need can only be met on the application site. In the absence of a clear demonstration that the identified need could not be met elsewhere it is not considered that this circumstance….would justify inappropriate development in the Green Belt.”

The un-identified Need for the Care Home may be difficult to establish, given that the business already has an establishment on a Brownfield site, that it could be argued, may be suitable for renovation to provide the care offered in this new proposal.

“it is considered that the specific scale of development proposed is excessive, resulting in a building of mean and cramped appearance”

“The proposal is therefore contrary to Government guidance as contained in the NPPF.”

The site, currently contains a Garden Centre consisting of basically a large “Green House” style building and wooden canopies to shelter plants. Council officers argue, presumably using imagination, that these they consider “permanent” buildings, in support of the new proposal!

Directly connected to the proposed site is “To the north the site is adjoined by a detached two storey dwelling beyond which is a bungalow and some 112m further to the north, the Dutch Cottage, a Grade II Listed building. 

To the west the site is bounded by open land designated an Ancient Landscape and Wildlife site (West Canvey Marshes Nature Reserve) and used, in part, for the grazing of horses.” 

Given the Approach to development within Castle Point’s Green Belt of late by the local authority on both a Policy level and at Development Committee  level, this proposal may provide some extra confusion to the mix!

Only recently ex-councillor J. King was granted permission for Equestrian facilities consisting of bricks and mortar stables and offices, within the Green Belt.

Contrastingly the need for Housing both market priced and affordable, is proven to exist within the Borough, yet this is denied Approval.

Care MUST be taken in the decision making to establish consistency.

Further, the suitability for a Residential Care Home, within such a small Borough, within an area at Risk of Flooding, should be a serious “consideration”!

The site is opposite an industrial estate with adjoining and nearby roads, Roscommon Way and Northwick Road, the subject of local residents complaints over Noise.

The proposal is also of some considerable size, especially compared to the existing “buildings” on site.

Confusion will be added to debate when the “position” of our previous Local Plans are touched upon. The Adopted 1998 Local Plan is out of date, the Core Strategy is “dead”, the 2014 and 2016 Local Plans are both “withdrawn”, whilst the 2018 hasn’t yet finalised consideration of the Consultation stage!

Most recent development committee decisions have attempted to comply with the proposed non development of so called “virgin Green Belt”, despite the decision in favour of ex-councillor J. King.

The site for the Care Home proposal has been proposed to be included in the most recent draft Local Plan’s. However the 2018 Local Plan is at a development stage, likely to be criticised by an Inspector well ahead of any decision.

Given that the 2 large Green Belt sites in the borough, Jotmans Farm and Glebelands, were both Refused permission  by cpbc officers and committee, and on Appeal also Refused by the Secretary of State on grounds that a decision would be Premature whilst a Local Plan was being produced by the local authority, it may appear “confusing” for a site proposed for inclusion in the 2018 Local Plan, to be decided upon ahead of the new Local Plan’s publication.

A new Local Plan, under close scrutiny from the Government’s Chief Planner, may be better used for Housing or indeed returned to the Green Belt. An interesting proposal indeed.

Whilst this proposal is not exactly the same as either the Jotmans and Glebelands cases we can expect to hear a few “However’s” from the cpbc Case Officer during tonight’s discussion!

Illustration Copyright: Brian Davison estates