Thorney Bay, change of Use Over-Heard on the Canvey Grapevine! CPBC Local Plan issues?

It started as a Whisper, became a Rumour and has now reached Conjecture level on the Canvey Grapevine!

Thorney Bay, the apparent answer to the Castle Point Council’s Local Plan dreams, has become the subject of unconfirmed speculation. With the humiliating Withdrawal of the cpbc Core Strategy in 2011, it was considered “timely” by cpbc officers that Thorney Bay, despite it being sited within the Hazard range of Calor Gas and within a 3A Flood Zone, should come forward to provide a Housing Development of some 600 dwellings plus sheltered accommodation.

Thorney Bay then became the Backbone, the largest single development site, of Castle Point council’s daft Local Plan and surviving the GB sites cull to remain as the spine of the Local Plan2016, 5 year Housing Supply!

The Thorney Bay proposal passed in Principle by the cpbc development committee, whilst in the following months / years a 1st Phase proposal has gained Health and Safety Executive’s permission and is apparently overcoming the Flooding Objections to the fundamental requirements of the Environment Agency and the ecc Lead Local Flood Authority.

Now then; Listen very carefully, I shall say this only once!

A little Bird has told me, and I must say there is little foundation, so to speak, for this to be considered information, but it could be that the development may not be going much further!

To me this would not be a surprise, I would have thought a more likely idea would be for the developer to follow the Kings Park, and remove the static caravans and replace with Park Homes.

The build cost would be far less, the speed of development would be probably twice as quick and success of the venture equally, if not more so, financially successful as Kings Park!

What’s to lose?

Park Homes and Luxury Lodges can easily reach an asking price of £300,000, the site is opposite Thorney Bay Road, and residents would likely be of an age not too concerned with, the daily commute.

Now that the Canvey Bay Watch team have created such an attractive area of the promenade and beach front, this forms another selling point for potential Park Home buyers. I would have thought that the Canvey Bay Watch team should soon be knocking on the site owner’s door for financial support, should this development rumour come to fruition!

Thorney Bay 1

Photograph courtesy: Dave Harvey

The question for cpbc is whether these Park Homes should count towards the official Housing Supply.

On one hand these Park Homes “are suitable for residential use throughout the year and are built to last at least 50 years”! (Omar park and leisure homes). Although whether 50 years lifespan is considered permanent is challengeable, however, their success is, and there are people desiring to own them.

The Planning Inspector examining the Glebelands, Thundersley, Appeal did not consider the numbers at Kings Park should qualify for inclusion in building numbers, but that may have been due to cpbc being unable to clarify how many caravans were replaced by Park Homes.

We do know that of the caravans at Thorney Bay the Inspector concluded;

“But that does not necessarily mean that the Households now occupying caravans would have chosen that type of accommodation, in preference to bricks and mortar.”

Well, “bricks and mortar” these Park Homes ain’t! But the appeal of Park Home life is generally popular across the UK, so if people are choosing to buy into this type of accommodation, then there is an argument for these dwellings to be included into the Canvey Island Housing Supply count.

With our “Broken Housing Market” leading to the apparent need to revisit Pre-Fabricated Housing, these Park Homes may well have some scope.

Whether or not any Affordable Home supply can be squeezed into the equation will be upto the negotiating abilities of cpbc, so we won’t hold our breath on that one!

What could be expected is for some Canvey Island “bricks and mortar” dwellings to become available, for local young families hoping to get on the property ladder, as older Canvey residents move into the Park Homes.

It may be doubtful , should the development come into fruition, whether the Housing Need in the mainland part of the Borough be part satisfied, as it will be difficult to argue that this type of dwelling satisfies the cross market “bricks and mortar” Housing Need. In fact it probably increases the pressure on mainland site supply.

I remind you this is only speculation.

As a reference, below, I include part of the text of the cpbc Report on Residential use of Caravan and Park Home Sites 2013.

“It is clear from both Census data and from Council Tax data that an increase in the availability of caravans for residential use resulted in an increased housing supply of the order of 800 homes in Castle Point in the period from 2001 to 2011. This increase was largely as a result of the change of use of Kings Park and Thorney Bay Caravan Parks from holiday use to residential use.”

“To date, the Council has only included those caravans registering for Council Tax at Kings Park within the housing figures for the period 2001 to 2011. However, given that caravans at Thorney Bay were included as homes within the Census 2011 outcomes, and this will be reflected in population and household data moving forward, it is appropriate that the housing supply figures for the period 2001 to 2011 are appropriately adjusted to include these homes also.”

“The change of use of static caravans from holiday accommodation to residential accommodation has made a significant contribution to housing provision over the last decade (2001 to 2011). Approximately, 800 additional caravans moved into permanent residential use over this time period, primarily on the Kings Park and Thorney Bay sites. This is supported by evidence from the Census and from Council Tax records.”

“However, whilst some of this provision has contributed positively towards the community, in particular at Kings Park, the nature of the provision at Thorney Bay has had negative socioeconomic consequences both for the surrounding community and for the vulnerable families who have found themselves living at the site.”

“Due to these issues there is support for proposals to redevelop a significant proportion of the site for traditional homes. However, it is the intention of the owner to retain a smaller caravan park of 300 caravans for residential use towards the west of the existing site.”

“Assuming that the proposals to redevelop this site as proposed for traditional housing are delivered in full over the next 10 years, then it is unlikely that the number of households living in caravans in Castle Point will increase further between 2011 and 2021. Indeed, as a result of the development of traditional housing over this period, it is expected that the proportion of households living in caravans will reduce.”

“However, should the Thorney Bay site not be redeveloped as proposed, then there is the potential for a further 800 caravans moving from transient use into permanent residential use. This will increase further the number of households living in caravans, and the associated socio-economic issues arising from this. It is therefore imperative that the Council work alongside the site owners to encourage and facilitate the redevelopment of this site in an appropriate timeframe.”

Video copyright BBC

“Smoke Filled Rooms, Dodgy Housing Site Selection Processes and Failed Local Plans,” sound Familiar?

Yet another Local Plan is halted in its Tracks. In an Inspector’s Note, reminiscent of that sent to Castle Point Council during 2011 when Mr P.Crysell stated, amongst other concerns; 

“I consider there remain serious shortcomings in the (CPBC) Council’s Plan.” “These are firstly, the approach in relation to the Green Belt; secondly, the consequences of this on the distribution of growth across the Borough”

“I have reservations about the methodology employed and the way in which it appears to have been used, leading to inconsistent and inappropriate site selection.  For example, the Council’s own Sustainability Appraisal is unclear as to why the most sustainable Green Belt site was discounted.”

“I consider it would be difficult to endorse a strategy which commits to Green Belt release in an area of potential high flood risk at Canvey Island yet fails to identify more than a token amount of land on the mainland where flooding is not a significant issue.”

The Shropshire Star commented of the Telford and Wrekin Local Plan;

“It is pretty clear that a ‘smoke filled’ room process occurred behind closed doors with Cllrs where political rather than policy issues dominated – something the post 2004 Act changes was designed to eliminate.”  Shropshire Star

Evidence had emerged of a similar smoke filled room meeting in the CPBC Lead Group rooms, during which Canvey Island Green Belt was sacrificed so as to progress a Core Strategy document bent on protecting mainland Green Belt at all costs!

Of the Telford and Wrekin Local Plan the Inspector commented;

Housing Site Selection Methodology

 7. You will recall the concerns that I raised at the Matter 8 hearing session in respect of this matter.  While I accept the need for a Plan’s evidence base to be proportionate, it is also the case that all parties need to understand why certain sites were allocated and why other sites were not allocated.

 8. In that context, I sought to examine the methodology that the Council has employed in selecting the 17 housing sites proposed for allocation in the Plan.  Unfortunately, the commentary set out in the Council’s (pre-hearing) written answer to my question in respect of this matter2 and in section 5 of the Housing Delivery Technical Paper3 contain only a brief summary of that process.  Indeed, the latter document states (para 5.6) that ‘the site selection or rejection reasons for each individual site can be found in the Integrated (Sustainability) Appraisal Report (2015)’ (the IA).

 9. However, Appendix X of the Integrated (Sustainability) Appraisal Report4 comments that ‘the IA findings are not the sole basis for a decision; other factors including planning and deliverability, play a key role in the decision-making process’.  Bearing in mind the position set out in Housing Technical Paper as described above, this suggests to me an element of circular reasoning.  

 10. Clearly, the detailed selection of sites for allocation involves an element of planning judgement.  However, that judgment needs to be both explicit and transparent.  In short, there needs to be a clear ‘audit trail’ that shows how the final decisions were arrived at, and what factors were taken into account in making such decisions.

 11. In response to my questions along those lines at the Matter 8 Hearing session, your officers offered to table working spreadsheets that would give more information about how the Council reached its decisions in this regard.  I accepted that suggestion and allowed other parties the opportunity to make representations accordingly.  However, the document that was subsequently produced5 was not the working spreadsheet that had originally been offered.  Instead it represents a commentary, apparently prepared after the event, that seeks to apply planning considerations to some (but not all) of the sites that were considered at the ‘strategic fit’ stage of the site assessment process.  I have now been advised that the Council is unable to find the spreadsheets that were apparently referred to at the hearing session.

12. The evidence that has been submitted since the hearing session is inadequate for several reasons.  First, it does not represent the actual selection exercise, as it was prepared after the event.  Second, comments are only given on a number of some 315 sites considered at the ‘strategic fit’ stage of the assessment.  Over 200 sites are missing.  This represents a substantial gap in the evidence base.  While the Council comments that the sites listed are only those that scored 5 or above in that exercise, it is clear that some sites with a lower score were also assessed – and indeed subsequently allocated in the Local Plan.  Clearly, an additional sieving exercise had taken place prior to the one that is presented in the new evidence.  Third, it is clear from the comments made in this document that a number of sites that scored highly against the ‘strategic fit’ criteria were then discounted on the basis of their existing use.  It is unclear why these were not screened out at the earlier site assessment stage, at which the site’s development potential was considered in terms of various factors – including use.

 13. I note the Council’s responses to the specific comments made by representors in respect of this additional evidence7.  For the avoidance of doubt, the present note does not seek to comment on the detailed scores that have been assigned to specific sites in the IA.  However, I share a general concern raised by some parties in respect of strategic fit criterion 2 (promoting sustainable urban extensions) that it is not immediately clear why some large sites (notably those that have been allocated) were given a positive score in respect of that criterion while other large sites – also adjoining the urban area – were deemed to not comprise a sustainable urban extension.

16. Drawing these matters together, and noting that some further comments are yet to be submitted by the Council, it appears likely that I will reach a finding that the housing site selection exercise underpinning the Local Plan is flawed.  Such a finding would call into question my ability to reach a finding of soundness on a Local Plan containing these site allocations.

13 years on from the 2004 Act, that the Shropshire Star referred to, appears to have resulted in very little impact!

May time approaches and Canvey Island must Know its Place where Elections are concerned!

Once again May time approaches and this year it is the turn of the County Council elections to take place.

Seemingly, as far as Road infrastructure investment is concerned, the south of Essex County fares less well than areas around and to the north of Chelmsford.

Whether this being main highways or the funding of the currently contentious street lighting of Unadopted roads, Castle Point routes appear to suffer from neglect.

It is also high time that representation from Castle Point is reassessed. Whilst population growth is relatively low, it is strikingly more so, on the mainland part of the Borough.

shutterstock_boot_crushing_man

Castle Point has seen little increase in population, a 1.6% increase since 2001 – 2011, from 86,608 to 88,011.

However the distribution of this increase is interesting, Canvey Island was 2.6% up whilst the Mainland saw just a 0.8% increase!

Canvey Island population is 38,459, whilst the mainland population is 49,552.

As far as Representation goes at Essex County Council, Canvey Island continues to be represented by just 2 members whilst the mainland enjoys 3 members.

Proportionately this is now becoming unbalanced: 88,011 residents being represented by just 5 members.

This means that each mainland County Councillor will represent just 16,517 residents.

 In comparison each Canvey Island County Councillor will represent 19,230 residents!

There is little likelihood, taking into account the distribution of councillors at Castle Point council, that the balance of population growth in the two parts of the Borough will alter in the future.

Canvey being Urbanised at Denser levels of Housing Growth, so it is fair to ask, at what point will Canvey Island receive equal representation?

It would not be unfair at this stage to suggest that there could well be justification in the proposed Boundary changes suggested OR that the 5th Castle Point County Councillor should be appointed in some other fashion rather than simply on an area / ward basis.

That is until Canvey Island population becomes equal to that of the mainland, which going by current growth should not be too long now!

Picture copyright; shutterstock

Irresistible, Selling Off of Canvey Island Assets to boost Castle Point Housing Supply!

Firre Station downgraded

Recent reports have raised concerns on Canvey Island that we may be seeing a reduction in emergency cover.

In the press there have been articles suggesting the Ambulance station and Police station may be closing down.

The Fire station has already been down-graded to part time cover only.

In the almost desperate efforts to find Housing Land in Castle Point these Government assets would appear ripe for development in the very near future. The resultant sale of the sites would raise much needed tax funds and allow, the much abused on Canvey, Permission in Principle for Development!

Do not be surprised to hear that following the £15,000 feasibility work to be carried out by Castle Point Council the study advises the demolition of the Paddocks and a Flats Development, with a much reduced replacement community hall, in its place!

It is not beyond reason to imagine a token Police Station and Ambulance car park incorporated on the Fire Station site, releasing the Police and Ambulance stations for more development.

A Report from 2015, laid the building blocks for the start of the stripping of “government assets”; 

“Local councils will be allowed to keep all of the money raised from asset sales to reinvest in local services, the chancellor announced today, as part of a wider move to encourage the sale of hundred of billions of pounds of public sector land.

In his 2015 Autumn Statement speech, chancellor George Osborne said locals governments are sitting on property worth a quarter of a trillion pounds.

The government will encourage councils to sell land by allowing them to spend 100 per cent of their receipts from asset sell-offs on improving services and local projects. That includes thousands of pubs, theatres , golf courses and restaurants currently in local government hands.

He pledged to release £4.5bn of government land and property to make space for 160,000 homes, while unused commercial or industrial land will be released for starter homes.

Previously developed brownfield sites in the green belt will also be allowed to be developed in the same way as other brownfield land, providing it contributes to Starter Homes.”

CITYA.M.

Whilst more recently the Get Building accelerator pedal was pushed by the replacement government regime;

“In a bid to boost home building, councils will have to produce up-to-date registers of brownfield sites in their areas, the government has announced.

Today the housing and planning minister Gavin Barwell said local authorities will need to create, maintain and publish these registers to help housebuilders identify suitable brownfield sites quickly.

The government said this measure promises to unlock derelict or underused land for thousands of new homes.

As set out in the recent housing white paper, the registers are part of the government’s programme to speed up house building.

Barwell, said: “We need to build more homes in this country so making sure that we re-use brownfield land is crucial.

“We want to bring life back to abandoned sites, create thousands more homes and help protect our valued countryside.

“These new registers will give local authorities and developers the tools to do this.”

The regulations implementing brownfield registers and permission in principle through brownfield registers have been laid before parliament today as part of secondary legislation relating to the Housing and Planning Act – they will come into force in 21 days’ time.

According to the government, permission in principle will make it easier for developers to ascertain if particular sites are suitable before they draw up costly proposals to secure full planning permission.”

PublicFinance

The potential to boost the Castle Point Housing Supply, via the use of Canvey Island land will not be over-looked!

Photograph: copyright the Echo Newspaper

CPBC reverts to 1998 Local Plan “Opportunity Knocks”Again for Canvey to start our own Plan?

For those Castle Point Residents that are unaware of, or who have not received this communiqué, here is the official notice of withdrawal of the Local Plan2016, due to the failure of cpbc in their legal obligation of the Duty to Cooperate with Neighbouring local authorities.

castlepoint

Regeneration & Neighbourhoods
Council Offices,
Kiln Road,
Thundersley,
Benfleet,
Essex SS7 1TF
Tel: 01268 882200
Fax: 01268 882382
Date: 4th April 2017
Our Reference: SAR/PP/IE/020
NOTICE OF WITHDRAWN PLAN
PLANNING AND COMPULSORY PURCHASE ACT 2004
TOWN AND COUNTRY PLANNING (LOCAL PLANNING) (ENGLAND) REGULATIONS 2012
CASTLE POINT BOROUGH COUNCIL – NEW LOCAL PLAN 2016
In accordance with Section 22 of the Planning and Compulsory Purchase Act 2004, and Regulation 27 of the Town and Country Planning (Local Planning) (England) Regulations 2012, Castle Point Borough Council decided to withdraw the Castle Point New Local Plan 2016 on 29th March 2017.
Yours faithfully,
Local Plan & Regeneration Adviser
01268 882220 (Direct line)
This letter of Local Plan withdrawal effectively means that Castle Point Council’s current Local Plan is again the saved 1998 Local Plan! The outstanding work by cpbc and the other Neighbouring local authorities is expected to require approximately 2 years to complete.
This appears to create an opportunity for Canvey Island Town Council to revisit the issue of creating a Neighbourhood Plan for the Island Residents.
There are many good points in the cpbc1998 Local Plan such as the improvement of the road infrastructure including a new access road, and protection of Green Belt, whilst recognising the constraints on development of Flood Risk, Infrastructure, COMAH sites and Green Belt.
It may be possible to encompass policies in a Canvey Island Neighbourhood Plan that comply with the castle point adopted 1998 Local Plan and the NPPF, that would in turn lead to a Positive and Acceptable document for Canvey Island’s future.
A document that prioritise residents safety and well being, equality and quality of life, and most importantly include an appraisal of what constitutes appropriate development.
The Canvey Green Belt Campaign group have never hinted nor expressed a view that a Neighbourhood Plan could stop all development on Canvey Island.
What we have consistently stressed is that any development on Canvey should be appropriate, and limited in its delivery, in line with the need to maintain the population at current levels or lower given the Risk of flooding and the Hazardous Industries.
The current situation, without any Canvey Island Plan, means in effect, that practically all development on Canvey Island is given approval so as to alleviate Castle Point Borough’s chronic lack of Housing delivery.
A Canvey Island Neighbourhood Plan would stand as a Positive Document, regardless of its completion, for an Inspector to view as a reasonable and effective Plan for Canvey’s future, when weighed alongside the Next Local Plan devised by Castle Point council.
A Neighbourhood Plan that could be actively supported by Canvey Islanders.
In its previous considerations of a Neighbourhood Plan many points relevant then (August 2016) are irrelevant now, such as;
 all development sites already in the Draft 2016 Local Plan for Canvey Island would have to be carried forward into the Neighbourhood Plan;
failure of the cpbc Local Plan will give the Borough Council six months to submit a new Plan;
new planning laws state that any development proposed to be built on a flood plain would be sent to Government Ministers for consideration;
As it stands the previous motion put to Canvey Island Town Council to consider a Neighbourhood Plan was defeated, Unanimously by both political groups 8 votes – 0 votes.
Time for a Rethink and Getting Stuck In?
The Minutes of the Canvey Island Town Council’s debate on a Neighbourhood Plan can be viewed HERE

£?,000,000 Block Buster – a Decade in the making Castle Point Local Plan IV – the Sequel! “Missing the Point”

download

“Fear not, for I have a plan!”

Castle Point Residents should be concerned as to why Local Plan Version III has ended in withdrawal with the vast waste of time and tax payers monies.

The Examining Inspector pinpointed the failure of the Castle Point council’s legal duty to have engaged constructively with neighbouring local authorities, actively and on an ongoing basis so as to prepare an effective Local Plan, in the context of strategic cross boundary matters.

The Duty to Cooperate work requirement, supports the evidence base that in turn supports the Local Plan Policies.

However the Duty to Cooperate is not a duty to agree!

The Inspector has indicated that CPBC have failed to fulfil the expected working practises.

The Duty to Cooperate was created in the Localism Act 2011.

During September 2014 a senior Planning Inspector held a “Secret” training session with CPBC senior officers and councillors.

Following a briefing I learnt that the Inspector, Mr K.Holland, made very clear that CPBC were expected to;

“Objectively assess its Housing Needs, Plan to meet those Needs, and very importantly undertake the Strategic Planning using the Duty to Cooperate that used to be done at Regional level.”

He pointed out that the Government is “completely uncompromising about these points”!

This, I was told, was the very first point that he stressed to the councillors and officers.

However the meeting was arranged as councillors were seeking to protect Castle Point Green Belt and wished to hear what options were available to them.

It is likely that councillors may have missed the Inspector’s opening warning regarding the Duty to Cooperate, however it would Not Have By-Passed the Officers!

Having found that CPBC could not meet its Housing Needs, and settled for 50% as a target, the Local Plan2016 then further sought a reduced target of 25% of Housing Need.

This would clearly indicate that much work and involvement with neighbouring Boroughs, to examine whether agreements could be reached over sharing Housing Delivery, would be a fundamental requirement.

Instead the Local Plan 2016 was submitted for Examination, knowingly failing the Duty to Cooperate, and supported by the 2013 Green Belt Boundaries review written in support of the rejected draft 2014 local Plan.

In other words the local Plan2016 was submitted knowingly doomed to failure!

 The local government Assoc. Consider “Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.”

Given the time and expense, reaching many, many hundred of thousand of Pounds to Castle Point residents, it is surprising that the belatedly undertaking of steps to fulfil the Duty to Cooperate, and the likely emergence of Local Plan Mk IV, has commenced without any apportionment of blame on the local authority, nor apology issued  to Castle Point residents, nor explanation of the reason behind the decision to submit a local Plan that would fail at the first requirement! 

View the Echo comment and Green Belt part of the allegedly leaked cpbc video HERE

How effective is the Withdrawal Method? Castle Point Planning to give it a Go!

Following on from the last evening’s Castle Point council meeting to debate the Local Plan2016 previously previewed HERE.

Regional strategies were disbanded in 2010, it has taken 7 long and expensive years for Castle Point Council and neighbouring Boroughs to realise in place of these strategies that they should have been working with neighbouring Boroughs to organise mutually beneficial Housing strategies rather than having Housing Numbers imposed on them!

There appears an acceptance amongst councillors, rightly or wrongly, that the Housing Supply figure of 100 dwellings per Annum is inadequate, and will be adjusted upwards! Whether the confidence in relying on the re-adopted out of date 1998 Local Plan is misguided will, no doubt be examined by developers.

The position now is that a formal Memorandum of Understanding (MoU) has been approved by all 5 South Essex local planning authorities, as a way forward in compliance with the required Duty to Cooperate part of the Local Plan process.

Having attended the Duty to Cooperate Hearing held by the Inspector and attended by members of the other 4 South Essex planning authorities, we must hope that a line is drawn under the aggressive and non-cooperative approach towards Castle Point representatives!

If not cpbc will be as uncomfortable within the MoU partnership, as the UK appear to have been in the European Union!

It appears now that work on the Local Plan will move further outside of cpbc members control. More strategic work and decisions will be taken at MoU level, which will be in the hands of officers and the Leaders of councils. Their decisions will be difficult to reject, however there remains the possibility that having completed the attempt to cooperate, despite failure, the Duty to Cooperate will have been complied with!

Having steered Castle Point council in this direction, an Inspector will expect to see some tangible results, not just a “we tried” but “we failed” pretence exercise, before a New Local Plan MkIII is (re) submitted.

A show of hands was not called for following the “debate” as the necessary agreement to follow cpbc recommendation to withdraw the Local Plan2016 and seek to comply with the Duty to Cooperate, was agreed by the majority of members.

Cllr Stanley having opened and closed the debate just about managed to stop himself saying “I Told You So”!