Tag Archives: 5 year housing supply

Canvey Island, is there Foundation for Park Homes Boost at Roscommon Way’s Expense!

It almost appears inevitable that Canvey Island will once again supply the bulk of the Borough’s Housing Delivery in the near future!

The all important Local Plan 5 Year Housing Supply will be boosted, or drained, by the success of the Sandy Bay venture at the Thorney Bay caravan site.

The potential for 1,000+ dwellings, will impact upon the area for better or worse, one of the major impacts, is seemingly the death knell of the Roscommon Way final extension. That is unless the cpbc cabinet’s appeal to Essex County Council to intervene, produces a significant U-turn in the developer’s plans for the Park Homes site.

From the Map below it is difficult to envisage a different route for the Roscommon Way extension that would not divide or disrupt the Sandy Bay site and its community, nor one that would not involve substantial Compulsory Purchase Orders.

Screenshot (3)

copyright: Google

The Sandy Bay development is aimed at the over 50’s and retirees, people who will have invested substantial sums and expect the use of the facilities on offer as well as an element of peace and quiet. A main commuter route that may divide the Park Homes site would prove an obstacle in creating the proposed facility. One can only hope that ECC can come up with a solution, otherwise the almost annual, call for road infrastructure improvement funding for Canvey Island, will be added to that of Canvey Way and Somnes Avenue!

The Housing and Planning Act 2016 gave the Thorney Bay site the Green Light to switch tack from the application for 600+ “bricks and mortar dwellings, to an even more numerous Park Home development.

” ‘Park Home’ is the industry name for a caravan which is used for residential purpose.

National Planning Policy, as reflected in the NPPF, requires Local Planning Authorities (LPAs) to produce Local Plans that will deliver the full, Objectively Assessed Needs (OAN), for market and affordable housing in the housing market area. The Government’s online Planning Practice Guidance (PPG) sets out the methodology for assessing housing need; it refers to specific types of housing which should be considered. No reference is made to Park Homes or residential caravans. Accordingly, there is no duty for LPAs to forward plan for provision of this type of housing.”

“”…the needs of people residing in or resorting to their district with respect to the provision of-  (a) sites on which caravans can be stationed…”

This suggests that local housing authorities (this includes District Councils and London Borough Councils) will need to start forward planning for provision of residential caravans.
This is a significant step change from other recent planning legislation because it is the first time non-gypsy caravans have been recognised as having a role in contributing towards the supply of housing in a given area.” *

All along CPBC have stated that their planning control powers are restricted to the point of no influence, this despite the apparent desire through the many versions of their Local Plan intending to seek central funding to provide the residents to the Eastern and Southern part of Canvey Island relief from the congested routes off of and onto the Island.

A balance between Homes, Congestion Relief and Profit, with congestion relief finishing an out of site 3rd!

Prior to the 2016 Housing Act it may have been necessary for a development application for Sandy Bay to have gone through the planning channels at CPBC. An apparent similar proposal went before Chelmsford Council’s planners, this site also is subject to Flood Risk so would have required sending to the Environment Agency, as consultees, for consideration. 

The use of the 2016 Housing Act, allows the Sandy Bay site to evolve outside of the Local Plan and cpbc planning processes.

Essex County Council may also have reservations in pursuing the remainder of the Roscommon Way link, as the original phases, whether as a cost saving exercise or not, were constructed with a shortened Life Span.**

The completion, however, of the final phase of Roscommon Way would increase usage of the existing phases from commuter, leisure and industrial vehicles, both hazardous and non-hazardous. ECC would need to ask what would be the likely effect of the increased usage on the road foundations, and subsequently the hazardous pipework beneath the existing Roscommon Way, especially where vehicles are filtered into the single lane areas of the carriageway?

Usually the provision of new Highways are restricted by the levels of new Business Use, rather than a level of commuter congestion. The completed stages of the Roscommon Way fulfilled this requirement, it will need compelling evidence, which may have come from a traditional “bricks and mortar” development at Thorney Bay, for the completion phase to be realised.

The problems of developing on Canvey Island are manifold, that one developer appears to understand ways of traversing these obstacles, is clear.

The residents of Canvey Island  are now encouraged by cpbc to direct their hopes and protest for highway congestion relief towards Essex County Council!

*The views of Sanderson Weatherall.                                                            http://sw.co.uk/property-consultancy/planning/911-the-housing-and-planning-act-2016

** http://planning.chelmsford.gov.uk/Planning/lg/dialog.page?Param=lg.Planning&org.apache.shale.dialog.DIALOG_NAME=gfplanningsearch&viewdocs=true&SDescription=14/00722/FUL


Jotmans Farm High Court Appeal – NOT for Castle Point council to Defend?

Green Belt Campaigners, particularly those concerned for the future of Jotmans Farm, having been kept well and truly in the dark over the High Court challenge to the Secretary of State’s decision to oppose development of the area, should be concerned to note the apparent inactivity by Castle Point Borough Council.


Mushroom syndrome where you’re kept in the dark

The statement issued by CPBC as reported in the Echo Newspaper reads;

“As the appeal is actually against the decision of the Secretary of State, it is for the Secretary of State to defend.”

“The council is monitoring the situation, councillors have been kept informed..”

The second point made by CPBC and why it was felt it un-necessary to inform residents, we covered HERE.

If you have read the Post’s link and read the contents you will be aware that, in the case of the Glebelands High Court Appeal, Castle Point Council were named as Defendents!

So referring back to the cpbc statement in the Echo above, it may appear to be a remarkably un-reassuring and passive position for our Local Authority to assume!

After all, as recently as the 11th July of this year Essex County Council, to which Castle Point residents are represented Agreed the following Motion, passed with Unanimous Approval

Perhaps some clarity is deserved by Residents from our local councillors after reading the following, of which they will also be aware;

Planning and Infrastructure

At the July 2017 Essex County Council meeting, it was Agreed (with UNANIMOUS Cross-Party support) that;

Essex County Council will not support Local (Development) Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure that sufficient infrastructure, including roads, schools, medical facilities, parking, sewerage and drainage, is provided in a timely manner and in a way that balances the needs to promote economic growth and provide housing for residents whilst protecting their quality of life.

Given the significant housing development emerging from Local Development Plans, this Council reaffirms its commitment to this policy. This Council also expresses its concern that whilst Local Development Plans and Neighbourhood Plans are being progressed to decide where this housing should be best located, some developers are exploiting the lack of a 5 year housing supply to gain planning permission on greenfield sites, often outside the development boundary, even when these sites have been excluded from the draft local plan and in some cases where there are brownfield sites available or in the pipeline.

This Council therefore calls on the Secretary of State for Communities and Local Government to issue urgent statutory guidance, which removes the opportunity for this exploitation and protects valued greenfield sites from predatory development.

Previously agreed at the October 2014 Full Council meeting.

It would appear negligent if legal representation was not made during the High Court Appeal by Castle Point Council to reiterate the County Council’s Policy on exploitation of Green Belt sites, especially those which will undoubtedly have a major impact upon road infrastructure, especially during the cpbc Local Plan process.

Dates, Canvey Islanders won’t even Notice! Thorney Bay’s, on its way!

Canvey Islanders, it is said, haven’t the nous to have a cynical thought cross their little minds.

Firstly, following the Election announcement on the very last day prior to the period of Purdah commencing, the Jotmans Farm Appeal Inquiry was Rejected by the then Secretary of State, thereby saving important mainland Green Belt from development.

Secondly, tomorrow, 6.6.2017, just 2 Days prior to the General Election, castle point council development committee will decide the Recommended Approval “first phase” of the Thorney Bay vast green field development, on Canvey Island.

Thorney Bay Beach Camp, Canvey Island, Essex

copyright Jason Hawkes

This so called first phase at Thorney Bay amounts to 113 new dwellings.

The development committee Agenda paperwork indicates officers advise :

It is not considered necessary for Members to visit the site prior to determination of the application.

This despite :

To the north of the site is the Local Wildlife Site (LoWS) Thorneyfleet Creek, which comprises a water body with Common Reed and rough grassland; beyond this is residential development. To the east is Public Open Space, in the form of a grassed area and children’s play space. To the south and west is the wider expanse of the Campsite. A water treatment works lies to the west of the wider site and beyond this is the Calor gas terminal. To the south is the Canvey Island Sea Defence, beyond which is the River Thames.

Of the Health and Safety Executive’s comment;

..more than 10% of the housing development area lies within the (Calor Gas Hazardous) middle zone….and HSE Advised Against Granting Planning Permission.

The HSE then go onto excuse the proposed development layout, stipulating that castle point council must not in future use the self regulating facility, instead be referring any future development directly to the HSE!

The Case Officer comment, which will no doubt be pointed out to the planning committee members in the Agenda Paper states; 

Health and Safety Executive  No objection.

As far as potential flooding is concerned, especially as the site is directly reliant on the Canvey Sea wall Defences;

Environment Agency  No objection: following the receipt of a revised FRA, subject to conditions and the satisfaction of the LPA that the proposal will be safe for its lifetime

It should also be noted, should the are become flooded yet again that responsibility has been relieved of the Leal Local Flood Authority (Essex CC.);

It is the applicant’s responsibility to check that they are complying with common law if the drainage scheme proposes to discharge into an off-site ditch/pipe. The applicant should seek consent where appropriate from other downstream riparian landowners. 
The Ministerial Statement made on 18th December 2014 (ref. HCWS161) states that the final decision regarding the viability and reasonableness of maintenance requirements lies with the LPA. It is not within the scope of the LLFA to comment on the overall viability of a scheme.

But of course the Rumours emanating from CPBC is that Thorney Bay will become a Park Home site, So None of these Rules Will Apply!

1,600 static caravans could quite easily become 1,000+ Park Homes, and there is the next Local Plan’s 5 Year Housing Supply.

Let existing Canvey Island residents and future property owners be warned!

We make no apology for over-simplifying these issues but for anybody interested the webcast and recording should be available via;  https://castlepoint.gov.uk/webcasting

The meeting Agenda papers are available via; https://www.castlepoint.gov.uk/agendas-minutes-library


Could it Be? Spade Ready – Persimmon Up for a Win Double in Castle Point?

Could it be that with the recent activity around the Canvey Dutch Village area that Persimmon see a potential for developing Canvey Island and Benfleet’s Green Belt off of the Constraints Map?


New paperwork added to the CPBC planning portal for the Dutch Village site and the pending Appeal Inquiry decision on Jotmans Farm indicates no let up ahead of the CPBC Local Plan Examination.

Jotmans Magaret March Benfleethistory.org.uk

Jotmans Farm

It is indication that Persimmons will be one of the strongest critics of the Local Plan2016.

No doubt having two major Green Belt development proposals will put Persimmon in a seemingly strong position should the LP2016 falter.

The apparent lack of a 5 year housing supply to back up LP2016 may also be a factor. Persimmons are positioning themselves in a way that would appear to suggest to the Examining Planning Inspector, that they are “SPADE READY”!

Most appealing to CPBC will be the possibility that persimmon could, handling 2 sites at the same time, devote the Dutch Village site chiefly to affordable homes, leaving the Jotmans Farm venture as entirely market value housing!
Our controllers at cpbc might see the advantage of sweetening the taste for the mainland electorate in that, should it be suggested.

Local Plans are likely to require updating in whole or in part at least every five years. Should the Local Plan 2016 not fulfil the expectation to “boost significantly the supply of housing” during this initial 5 year period Castle Point residents could expect to face having to fund planning appeals! And the likelihood of further appeals in the subsequent years cannot be disregarded should the reliance on the Blinking Owl site H11 be unfulfilled.

The necessity for a 5 year housing supply, is a rolling, never ending requirement of a local authority. An insatiable requirement of land!

How often should a Local Plan be reviewed?

To be effective plans need to be kept up-to-date. Policies will age at different rates depending on local circumstances, and the local planning authority should review the relevance of the Local Plan at regular intervals to assess whether some or all of it may need updating. Most Local Plans are likely to require updating in whole or in part at least every five years.  Reviews should be proportionate to the issues in hand. Local Plans may be found sound conditional upon a review in whole or in part within five years of the date of adoption.

The National Planning Policy Framework makes clear that relevant policies for the supply of housing should not be considered up-to-date if the authority cannot demonstrate a five-year supply of deliverable housing sites. Local planning authorities should also consider whether plan making activity by other authorities has an impact on planning and the Local Plan in their area. For example, a revised Strategic Housing Market Assessment will affect all authorities in that housing market area, and potentially beyond, irrespective of the status or stage of development of particular Local Plans.

Of late this requirement has seen pressure from those in authority at cpbc to approve all development proposals on Canvey Island, except those few that fall into a similar category of the LP2016 policy to protect mainland Green Belt sites from development.

This has seen proposals approved, despite having Holding Objections from the Lead Flood Authority! This level of disregard to important constraining issues underlines the depths our local authority are prepared to stoop.

Once again we venture to suggest that without a Neighbourhood Plan, Canvey Island is defenceless against the power and deviousness of developers.

Castle Point Green Belt development-Damned if you do-Damned if you don’t!

Just to add further to the upheaval that appears to be occurring behind the scenes of the Castle Point Council Local Planning process, news contained within a recent Amber Valley Council announcement gives opportunity to reflect.

The importance of a 5 Year Housing supply appears paramount to Local Plan processes.

Confusion and frustration are introduced when work on sites selected for development within Local Plans, fails to materialise.

This can lead to sites reserved for development at later dates are promoted prematurely. And sites removed from Local Plans and considered protected, become the subject of Planning Appeals.

On one hand the value of Land Banking would be valued in developers accounts sheets and on the other a Local Plan becomes the opposite of its intention; a free for all of un-planned development.

The fact that in Castle Point very little of the promised infrastructure is likely to materialise, little may be made of a haphazard development approach if the above scenario was to unfold.

An emerging Plan for Castle Point may include a new “village” site being proposed. This in itself should through developer contributions assist in new access infrastructure. The issue of Essex County contributing a proportion of the access funding needs clarity.

Other less large sites, should they come forward would only affect traffic wise less strategic junctions, these would be unlikely to receive funding despite what our Local Plan may aspire to!


I will make no suggestions as to the merits or the folly of our councillors having approved the daft New local Plan despite it being the best possible at the time. What it clearly did, as well as officers behind the scenes being motivated to encourage developers to invest time and money in preparatory work on sites in a Flood Risk Zone, was to expose a large number of Green Belt sites that our local authority deemed suitable for development.

Having put on record these intentions may allow a scenario to develop similar to that at the Amber Valley district and lead to an amount of land banking and unfortunate development in  areas within Castle Point.

Readers will have their own opinions as to the future outcome and the rights and wrongs of the next stage of the local process.

It was timely that as this article was posted Greg Clark,Secretary of State for Communities and Local Government,  tweeted a reminder that “Local councils answerable to local people, rather than central government.” All well and good until local decisions are challenged through the Planning Appeals process.

However it is clear residents, those being involved at least, have indicated a preference for a new approach from our local authority. Whether there will be a price to pay in the long run, will be one of a few consequences residents appear willing to take, and face that risk.

Derbyshire local plan withdrawn over housing delivery glitch

by Planning Portal Content Team

A Derbyshire planning authority has withdrawn its local plan from public examination after announcing it could no longer demonstrate a five-year supply of sites which would deliver the council’s objectively assessed housing need as set out in its draft Core Strategy.

Amber Valley Borough Council, a semi-rural local authority, has taken that draconian step after telling the planning inspector examining the strategy that discussions in the past month with relevant land owners and site promoters had revealed that fewer homes than originally anticipated would be available over the five years to 2020. Some 310 fewer dwellings were involved, the council reported.

The council told the inspector: “it will not be practical to achieve a demonstrable five-year supply through the identification of further sites for housing development without revisiting its overall strategy for housing growth. It anticipates that the process of reviewing the growth strategy and reaching a conclusion as to an alternative approach, including appropriate public consultation and engagement, will take at least 12 months”.

Alan Cox, Leader of the Council, said: “I am deeply dismayed that such a decision had to be made at the eleventh hour, after so much effort and expenditure on the process by so many.

“Regrettably, however, despite the fact that there are many sites within the borough that have been given planning approval by the council, the council has no powers to force developers to start building the houses, or influence the timeframe over which a site is developed.”

He added: “The council remains fully committed to establishing an up-to-date local pan for Amber Valley, which will provide a robust set of policies and proposals to support housing and economic growth in the borough, whilst at the same time safeguarding and enhancing the environment.”

View more information

Roger Milne

Hokey Cokey Local Planning and confusing the defence of Green Belt Appeals!

Castle Point New Local Plan Task and Finish group members, retracted the work and decision making they had made during their previous meeting.

The proposed Housing development site H18, the Blinking Owl site having previously been decided to suspend background work upon until the Constraints issue had been re-visited, had that decision reversed so as to direct officers to continue seeking supporting evidence that H18 was a viable proposition.

The Local Plan process is appearing to be going through a period of taking one step forward followed by a another step backward.

The decision to re-visit was, in part, considered a re-plugging of the breach of defence that Castle Point Council will offer in protection during the Jotmans Farm and Glebelands Appeal examination.
It appears that there has been a shift in Planning Guidance in that the previously “all deciding” need for an immediate 5 Years worth of Housing supply, has been relegated in favour of a requirement that, a Local Plan is continuing to progress towards a final document.
It now appears that being able to evidence a 5 Year Housing Supply is not as crucial as we were led to believe.
Or is it? Are we simply being told what suits policy makers at the time of delivery?
Whether confidence in this change of guidance will alter should local authorities extend their “work in progress” into an endless timeframe remains to be seen.
Until then it makes sense, ahead of two possible Green Belt Application Appeals, to use this tactic.
The Task and Finish agenda paperwork, again reminded members of the NPPF principles, that preparation of a Local Plan should be; Positively prepared, Justified, Effective and Consistent with national policy. The agenda paperwork then reminded members that “the Council has undertaken considerable work on developing an evidence base” and that “it is on this evidence that the policies and proposals within the Local Plan should be based if it is to meet the tests of soundness set out in the NPPF.”
Seemingly an officer’s warning that by re-visiting the H18 proposal as a priority, the Local Plan progress may be in danger of becoming unsound.
The fact that Castle Point is without a 5 year Housing supply, 0.7 years worth in the reckoning of the Glebelands Inspector, remains so far un-addressed by the Task and Finish committee.
This may be due to the 5 Year supply not being part of their remit. Then again the original remit of the committee appeared to be to simply consider the responses to the draft Local Plan’s consultation, prior to returning to full council with a recommendation.
There will be consideration on whether extra CPBC funding is to be allocated to appoint consultants Peter Brett to evaluate the viability of the H18 proposal.
Officers reminded members that should the Blinking Owl site be released for housing,  Castle Point Council would be undermining one of the main functions of the Green Belt in that area, that is to keep neighbouring districts from merging.
A decision would require a decision on what width of Green Belt does retain that function, ie 25 metres or 50 metres etc. The other option is that the whole of the site is taken out of the Green Belt and the area opposite, across the A127, Rayleigh Green Belt is solely relied upon to perform the required function.
Either way a decision by Castle Point Council, possibly objected to by Rayleigh, would have to be made.
This decision would then possibly undermine local opposition to other Green Belt housing proposals in other parts of Castle Point, chiefly alongside other main highways such as Jotmans and Glebelands, where the particular function of the Green Belt, in protecting districts from merging, is supported by neighbouring district’s land, during development Appeals.
The “new” Castle Point policy of defending Green Belt unless it has any examples  of development on it, theoretically only adds to the area of Green Belt that may become available for release. Other areas that poorly support the function of Green Belt but also are supported by developers will be found difficult to defend at Examination, unless sufficient sound evidence is available.
Site H18 contains some development, it is also linked along the A127 to other Castle Point land previously released for development. This in turn links to the released Green Belt across Rayleigh Road where the Fire Station is situated.
Therefore it is fair to say that the integrity of the Green Belt within Castle Point is allowed to be compromised when it suits!
What residents should be aware of, once these perimeter assets are conceded, is that the areas between these “new” sites and the existing urban areas may become available as “infill.”
This is one of the difficulties developed over many years in defending the area around Felsted and Bowers Road and why the Planning committee did not use loss of green land as a reason for refusal, despite the areas obvious amenity value, and was included in the Local Plan’s 5 year housing supply.
In re-visiting the viability of the H18 site access will be an issue, especially for County if a new access onto the A127 is considered necessary, and residents if the existing road network is to be expected to alone support the new development. If the H18 site is to reach its full potential then a new access onto the A127 will be critical.

Castle Point residents may need to be prepared to contribute financially alongside developers and Essex County Highways. Should funding be required to come singularly from County then the scheme will have to join a long list of aspirational improvements, not only in the Borough with Canvey’s new access road and Roscommon Way final phase, but other County projects.
Meanwhile the New local Plan Task and Finish group turn their attention to the subject of housing constraints.
It will be interesting to hear how, after the exhaustive discussion on mainland green belt, members value the safety concerns of living within range of hazardous industrial installations and within a Flood Zone, as on Canvey Island, when considering what constitutes an actual Constraint and the weighting they consider should be applied through the Local Plan!

This work commences this week and will be available to follow  on the Castle Point Council’s webcast.

Glebelands – Has time just run out on this piece of Castle Point Green Belt?

“You win battles by knowing the enemy’s timing, and using a timing which the enemy does not expect.”

News has filtered through that a new Appeal Inquiry has been launched for the Glebelands housing development proposal.

The timing is most intriguing, an expected hearing date during March.

The result may not be available until General Election time.

Does this mean that there is a possibility that the Secretary of State would not call in the decision? Allowing the Planning Inspectorate to decide.

Previously the refusal to develop has relied on the fact that Castle Point Council have been busying themselves with producing a Local Plan.

However this has proved, even since Mr Pickles’ decision, a timely exercise.

Last weeks Local Plan Task and Finish group meeting heard officers suggest that the addition of site H18, the Blinking Owl site, would quite possibly only add to the Green Belt sites available for development, rather than be in place of some named sites!

It appears this time consuming progress of the CPBC Local Plan may have led to an opportunity for the Fox Land and Property group to take advantage of the political calendar. The period of purdah may prevent some wishing to give evidence in defence of the Green Belt at Inquiry.

With Glebelands watching in the wings this will indeed be a test for Castle Point Council.

Much of the previous Appeal finding relied on the timetable and progress of the Local Plan process.

Officers suggested adhering to a strict timetable was achievable.
The 5 year housing supply / or lack of, may well also be a stumbling block for Green Belt campaigners despite cllrSmith’s re-assurances.

Extracts from the Appeal application paperwork suggest otherwise:

Progress of the Local Plan remains stalled since 2006.

 Reason for Refusal 1

that there are in actual fact a number of ‘very special circumstances’ under which the appeal proposal should be released from the Green Belt (as set out above), and believes that the proper consideration of this issue will require detailed evidence to be presented and tested in respect of policy compliance with the Framework; the current housing land supply position in the Borough; the need for affordable and market housing in the Borough; and, the contribution of the appeal site to the functions of the Green Belt and its suitability and a sustainable urban extension.

Reason for Refusal 2 states that the appeal proposal is premature to the emerging Local Plan, and so would prejudice the plan’s ability to allocate land for housing at the strategic level. Again, the factors that inform this position are complex and will require cross examination to determine at what stage in its development the emerging Local Plan is currently and to what extent the appeal proposal is of the scale and significance necessary to prejudice the planmaking process.

Following the previous Appeal the Secretary of State amongst other considerations found:

Housing Land Supply

The Secretary of State agrees with the Inspector’s analysis of housing land supply at IR297-334. He share’s the Inspector’s conclusions that the requirement figure for assessing the 5-year forward supply should be 2,350 dwellings (IR323). Whilst the Secretary of State broadly agrees with the thrust of the Inspector’s overall conclusions on land supply and housing delivery, as set out in IR335-340, he does not agree with the Inspector’s comment at IR339 that the current programme for adoption looks somewhat optimistic, especially in the light of the Council’s experience with the now aborted Core Strategy (CS). In the Secretary of State’s view, whilst the now withdrawn CS was in preparation, there were no real drivers to ensure that the Council pressed ahead. With the publication of the NPPF, he is more positive than the Inspector that the Council can achieve its’ programme for LP adoption, especially given the drivers within it.

While he also agrees with the Inspector that there have clearly been difficulties for many years in planning for sufficient housing in Castle Point, he does not consider that this history means that the task of preparing a new local plan cannot be accomplished easily or quickly (IR359).

The Secretary of State has found that there are factors in favour of the appeal including a severe lack of a forward housing land supply and that, setting aside GB considerations, development of the appeal site would not cause demonstrable 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.

Whilst the previous Appeals Inspector’s findings revealed:

In Castle Point, there have clearly been difficulties for many years in planning for sufficient housing. The LP failed to plan far enough ahead. The long-term reserve sites all turned out to be poor choices, because none came forward to fill the gap.

The CS took too long to prepare, and in the end failed because the housing provisions were inadequate. In the light of this history, it cannot be assumed that the task of preparing a new local plan will be accomplished easily or quickly. Although it is right that planning decisions should be plan-led where possible, the Council’s own action in announcing a list of preferred housing sites, in advance of having any kind of draft plan , seems to acknowledge that some decisions will not be able to wait for the new plan to be in place.

It is difficult to escape the conclusion that this must be related to the lack of any up-to-date or adopted local plans, or relevant DPDs, since 2001. The lack of housing delivery in 2001-12 therefore seems to reflect a failure in terms of planning, rather than any failure of the housing market.

It is common ground amongst all those involved in the appeal that the task of finding suitable land for housing in Castle Point is not an easy one. The Borough has severe constraints, including the already high density of development, the close spacing of existing settlements, the widespread flood risk, the SPA, and the relative scarcity of suitable land. In the light of these constraints, the Council has acknowledged that there is a need to take land from the Green Belt, even for the lower level of housing provision that they currently propose.

Other than GB considerations, development at the appeal site would not cause demonstrable harm. There appear to be no particular constraints on delivery, and the site could thus make a valuable contribution to the District’s housing needs in the short term.

The development would not conflict with any development plan policies. Nor would it conflict with any policy in the NPPF, apart from the loss of GB. The protection of GBs is one of the Framework’s core principles, but it is not the only one, and may be outweighed in very special circumstances. Boosting the supply of housing and delivering sustainable development are similarly important. In all respects other than the loss of GB, the present scheme would represent sustainable development.

On the other, there is the severe lack of a forward housing land supply; the acute shortage of affordable housing; the Council’s very poor track record in delivering all forms of housing in the past; the past failures of the development plan process in the area, and consequent delays in the release of land through that route; the acknowledged need to release GB land; and the suitability and availability of the appeal site.

Castle Point Council may find difficulty in mounting a reasonable defence to these issues, given recent investigation work. However Green Belt campaigners will wish them well. It would be a shame if these recent investigations have in themselves caused an issue for Castle Point Green Belt.

What cannot be denied is that progress on the Local Plan has once again fallen way behind schedule.

Castle Point Local Development Scheme January 2014

Key milestones (for the Local Plan) are as follows:

Issues Consultation (Reg 18) Jan-Mar 2012

Draft Consultation  Jan-Mar 2014

Submission Consultation  Jul-Aug 2014

Submission Sep 2014

Examination Dec 2014 Inspectors Report

Feb 2015

Adoption Mar 2015