Tag Archives: Canvey Green Belt Campaign

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.

 

 

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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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Canvey Island Dutch Village Estate “doers”, Get the Job Done! In the process they Embarrass the local authorities! Time to streamline local Council officialdom?

The treatment of Canvey Island residents, fronting and affected by the many Un-made Roads on the Island is nothing short of Shabby!

Whether it be the original developer, the old Canvey Island Urban District Council, Castle Point Borough Council, or that fine hierarchy that is Essex County Council, all have shunned responsibility where the situation of road maintenance and improvements are concerned!

20180824_113426

Even protracted legal discussions between ECC and CPBC have failed to reach a final decision on who should be responsible for changing the street light bulbs.

It is common knowledge that frontagers of these roads are ultimately responsible for the upkeep of the road surfaces, however why have so many of these roads been granted permission to be constructed in such a temporary fashion?

Permission for the substandard access roads would have been granted in the first instance, across many developments by the local authority, we assume that a financial “contribution” for the roads eventual making-up would have been levied upon the developer.

It would appear that these funds may have been put into reserves by the old Canvey Island UD Council. These funds would then have been absorbed into the coffers of the Castle Point borough council when it was then formed.

Essex County Council is the Highway Authority.

Government have given legislative guidance that:

“Section 230 of the 1980 Act empowers the ‘street works authority’ (i.e. the county council or unitary authority) to order the frontagers to carry out repairs to a private or unadopted road which are “needed to obviate danger to traffic”. The legislation also allows the authority to carry out the work itself if the order is ignored and to recover the expenses incurred from the frontagers.

Section 230 of the 1980 Act may only be invoked where repairs are needed to obviate danger to traffic. In other cases a highway authority may decide that a private or unadopted road should be made up under the Private Street Works Code (PSWC), set out in sections 205 to 218 of the 1980 Act.”

There has long been friction and complaint in the instance of the Dutch Village Estate roads. Many approaches have been made through official and direct channels for action to be implemented. Residents on the estate both of the unadopted and adopted roads wished to just have a reasonable and safe surface to access the estate whether on foot, by vehicle or by mobility vehicle means.

Given that, as further above, it is likely that monies were held and passed on between the two local authorities and that the ECC as Highways Authority have the authority to have the works carried out and collect the funds to pay for the improvements.

It could also be suggested that between the 3 local authorities some responsibility to contribute to the works is fairly obvious, having received developer contributions and having collected a proportion of council taxes towards Highways!

Instead all approaches, as you may expect from our local authority, were Rejected! Not just recently, but going back some many decades, so austerity cannot be upheld as a viable reason.

Many years ago MP Sir Bernard Braine intervened on a few residents behalf. When he did, Castle Point borough council jumped, to get Highways work implemented. Those days are long past.

It is only fair to note that Cllr.Howard has over many years shown support on unadopted Highways improvements, and endeavoured to assist in achieving some progress. However the local authorities controlling Canvey Island have collectively frustrated and failed the residents.

Contrast this with Cheshire, where many years ago the local council realised the predicament that homeowners had found themselves in and decided to take some action on the issue!

“It is proposed that Cheshire East Council should have a policy for dealing with urgent repairs to private streets where expenditure is limited to £500 in any one street in any one year and that the budget for repairs to private streets be limited to £5,000 per annum where overall budgets allow this. The budget shall be managed by the Highway Manager.”

Contrast this with Castle Point borough council’s almost prehistoric position indicated within the Adopted Local Plan thus:

POLICY T7 – UNMADE ROADS THAT IN ALL APPLICATIONS FOR THE INTENSIFICATION OF DEVELOPMENT SERVED BY UNMADE ROADS, THE COUNCIL WILL SEEK APPROPRIATE IMPROVEMENTS TO THE HIGHWAY. 

Never has a Policy been more appropriately considered;  too Little, Too Late!

Cheshire recognised the difficulty of a group of individuals to organise themselves as a collective, given the usual fractured communities we find these days, and have taken an initiative to offer some recourse to residents with a dangerous or deteriorating road surface is concerned.

What it has taken, in the case of the Dutch Village,is a very determined, very small group of residents to organise estimates, financial contributions and works to resolve the implementation of a flat road surface that all will benefit from, whether emergency vehicles with seriously ill patients, residents and their visitors and, not least and ironically, Council Refuse Vehicles which have been responsible in no small part for a level of damage to the old road surface!

Some of the funding has come from nearby residents not financially responsible for the Road requiring repair, some residents, with responsibility may have not been in a position to contribute, others owning but letting out property, may not have proved contactable.

Little wonder that a Policy on these and similar Roads should be forthcoming from Castle Point borough council! It is long overdue!

Few would argue that an Unadopted Road tax precept could not be charged on Council Tax payers, either generally or specifically on frontagers of Unadopted Roads, so as to build up a Ring Fenced Fund for the purpose of repairs. After all Canvey Islanders are charged an extra precept for our Town Council, police etc.

Look at the photograph above, and ask whether it is fair for residents to be left to organise such work themselves, especially given the Flooding issues on Canvey Island.

This has been quite some undertaking as nowadays many residents lease their properties thereby not being the owners responsible. The Canvey Green Belt Campaign were happy to allow the use of their bank account. And without a Residents Association the “bringing together” of all of the loose ends deserves great credit to the residents organising this undertaking!

Especially as the short length of road concerned is costing some 10’s of thousands of £’s !

It occurs to us that what is actually needed is some type of collective responsibility in the form of an elected group with powers to implement improvements, general maintenance, contracting resources and planning for future issues.

But then we came to the conclusion that what we really need is a Council fit for purpose!

What these Dutch Village Residents will have achieved, has been done despite councillors and officers!

So perhaps with these heady days of strategic planning, with the likes of the grandly titled “Association of South Essex Local Authorities” (ASELA) or “The Thames Estuary 2050 Growth Commission”, both of which Castle Point council are an eager part of, it is now time to reduce the burden on the local tax payer and abandon the layers of executive “professional”officers at local authority level and reorganise a single authority for decision making across the region with lesser devolved powers implemented at a local level.

After all, in this instance the local authorities have failed, and continue to fail the people they are supposed to represent and carry out duties on behalf of, the Local Residents!

Despite the many unmade roads in the Borough, I cannot see many achieving what these Canvey Dutch Village Residents have achieved.

Hats off to them!

Daily Mail Photo

Responsibility for street lights on unadopted roads denied

Canvey Green Belt safe? Really? Probably as Safe from Development as Jotmans Farm, or Even Less So!

Canvey Islanders are right to be fearful of both Castle Point Council and the Government chief planner, as between them they concoct the next Local Plan for the Borough.

Why, because it appears previous promises and assurances that Canvey AND the mainland’s Green Belt is not in danger of being released for development, are worthless!

Anybody that has visited the cpbc Local Plan consultation Portal, will have noticed that all Green Belt sites considered and promoted for development in the daft 2014 Local Plan, including those rejected and omitted for the Local Plan2016, have now reappeared for consideration!

Directly below are just some of the sites that cpbc Leaders and officers are “considering” including in the list of sites released for development.

You will note that this will affect West, South and East Canvey Island, with knock on effects across the whole of the Island AND south Benfleet, when Traffic, Commuting, Doctors, Hospitals and Schooling are concerned!

Sites appearing in the LP 2018 consultation questionnaire include:

 Do you support the potential residential development at land east of Canvey Road?  Otherwise known as the Dutch Village fields or Corn fields.

Do you support the potential residential development at land fronting Canvey Road? Land alongside the Dutch Cottage

Do you support the potential residential development at land at Thorney Bay Caravan Park, Canvey Island?

Do you support the potential residential development at land at Point Road, Canvey Island?   The Canvey Supply and surrounding Business area.

Do you support the potential residential development at land west of Benfleet? (Jotmans Farm).

Plus other mainland Green Belt sites, making up the list. And of course the other sites we know about, such as the Paddocks, The Jellicoe etc are extra to these!

And yet we have been assured ahead of elections and announcements that the Borough’s Green Belt, at least those sites considered “Virgin” were all protected.

How very disappointing to hear and read the council leader and officers and Government chief planner are now making completely different noises.

We hear NO Dissenting Voices, and our local newspaper, the Echo, appears to be under some level of censorship from cpbc!

As an illustration of the change of direction, reproduced directly below is our Blog post dated 6th October 2017. In it is included a message from Cllr Sheldon, a councillor with good connections to have spoken knowledgeably on Castle Point’s Green Belt situation.

One must ask, “where did it all so horribly go wrong?”

“THE DECISION STANDS. JOTMANS WILL NOT BE BUILT ON.”

Following the Secretary of State’s decision following the Appeal inquiry into the proposed Jotmans Farm Green Belt Housing Development, the developer registered a High Court challenge over the decision of the SoS and Castle Point council.
CPBC Councillor A. Sheldon has issued this notice:

Dear Residents,
I have just received the news that the Developers have not been granted permission to appeal the Jotmans decision by the Secretary of State!!!
This means that no appeal hearing will take place.

They made an application for an appeal and it got refused!!!

THE DECISION STANDS. JOTMANS WILL NOT BE BUILT ON.

I have received word that they are looking to get this decision reviewed (the decision not to review the decision…..), but I am confident this will get thrown out. With every unsuccessful legal bid they make, the case they have grows weaker and weaker. As your local councillor I will keep on monitoring this and keep you updated.
Our message to the developers: “Democracy has won. Take your money and build homes on sites the community want, not ones that are easy”.

Well done again to all those who kept the faith and supported our cause. I also want to thank the Jotmans Farm Action Group who fought this application hard from day 1.

We can all rest that little bit easier now.

We are not completely out of the woods just yet, but we one last step away and I will be dammed if I am going to let anything make us stumble now.
I will be putting out a letter to let the rest of the estate know at the weekend and if anyone could volunteer to deliver their road I would be grateful.

Kind regards,
Councillor Andrew Sheldon

Jotmans Farm SAFE!

Jotmans Farm Safe!

Photo: Echo Newspaper.

Canvey Island, Flooding, Over-Development, Local Plan, draft NPPF Consultation and the National Flood Forum. Unrest Grows!

Canvey Island, is synonymous with Flooding.

rebecca_harris_mp_flood_free_homes

Despite the tragedy of 1953, the major Surface water Flooding of 2014 and other similar events, Canvey is cynically treated as a “Special Case”. This is so that Housing Development, Park Home expansions can continue unabated.

These new homes are sold to unsuspecting buyers, with little reference as to the likely problems in obtaining House Insurance against Flooding on New Builds, since January 2009.

All so that the expectations of a New Local Plan are fulfilled.

The Castle Point Council Strategic Flood Risk Assessment, undertaken by Scot Wilson to comply with the demands of the failed Core Strategy in 2010, identified Canvey Island being “At Risk” from Flooding!

Consequently a Reason had to be “invented” so as to permit all, from Small to Large site Housing Development on Canvey. CPBC’s officers, at the behest of certain councillors, cosied up to the Environment Agency and the Strategic Flood Risk assessment was Distorted to permit continued over development!

Since then no developments are Rejected in principle by cpbc on Flood Risk grounds. CPBC claim that for development to serve, and the continued growth of Canvey Island, the development MUST be ON Canvey Island. As though Castle Point is a massive Borough divided by language barriers and with miles of sea between us and the mainland!

The draft National Planning Policy Framework (NPPF) has recently been consulted upon. We, the Canvey Green Belt Campaign Group, have monitored the submissions, especially where Flood Risk is concerned.

We found that the group known as the National Flood Forum have submitted comments that identified issues most relevant to Canvey Island.

And that if our local authority “Ruling Party” and our new leader, are unwilling to truly represent Canvey Island Residents, at least the National Flood Forum have quite capably stated OUR Position

We make no apologies for this being a long read, but we ask you to at the very least skim through it and allow the relevant issues trigger something in your mind, if you were affected in 1953, 2013, 2014 or have been concerned or affected by Flooding at any stage.

The NPPF Consultation has closed, however we have failed to discover a published response to the consultation from Castle Point Borough Council, perhaps one of our councillors may be able to direct us to the document, if it exists.

The National Flood Forum’s submission the draft NPPF consultation, with highlighted passages of some significance to Canvey residents, reads:

The National Flood Forum is a national charity dedicated to supporting and representing communities and individuals at risk of flooding. We do this by:
1. Supporting people to prepare for flooding
2. Helping people to recover their lives if they have been flooded
3. Working with government and agencies to ensure that they develop a community perspective when addressing flooding issues

As part of the flooded community, the National Flood Forum is a charity that supports communities to tackle the things that matter to them; creating hope and reducing the fear of flooding; helping people to work together to reduce flood exposure and its impacts, both physical and emotional. Over 300 flood groups are affiliated to the National Flood Forum and this response has been developed from their many comments.

The National Flood Forum regularly deals with a range of scenarios:
1. New developments that have flooded or which are likely to flood because, for example, SuDS measures are at capacity under normal weather conditions, or sites have been built on areas that are waterlogged
2. Developments which have apparently caused flooding elsewhere, or are likely to
3. Planning applications and decisions that do not make use of local knowledge of flood risk issues
4. Development planning that does not make use of local knowledge

The result is that people become extremely fearful of the future, distrustful of those in authority. This can appear as either apathy or combative behaviour.
“We had a housing estate built up in Eyam and they concreted over a large natural drainage point. And that’s in the Peak Park which is supposedly highly regulated. It’s a shambles. If you have a lot of money you can do what you want.”

Caterham Flood Action Group are also angry:
Hey “To briefly explain, our community has been blighted by surface water flooding for over twenty years, development has continued, responsibilities have been fractured, affecting maintenance (tantamount to neglect) of the delicate drainage infrastructure leaving residents in fear of precipitation.

On the 7th June 2016, after campaigning and complaining for almost two decades, the great storm wreaked havoc, destroying homes, devastating families, trapping our vulnerable and elderly neighbours for hours without power, as rivers of raw sewage flowed into our homes, through the streets of Surrey across the administrative border into a London Borough (contrary to the draft London plan, Policy Si12 B, which states ‘Boroughs should co-operate and jointly address cross-boundary flood risk issues including with authorities outside London’).

The CFAG must question if measures really are in place to guarantee that councils on the edge of the London Basin are considering the quality and capacity of the infrastructure ‘downstream’.

Paragraphs 154 – 163 of the Draft NPPF are an improvement on previous versions. But Caterham Flood Action Group, and others, do not believe that the Draft NPPF addresses their concerns that people will be put at risk of flooding.

In particular, policies and guidelines need to be much more ambitious if we are to create places that people will want to live in, that are adaptive to the future (such as being able to absorb more development) and where people feel safe.

Policies need to be translated in to action and many of the concerns from Flood Action Groups are that even the existing policies are being ridden over roughshod, with no recourse for affected communities.

The National Flood Forum strongly refutes the notion that flood risk can be outweighed by the economic benefits to the community and does not reflect the absolute misery flooding problems can cause to those involved.

The current wording in the draft NPPF virtually establishes that flooding is acceptable and provides opportunities for those who wish to find loopholes to do so. If development impacts even on a handful of households/properties, then it’s not a benefit to the community. For example, words such as “safe” in paragraph 154 are ambiguous. Whilst no one can ever be without flood risk, the wording here and in wider guidance needs to reflect community perspectives on safety, risk and what it means to feel resilient.

Data from the Association of British Insurers shows that 50% of insurance claims for properties flooded during the winter of 2015/16 were from areas that had not been identified by the public or private sectors as being at risk of flooding. In previous years the figure was sometimes higher (80% in 2007) and never lower, indicating that our understanding of flood risk and the flood risk maps available only cover a proportion of the risk. Surface water, groundwater and combined risks in particular are poorly understood.

For these two reasons greater stress should be placed in the NPPF on the rigour that is required to assess flood risk through all forms of Food Risk Assessments.

The biggest complaint from Flood Action Groups across England is that people’s local knowledge about their area is ignored, resulting in poor decisions about their future. People frequently have knowledge about their local area that professionals do not; details about previous flooding incidents, underground drainage, old drainage systems, etc. Modellers will frequently say that their modelling work simply produces useful tools and does not represent the real world exactly.

It will often lack local information to put in to the model and the parameters through which the model works will have limitations on the accuracy of what results. However, in the planning system models are often regarded as the absolute truth in the decision-making process and other evidence ignored. Communities regularly complain that this is the case. This can include information about local drainage patterns and historic flooding incidents through to the routes of major flow channels, groundwater levels and sea level rise. Therefore, development plans and planning applications should demonstrate how they have listened to local voices and how those views have been taken in to account in developing proposals. In particular they should demonstrate how triangulation has occurred between modelling, local knowledge and other forms of evidence to arrive at the most reasonable answers.

Paragraph 156) demonstrates an improved level of ambition, but not significant enough if we are to tackle flood risk seriously. The example from Shipston in Warwickshre below illustrates the point:
“The NPPF requires new developments to achieve ‘flood neutrality’ as a minimum i.e. that water run off post development should be no worse than the pre-developed site.
We work with our Town Council and the developers in negotiating better than flood neutrality at or before the planning stage and have had some success in getting their drainage strategies to achieve betterment – in most cases within the range of 25/40%.
With modern SUDS systems, their creative application and a willingness to meet improved objectives this is perfectly achievable at relatively low, if any, ‘on cost’ and of course the whole concept of betterment is essential with the increasing pressures brought about by adverse climate change trends and as a community support programme by developers.

We are concerned that the present policy is simply not ambitious enough and consider that a policy of betterment should replace the current ’neutrality’ policy.
Further, whatever the policy, specific local ground and geological conditions should be taken account of when determining the adequacy of drainage strategies by the LPA’s.
In our area Warwickshire clay is the predominant soil type and is almost completely impermeable so a literal ‘greenfield’ site in this area will already have a pre-existing high level of surface water runoff.

Further, should such ‘greenfield’ site have been used for grazing it will be highly compacted making the situation even worse.
Even further, should the site be sloping down to other developed areas great care needs to be taken to design a drainage strategy that absolutely reduces run off compared with the pre-existing situation.

Finally, the requirement that developments of less than 10 dwellings do not need LLFA oversight in giving guidance to the LPA (if different) should be reduced as it seems clear that developments of 9 or less are deliberately introduced perhaps to circumvent properly qualified scrutiny.
At present, it appears that the LPA’s simply have to check that a drainage strategy meets the NPPF guidelines which, in the circumstances described above, would likely be completely inadequate.

Once new developments are built to inadequate drainage standards in their specific local context there is no going back so this consultation is a once off opportunity to address the issue and build better resilience for the future into such developments.”

Para 158 a) contains an assertion that where there is no other option it is acceptable for a development to take precedence over people’s lives, however traumatic the outcomes might be. This is simply not acceptable and should be deleted. Developments that put people or their neighbours at a significant risk of them being flooded should not be built, whatever the pressure for new housing. Areas in Flood Zone 3, where there is significant groundwater (such as permanently within 150 cm of the surface) or significant drainage limitations should not be built on.

Where there are wider societal benefits identified, the risks of any new development should be transparent, so that businesses, infrastructure providers can make judgements about the level of risk that they are prepared to accept.

Para 160 – footnote 41. The site-specific flood risk assessment should triangulate modelling, local knowledge and other evidence. The assessment should proactively seek out local knowledge and demonstrate how this is used to develop an overall assessment. Guidance should be updated.

A common failing of current developments is that drainage plans are developed after the site layout has been determined. Retrofitting a drainage plan to a site can be difficult and lead to inferior results. Drainage plans should be submitted for all outline planning applications and should detail measures to manage water during the construction phase. The example from Charlton Flood Action Group, Worcestershire below illustrates the point.

“The Plan [South Worcestershire Development Plan] does not make any reference to the Environment Agency designated “Rapid Response Catchments” of which the Merry Brook is a very High risk one.
To minimise future flood risk in these particular vulnerable catchments we believe the plan should make reference to these Catchments and further that when any development/planning application is being agreed in these catchments that the conditions of planning should require that:
• Any flood prevention schemes should be put in place prior to the development of houses and other infrastructure being commenced. (During the last few years the development of the housing estate at Hampton, Evesham was commenced with top soil being stripped off the land. Those living in Charlton noticed that the water levels in the Merry brook increased far more quickly due to water running draining off the site. It was only when we started complaining that thought was given to installing the retention ponds and there was then a further delay until weather conditions were suitable).
• That in these catchment areas the water run off levels should be half the normal levels allowed. This should be achieved either by reducing water run-off levels or where this is not possible by the developers installing recommended schemes suggested by the Environment Agency – such as ponding on water courses.
• That all suggestions recommended by the Environment Agency should be installed. (At the Hampton development the Environment Agency had suggested that some ponding take place on the Merry Brook to help reduce water flows. This suggestion was totally ignored).
• That on small / single developments where planning consent is being sought that water run-off be considered and reduced to a minimum. Should there be a small water course running through the site then ponding/other means to reduce the flow should be installed.
• That any work on Highways in Rapid response catchment areas should also involve the installation of measures to reduce the flow of water into water courses.”

161 a) It is difficult to imagine situations where “overriding interest” applies. This clause should be removed, otherwise it will be used to push through inappropriate developments. The overriding concern must be for the wellbeing of people.

161 e) There is some confusion amongst Risk Management Authorities as to which organisation should comment on this aspect of planning applications. This needs clarification
Note 42 does not adequately cover the risks posed by surface water, ground water and combined sources. With at least 50% of flooding incidents involving surface water, this aspect needs particular attention to ensure that people are kept safe, whereas the focus of attention in the guidance is on fluvial flooding because that is where the better evidence base is. Surface and groundwater risks are often highly localised, but the trauma that is caused can be significant because often there is no scheme available that meets benefit cost criteria for investment. Rapid response catchments pose a particular risk. The result is that people continue to suffer without the prospect of ever escaping from the threat. In addition, the National Flood Forum’s experience is that people are increasingly finding it difficult to sell their home, restricting their ability to change employment, move closer to family, etc. Therefore Note 42 should explicitly refer to areas of high surface water and ground water risk, combined sources of flooding and rapid response catchments. The quote from the Food Action Group in South Woodford Ferrer, Essex, illustrates the point:
“We are currently doing our best as a voluntary group to try to alleviate a recurring fluvial/sewage flood in our local area. We are now in 2018 and still do not appear to be able to assist the residents of our town to have a better quality of life. Funding issues and OFWAT regulations leave local residents baffled as to what they can do to resolve this horrendous flood and sewage discharge situation. These flooding events appear to be occurring every 2 years (2012-2014-2016) ….surely this can’t be right? We do understand that funding is a problem but by working together we should be able to come up with a solution for these poor people living with the prospect of a significant flood every time there is a heavy rain fall.”

An area may be in Flood Risk zone 1 but at very high risk from surface water. However, reference to Flood Zone 1 will frequently allow developers to push through schemes in very high surface water risk. The point is well made by Caterham Flood Action Group:
“The Draft NPPF supports small sites being identified, essentially promoting ‘garden grabbing’, to reiterate we’re aware of the need for homes BUT in a surface water flood risk areas, we can confirm this has had devastating results over the decades, hence the need for SuDs in ALL development and retrofitting (refer to 1.2). YET 71) resists ‘inappropriate development in residential gardens, where development would cause harm’… But as we’re technically in a ‘flood zone 1’, on paper there’s NO risk, therefore development is be permitted (refer to 3.3), hence the desperate need to ensure policy guidance is ‘joined up’”

163 Minimal operational standards for Sustainable Urban Drainage systems should go beyond normal and projected normal rainfall events, with or without taking account of climate change projections. Whilst systems are unlikely to cater for every eventuality, they should be designed to cater for abnormal events, occasions where soil moisture levels are full and a series of events over a short period of time.
In some areas SuDS schemes will be inappropriate due to high water tables or permanently waterlogged soils. It may be possible to pump dry sites, but this has carbon emission issues and pumps failure does happen. In these cases, it is especially important to have a full and detailed drainage plan.
Developments currently have a right to connect to sewerage and drainage infrastructure. The National Flood Forum experience is that this may place other people at higher risk of flooding and we deal with people whose homes may not have flooded for 40-50 years, but who suddenly find that they flood every couple of years or more frequently with sewage once a development takes place. Sewerage and drainage undertakings must have the ability to refuse to connect to new developments where appropriate infrastructure is not currently in place.

Many of the issues and concerns that people in communities have relate to the skillsets and resources in drainage and flood risk management in local authorities, particularly planning authorities. These are hugely variable. It is important that Lead Local Flood Authority and Planning authorities have a qualified flood risk managers and drainage engineers to support the planning development and control process. In many cases the lack of the skills to critically examine proposals and applications has led to a failure to spot problems or allowed poor design. Whilst not a consideration for the NPPF, it is a major component of the many failures to see it applied appropriately.

Enforcement is a concern for many communities. Where there is unauthorised development or where there are planning conditions, it is a common experience that these are not enforced effectively, leading to increased flood risk for occupants and/or neighbours. The quote below from a flood group in Essex illustrates the problem:
“As regards, unauthorised development, the local authority (XXX District Council) does not seem to have adequate staff to deal with this by planning enforcement.”
Communities have sometimes worked with developers to bring forward better designs, using their local knowledge. The willingness of developers to engage meaningfully with communities has been very variable, with markedly different approaches even within the same settlement. There should be an expectation in the NPPF for developers to work with communities meaningfully to develop better designs delivering multiple benefits, rather than just running a consultation.

The Paddocks no plan, “Project”. Highlighted as an Example for Castle Point Council of How Not To introduce a Plan!

The Paddocks, seemingly a building close to Canvey Islanders hearts, and apparently for which there are no Plans to demolish and replace with a smaller version, with a Housing development on the site.

Paddocks

The Paddocks community centre, Canvey Island

Interesting then that this extract should appear in the cpbc Peer Challenge Report;

“The Paddocks facility on Canvey Island is a clear example where an inclusive approach to developing the Centre will lead to joint ownership and subsequently better outcomes for the community it serves. The Peer Team heard how communities and their representatives are keen to be involved from the earliest stage to final completion, through improved communications and engagement, so that such developments can, where appropriate, be co-designed and fit for the future.”

Clearly the Peer Challenge team identified issues surrounding the way the Paddocks future had been “suggested” to Canvey residents, critically the Report noted:

“The Council would benefit from greater co-operation and joint-working between all councilors,(sic) celebrating the unique places they represent, but also working together to allocate time and resources equally between the different communities. This would involve communities affected by emerging projects from the earliest opportunity to create ownership of the issues, the journey and share pride in the outcomes. An example that could benefit from this more inclusive approach are the issues around the Paddocks Leisure facility. ” 

Whilst the Report was complimentary of cpbc’s handling of finances; “CPBC has sound budgetary processes in place as illustrated through its latest Statement of Accounts”, there appeared much that the Peer Team were critical of.

More to follow from us on the subject.

In the meantime, the full Report can be found HERE.

Riley+marchant

 

Persimmons seek Change of Use of Canvey Island Green Belt Land, with Stable Block for just 3 Horses, whilst Profits impress and Residents unaware!

On first glance it might be puzzling to explain why Canvey Island should be the first choice for Persimmon Homes to expand their successful business interests into the world of Equestrian pursuits at the Dutch Village on Canvey Island!

Persimmon’s profits more than triple over five years to £782.6million in 2016.

And yet they have registered a Planning Proposal with Castle Point borough council;

18/0118/FUL | Erection of stable block with adjoining hay storage/tack room and associated landscaping, formation of access track together with the change of use of land.

Persimmon, this mighty developer, seeks to enter into Equestrianism with a 16+ Hectare site for just 3 horses!

thelwell

Riding Roughshod through Planning Policy

Quite obviously the Change of Use of Land is tactical manoeuvring in preparation for their challenge to the next cpbc Local Plan, Housing Supply and its interpretation of Green Belt Policy.

Either way, should the Dutch Village site become developed with the anticipated 300 dwellings, the infrastructure issues on Canvey Island will be exacerbated.

Health Service, traffic, recreation and Flooding issues will all be worsened, affecting each and every Canvey Island and South Benfleet resident!

The Change of use of Land, should signify a warning to all of the Borough’s Green Belt site neighbours, many of the Borough’s GB sites have some Built Development on them.

CPBC needs to be working on a Red Line to define where GB land changes from their pristine, cherished “virgin” sites to, GB with limited development, before finally becoming Previously developed Green Belt with the same lack of protection as Brownfield sites.

The KEY to ANY Canvey Island development must be that it is, APPROPRIATE DEVELOPMENT!

Castle Point council must respond in the correct manner to this application. We should all make our thoughts known to the council officers, otherwise Green Belt Policy will be undermined and Canvey Island and Sth.Benfleet residents will suffer.

The Link to the Application to view documents and to make comment is HERE.

Reasons to Object or comment upon could include:

Green Belt Development

as a whole, it should be considered that the proposal represents inappropriate development in the Green Belt. The NPPF identifies that such development may only be permitted under Very Special Circumstances.
NPPF Paragraph 83 instructs “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.”
It can be argued that the “Change of Use of Land” should also only be considered, through the preparation or review of the Local Plan rather than by individual applications.

“All permanent stables and field shelters will require planning permission and, if the land is not in use for the keeping of horses, an application is unlikely to be acceptable.”

The term Very Special Circumstances implies that a desperate “Need” for this facility must be Obvious and Proven, or that there are very few similar facilities in the area.
It should be noted that there are many similar facilities in the local area.

The “facilities are small scale” indeed accommodating a maximum of 3 horses only. This will have no tangible impact on any suggested unmet need for such facilities, even if such need were proven to exist.

The applicant refers to the Purposes of the Green Belt and notes ‘to check the unrestricted sprawl of large built-up areas’;
The applicant points out that their intention is to construct “buildings in the Green Belt will give rise to built development”

Archaeological Features

The field abutting the proposed Stable Yard contains the Roman Saltern, a scheduled Ancient Monument, 260m south east of Great Russell Head Farm. This monument is scheduled under the Ancient Monuments and Archaeological Areas Act 1979 as amended as it appears to the Secretary of State to be of national importance.

Proposed Access

The current access is on a busy dual carriageway, Canvey Road.

The design plans indicate the intention to “set back” the gated entrance 6 metres from the footpath. Whilst this “pull in” may make the actual entry to the field somewhat safer, other Canvey Road field entrances, with similar “pull in”design, have been the subject of serious “Fly Tipping” problems. This has been notably recorded at the entrances to the Canvey West Marsh RSPB site, directly opposite.

Vandalism and the protection from Harm of Horses

The Stable Block would likely act as a “magnet” for vandals being, unlit, housing unattended animals over night, out of sight of passers-by view thereby “secret”, and of wooden construction, containing feed and bedding, all potential fire hazards.*

*Extracted from the Canvey Green Belt Campaign group’s 4 page Objection document.

Illustration with apologies to Thelwell