Our fractured planning system still enables developers to build homes in high flood risk areas! At what Cost to Public Finances and Residents well being?

The fact is, Canvey Island is a high Risk Zone 3A flood plain. Albeit the Island is protected by sea defences, we must all be aware that Canvey is; at or below sea level and that residents safety is reliant on none of the individual parts of sea defences failing during a Tidal Flood event.

The works currently underway to protect the Sea Defences, are mainly necessary due to the damage that Tidal movement can cause. That and the discovery that sea water is able to leach under the Sea Defences undermining the structure that actually is intended to keep us all safe. The Environment Agency works are not an improvement in protection to Residents!

Persimmon, for instance, have plans to create a large lucrative development which will take advantage of, and be reliant on, the existence and continued improvement of Canvey’s sea defences over the years of the lifetime of their development. Is it fair that they should contribute zero towards the Vital Sea Defence Infrastructure which will keep their future Housing and Residents safe? Local Plan’s should seek Funding, as Government indicate they cannot alone be expected to continue to underwrite such major schemes in future, perhaps even questioning the Sustainability of Canvey Island.

The 2014 Summer Floods exposed the “Broken Drainage System” and the issues that being such a Flat area causes, namely a total reliance on gravity. Until the drainage system starts to fill up, nothing will reach the pumps for them to commence pumping. Remember how CPBC revealed the need for a £24,500,000 scheme to improve Canvey’s “Broken Drainage System”?

Castle Point Council, since its formation, has been responsible for increasing the population on Canvey, at Risk of Flooding by in excess of 40%!

Of late we have been very fortunate in not having the Rainstorms that other parts of the UK have suffered from. With this in mind we must be aware that CPBC are currently working hard on a Local Plan. Our remaining open Green Spaces act as a water dispersion area giving some alleviation to residents safety and property protection.

Residents safety and well being must be the priority!

Developers and Planners believe it is the easy option, build in Flood prone areas, where those in Authority hear little opposition from the electorate, where Planners fail to insist Developers provide Flood Resilient measures, claiming viability doesn’t allow funds for such important and safer building design.

All the while seeking to increase the Population at Risk of Flooding, which could never be protected even at the current numbers of residents!

With this in mind, I came across a 2019 article by Professor of Risk Lee Bosher. I have been assured that much of the content remains relevant to Development Planning in Flood Risk areas.

Prof. Bosher wrote for “The Conversation;”

“Recent floods in England have been described as unprecedented or even “biblical” events, often with the misguided assumption that they were unavoidable or unpredictable. That is not the case. Over the past few decades, development practice in England has led to more than 300,000 homes being built in high flood risk areas. In this sense, the planning system has actually created (not reduced) flood risk.

The flooding in northern England was indeed extensive, with about 500 homes flooded and more than 1,000 properties evacuated in Doncaster, and major transport disruption across several counties. Subsequent media coverage did highlight the many ways that flooding can be stopped, but key articles tended to focus on typically capital-intensive solutions: flood walls, river embankments, demountable flood barriers or dredging (the benefits of which are highly debatable). The overarching message was that these events are unpredictable and unprecedented, and the only way to properly deal with them is to invest millions in large physical infrastructure.

While these are helpful suggestions, they only address part of the problem. There is another root cause of flooding that appears not to get so much airtime, namely the role of a fractured planning system that still enables developers to build homes in high flood risk areas.

How planning laws made risky building easy

Urban planning in England is highly regulated and has often been accused of constraining development or in some cases stymieing private sector investments. A 2006 government policy statement attempted to direct development away from areas at highest risk – in simple terms, the intention was to promote building appropriate things in appropriate locations.

However, in 2012, the then coalition government published a new National Planning Policy Framework for England, which replaced existing policy and meant there was no longer clear guidance to prevent building in flood plains. To complicate matters further, the Growth and Infrastructure Act in 2013 released large areas of greenfield land for development. The act effectively gave developers a right to submit major planning applications directly to central government and thus proposals and decisions could evade not only communities but also local planning authorities.

As a result of these legislative changes, there is now a better chance of vulnerable homes being built in flood-prone areas. So how has this policy landscape impacted the number of homes/apartments (typically referred to as “dwellings” in government data) being build in flood risk areas?

More than 300,000 new flood-prone homes

The number of New Dwellings built between 1989 and 2016 within areas of high flood risk (technically Flood Zone 3: “floodplains” with a one in 100-year return period and “coastal areas” with a one in 200-year return period), totals 301,000! The average proportion of new dwellings built in areas of high flood risk has fluctuated annually between 7% and 11% with some regions such as London, Yorkshire and Humber, and the East Midlands regularly surpassing these.

This adds up to more than 300,000 new homes being built since 1989 that are at risk of flooding. Despite a plethora of guidance for planners and apparent restrictions on developers, this building persists.

Over this period, the continued “free-market” development of flood plains in England has had an unexpected effect. Developers have increasingly been using flood plains to build social housing for low income families, homes for the elderly/disabled as well as schools and hospitals. One 2009 study identified 2,374 schools and 89 hospitals in flood prone areas of England. Planning policy has thus caused some of the most vulnerable members of society to occupy highly flood-prone areas.

Urban areas have been creating flood risk. And this is largely due to the government’s focus on making land – low cost, flood prone land – available for development.

Therefore, when considering “extreme” flood events and the highly expensive defence and protection solutions, we should not lose sight of how government policies have consistently created more risk – in England, at least. To see how different things could be, just compare England to Scotland. North of the border, flood policy is controlled separately by the devolved government, which tends to deal with the risk rather better.“

Prof Lee Bosher

Professor of Risk

University of Leicester School of Business

Department of Marketing, Innovation, Strategy and Operations

University of Leicester | Brookfield | London Road | Leicester | LE2 1RQ | UK e:  lsb235@leicester.ac.uk w: https://le.ac.uk/people/lee-bosher X: @leebosher 

Housing Today latest, reveals Gove’s hoped for protection of Green Belt spells Developers Angst!

Daniel Gayne of Housing Today writes:

“HBF decries ‘capitulation to NIMBYs’ as Gove prepares to scrap greenbelt housebuilding targets

New NPPF rules expected to be announced this week

Local authorities will not have to set aside greenbelt land to meet future housing need under new planning rules expected to be revealed later this week. 

Housing secretary Michael Gove is reportedly poised to publish the delayed National Planning Policy Framework as early as Thursday.”

So far some 60 Local Authorities have either suspended or withdrawn their Local Plan’s.

Castle Point having withdrawn their potentially disastrous Local Plan that intended to develop 5,500 dwellings across sensitive, Constrained sites within Green Belt and Flood Risk areas, must feel completely justified in their actions.

Hopefully this proposed action by the Government is genuine, rather than political shenanigans.

A potential development site within the Green Belt and Flood Risk 3a zone.

The Castle Point Local Plan – Canvey Residents Opportunity to Have a Say, on the Borough and Island’s Future!

Canvey Islanders opportunity to engage with the Borough Councillors ahead of the CPBC Plan. If you wish to be involved and be heard, the time to Act is Now!

Commences THIS WEEK at The Paddocks.

Residents from across Castle Point are being invited to get further involved in helping shape the future of the places where they live. As part of initial work to develop the Castle Point Plan, the Council is holding a series of workshops for residents.

Their are 2 Meetings planned for Canvey Island, You must use the Links below to book your Seat:

Meeting 1

Castle Point Plan Community Workshop – Canvey, The Paddocks

Thu, Jun 8, 7:30 PM

The Paddocks Community Centre • Canvey Island

Free

Meeting 2

Castle Point Plan Community Workshop – Canvey, The Paddocks

Thu, Jun 22, 7:30 PM

The Paddocks Community Centre • Canvey Island

Free

Castle Point Council Development Board – Confused priorities! Car Parking taking Precedence over Flood Risk! Flood Risk Policy – What Flood Risk Policy?

The CPBC Development Board were asked to consider the Unsightliness of a Disabled Ramp access over Flood Risk issues, on a proposed Canvey Island development of 3 Council houses.

Guess what, they came down in Favour of the Unsightliness of the Ramp!

So what in effect the Committee decided was that in an area prone to Surface Water flooding, and with the added possibility of Tidal flooding to a potential depth of 2 Metres, they should ignore the issue of flooding,  because a high access ramp at the front of a property for Disabled Access would make the property look in some way unsightly.

To overcome some Flood Risk elements the Developer originally proposed that;  “Due to the flood risk associated with the site, a Flood Risk Assessment has been produced, The assessment has confirmed residential development may take place on this site, and has set the minimum first floor level required to minimise flood risk to residents. The impact of this is that the ground floor level will be raised above the existing ground by some 600mm. As a consequence, ramps will be provided for access.” This proposal was originally considered acceptable, fair enough.

The raised ground floor level would mean that in the event of the Surface Water flooding that has occurred on Canvey recently, the flood water, on entering the building would likely cause little harm, at least to the fixtures and fittings, and that any disabled residents would likely remain safe.

Now because of the Access Ramps appearing to be visually objectionable, being at the Front of the Property, it was thought it more appropriate to build the House at Ground Floor Level, rather than 600mm above! Making a Mockery of all safety precautions previously considered necessary to build in a 3a Flood Zone, where Surface Water Flooding is likely!

In effect totally ignoring the absolute Planning requirement that; “the development will be safe for its lifetime taking account of the vulnerability of its users”

The Case Officer when attempting to explain the logic of the relaxing of the Flooding safety requirements and asked if there was a new Policy on Flood Risk for Canvey Island could only mumble yes and that some time ago the EA stopped all development on flood risk grounds! He was neither challenged or asked what the New Policy, if any, was !!

Access Ramps imply that the buildings, being Accessible to Disabled and Vulnerable occupiers, may be in fact Allocated to Disabled and Vulnerable occupiers!

These Buildings set a Precedent that the Large developers will exploit.  No need for Land Raising, No need for raising Ground Floor Levels, no need for Environment Agency Advice, no Need for Caution!

The Application was Unanimously Approved!

Whilst another Application for flatted accommodation on the mainland was Refused on Car Parking inadequacies!!!

Priorities appear to be confused.

Canvey Island Flooding – National Infrastructure Commission, shows the Castle Point Borough Council the Way!

“Over coming decades, the effects of climate change are likely to lead to more extreme weather events.

This means more heavy rain storms. Storms so intense that rainwater often cannot drain away very easily and overwhelms existing drainage systems. This leads to localised surface water flooding. This is a separate type of flooding – particularly affecting urban areas – that’s distinct from coastal or river flooding. Our study has found that over 300,000 properties in England are currently in high risk areas, compared with 240,000 at risk from river and coastal flooding.

The chances of these high risk areas experiencing surface water flooding is 1 in 30.

Without action, we think that by 2055, up to 295,000 further properties could be put at high risk.

Why does this matter?

The impacts of surface water flooding are considerable. It can cause significant damage to properties and shops, disrupting businesses and communities.

But there are no clear targets for alleviating the risk, or clearly defined responsibilities for who should take action, and when.

When it rains heavily during a storm, water will soak into the ground or run off into local water courses, such as streams and rivers.

In areas with plenty of roads, tarmacked driveways and large paved areas, it can be harder for water to drain away, leaving it to run down the street and into gutters.”

Canvey Island has the added complications of having fairly flat ground level, what green fields that are undeveloped having a high water table and low rain-water absorption rate, a broken drainage system not built for the density and numbers of Housing, and low levels of drainage maintenance.

This issue, alongside Climate Change means that the time to address these issues is Now, whilst the Castle Point Plan is being debated.

The National Infrastructure Commission believe there are 3 Ways to Improve the Situation;

“1. Stop as much of the water as possible getting into drains

The growth of hard, impermeable surfaces – such as when people turn their gardens into driveways – reduces the chances for water to drain into the ground.

So too does the growth of major new developments.

We think government should set out by the end of 2024 the policy changes it thinks are necessary to mitigate the impacts of surface water flooding and limit the impacts of growing development.

2. Expand the capacity of drainage systems

Existing drains need first of all to be better maintained.

3. Create more joined-up, targeted governance and funding

A new approach, supported by the Environment Agency and Ofwat, would see local authorities and water companies working together on fully costed joint plans for each surface water flood risk area.

We recommend that public funding is devolved to local areas to assist with longer term planning.“

There appears nothing much that wasn’t covered within the Essex County Council Flood Risk Report into the Canvey Island Summer Floods of 2014, nor the S19 Report of the Government Office of Science follow up Report.

Except that much of the Recommendations and Warnings have been ignored!

The Surface Water Flooding Issue facing Canvey Island and parts of the Mainland, bring into perspective the thought processes of the previous CPBC Regime, with their driven intent to impose over 5,500 new dwellings on the borough through their 2018 Local Plan, now thankfully shredded!

Their allowing of the ECC as the local flood authority, to greatly reduce the area indicated within the Canvey Island Critical Drainage Area, to go Unchallenged, is yet another failing of previous regime. As this will make it harder to Secure Funding to fulfill much of the National Infrastructure Commission’s 3 Ways to Improve the Flooding Situation!

The Link to the National Infrastructure Commission Report is HERE.

14 Years of Castle Point Neglect – of Affordable Homes – of Flood Defence Infrastructure! Time for Change is Now, Residents Safety & Well Being First! The Need for a Supplementary Planning Document.

No doubt the overthrow of the CPBC lead group by the 2 Independent Parties, came not a moment too soon! 14 long Years CPBC have been identified as Under-Performing in securing Infrastructure Levies against Development on Canvey Island and across Castle Point.

Emphasising the lack of Affordable Homes being supplied in the Borough, “CPBC’s SHMA 2017 Addendum concludes that 110% of new homes delivered in the Borough should be affordable” ! A clear sign that CPBC have been  either keen to be “agreeable” towards developers, or plainly negligent where providing Homes for local young people.

This is clear to see in an Appraisal that CPBC had procured in 2008, from an outside Agency, Baker Associates, which found;

“To date Castle Point Borough Council have been identified as performing badly against securing contributions particularly with regard to affordable housing, reflected in poor Best Value Performance Indicators scores. At present (2008) in Castle Point there is only an advice note on Planning Obligations for developers, this covers only affordable housing, physical infrastructure, travel plans and community facilities – but the note contains little detail or certainty on what the expected contributions would be, leaving much up to negotiation. Therefore retaining this approach is unlikely to bring about the change necessary in securing these obligations that will help to realise the sustainable community benefits of suitable contributions.”

“Specifically the risks in areas identified as Flood Zone 3 need to be controlled by the maintenance of high quality flood defences, that are suitably future proofed against the increased risks posed by climate change and associated sea level rise.  Therefore, it is only right that developers should contribute towards the cost of their maintenance and enhancement in areas identified as having a high risk.  This applies to all types of development, as it is appropriate given that all development are effected on by flood risk, although some types such as residential may be less resilient to the impacts.  However, payments should be reasonable based on the benefit this will also bring to existing homes and businesses.” 

As we, the Canvey Green Belt Campaign group, have been encouraging, despite it falling on “Deaf Ears,” all development within Castle Point should be required to contribute towards Flood Defence Improvements!

The Baker Appraisal even recognised the relevance of Contributions from New Development towards supporting the Fire and Rescue cover, with Canvey Island containing 2 Top Tier Hazardous Industrial sites alongside the potential Tidal threat ;

“Fire and Rescue

“Clearly this is an important issue, although its inclusion as part of obligations may not be necessary as these provisions may be part of conditions on development in larger sites, and are not a suitable matter to be addressed in smaller developments.  However, given the particular hazards in Castle Point consideration of additional payments to support fire and rescue services may be suitable where development is located in locations of greater risk, this could encompass both fire and flood.  It is understood that the Flood Risk Management Plan to be prepared for Canvey Island will consider whether extra fire and rescue services are needed to improve safety in high flood hazard locations.”

Canvey has seen the largest increase in population since CPBC was formed, and the Island is now seeing the bulk of the Commercial Development.

Why should Central Government funding be solely expected to provide the necessary Infrastructure so that Developers may take advantage of less expensive land to make Higher Profit margins, and leave more buildings, businesses, and increase the Population, at Risk of Flooding?

If they cant afford the Infrastructure Levies, then develop away from a borough with a Flood Risk Zone 3a! As the NPPF, House Insurance Agencies, the Town and Country Planning Association, and the Environment Agency encourages!  Video Information available below.

In the light of CPBC Local Plan2019 having been Withdrawn, it might be considered “timely,” especially if the local authority are fearful developers may attempt speculative planning applications for the new regime at CPBC to produce a Supplementary Planning Document ahead of a New Local Plan, to ensure that relevant and reasonable Community Infrastructure Levies are collected, rather than avoided by Developers!

“In terms of achieving sustainable development it may be” more suitable for a “flexible approach of securing contributions based on a Supplementary Planning Document (SPD).” “This allows for the exact payments or other obligations to respond to the particular needs of an area or contribution of a site. In addition an SPD should follow a much quicker preparation process and therefore be finalised for use in a shorter timeframe than a DPD would, similarly the review process for an SPD if necessary would be able to be completed more rapidly. Ideally this means that it is possible to implement these obligations, and secure sustainability benefits, sooner”…..

“They can never remove all of the Risk”

Quotations extracted from Baker Associates Sustainability Appraisal of the Castle Point Borough Local Development Framework Developer Contribution Supplementary Planning Document October 2008

Canvey Island Flood Risk – a New Video by the EA and TCPA to Inform Residents, New developers and most Importantly CPBC Councillors.

Whilst the New Castle Point Borough Council are focussing on the Adoption of the Local Plan and in particular the Housing Distribution and Numbers, it is well worth them viewing a recently released Video from the Town and Country Planning Association (TCPA).

Canvey Island, and indeed areas of Castle Point are at Actual Risk of Flooding from more than one source.

If the intention of Persimmon Homes, developers and Castle Point Borough Council is to continue adding to the numbers of Population at Risk of Flooding on an Island, situated at or below Sea Level, with an ageing Population, without a secure Evacuation Route, and with scarce Resources to Rescue Existing Residents, I would recommend anybody thinking of moving into the area, Councillors, Decision Makers and Current Residents to spend just a few minutes to watch this Video.

Watch it in the light of there no Secured Funding for the necessary Raising of the Sea Defences, no Unmechanised means of Surface Water Drainage (remember 2013 and 2014 summer floods).

This is not being Alarmist, it is simply being Realistic. If you are one of us that have looked at the Sea Wall and been encouraged to take comfort for the Defence it offers us all, remember that times change with the Climate, and that No Defence is Infallible nor Indestructible, and that Canvey Island’s Surface Water Drainage System is neither Maintained to the required Standards, nor Unbroken, as revealed following the Essex County Council S19 Report into the Canvey Island 2014 Summer Floods, which by the way appears to have been buried and not as readily available as before! Fortunately our Campaign group noticed that CPBC felt that it was a document best kept from the Local Plan Examining Inspector and we were able to make it available to him and was accepted as Local Plan document EXM-051 – Canvey Island Flood Investigation Report 2014.pdf 

Anyway the purpose of this Blog Post is to make available to all interested and potentially affected, a New Video released by the EA and TCPA.

“The Environment Agency and Town & Country Planning Association have partnered to produce an introductory video on addressing flood risk through the planning system in England. This video explains how and why planning must consider flood risk and explores different options and opportunities. The role of the Environment Agency in the planning system is to provide flood risk advice to inform the decisions made by local authorities on planned development. This also includes translating the latest climate science to create user friendly guidance on how climate change can affect flood risk in the future. Both decision makers and developers can utilise this guidance.”

View the Town and Country Planning Association video by Clicking HERE

“They can never remove all of the Risk”- Remember a Substantial part of the Canvey Sea Defence is of Clay!

Moving Forward with the CPBC 2019 Local Plan and The Lessons from Jotmans Farm!

Canvey Islanders can consider themselves Hard Done By over the years, where Local Plan issues are concerned. The Hazardous and Environmental issues facing the Island’s population were, in general disregarded by the now-ousted Borough’s representatives, and CPBC officers.

Likewise the mainland residents were equally frustrated, chiefly over Green Belt issues, this leading to a new and politically Independent Council being appointed via the May 2022 Local Elections.

It will be interesting to see what advice the new regime at Castle Point Borough Council will receive, given that they are now not-minded to Adopt the draft 2019 Local Plan. The majority of Canvey members having previously voted against the Plan being sent for Examination and a unanimous majority, with one abstention having recently voted against its Adoption.

It could be argued that the sole reason it was drawn up in the first place was the duress of the Government’s threat of Intervention, under the direction of a council leader soon to “leave” office.

The somewhat unfair position that the old regime have landed the new Independent coalition council in is unenviable. However they appear as angry and determined as residents to rectify the Local Plan situation, if at all now possible!

Whether time will allow the Plan to be Withdrawn, “ the deadline set by the government to have in place an up-to-date Local Plan by December 2023 remains in place” we must wait to see.

It appears too late to legally challenge the Local Plan as; “The window closes when the plan is submitted for examination and any subsequent challenge can only be brought once the plan has been adopted.”.

In Canvey’s case there is a definite grievance that Consultation Evidence against the 2019 CPBC Local Plan was suppressed!

The Inspector, we can only assume, felt that cpbc officers and councillors had dealt with, through the consultation process, all matters and, disappointingly for us, rather than challenging and doubting the evidence base he avoided opening the can of worms and considered the Plan at face value.

 Sceptics are already scaremongering about the opportunity for speculative developers taking advantage of the current situation to bring forward proposals for development in the Green Belt. Whilst the possibility remains for the Withdrawal of the Local Plan, being allowed right up until the decision to Adopt.

Where do we stand? Well looking back at the Jotmans Farm rejected planning application that was appealed by the developer following the time of the withdrawn 2014 draft Local Plan, we can see that the Planning Inspector felt that the Appeal should be upheld.

However large development proposals in the Green Belt are called-in for the Secretary of State’s decision. His findings included, and I quote, “Given the withdrawal of the dNLP, the Secretary of State takes the view that no weight can be afforded to the withdrawn policies.”

This implies that it is fair to expect the CPBC officers, the Development Board, and any Appeal Inspector may assume the same approach, no weight can be afforded to the withdrawn policies in this 2019 Local Plan! This hopefully would be the approach to any Green Belt speculative development application wherever in Castle Point.

The  Letter went onto say;                                                                                                                                “The Secretary of State has considered carefully whether these considerations amount to very special circumstances which clearly outweigh the harm to the Green Belt and other harm. The Secretary of State has taken into account the extremely low housing land supply, and the withdrawal of the dNLP. This increases uncertainty about the future delivery of housing. He has also taken into account the Written Ministerial Statement confirming the Government’s policy that ‘subject to the best interests of the child, personal circumstances and unmet need are unlikely to clearly outweigh harm to the Green Belt and any other harm so as to establish very special circumstances’. In the light of the change from guidance to policy (see paragraph 12 above), he considers that this policy carries more force than the Inspector attributes to it. Having considered the facts against this policy, he concludes that the considerations above do not clearly outweigh the harm to the Green Belt and any other harm, and that very special circumstances do not exist. The proposal is therefore in conflict with national policy on the Green Belt, which indicates that development should be restricted.”

Bearing in mind that Local Authorities are at present working to complete a Local Plan by the end of 2023, and that there has been a democratic reaction through the Electoral polling system within our Borough, it would appear only fair and just to allow the new Independent Council at Castle Point time and freedom to consult and reconsider the 2019 Local Plan.  

We wish them Well.

CPBC Leader cllr D. Blackwell and Deputy cllr S. Cole

Persimmon Homes offer Canvey, Dutch Village Development new Residents, a Flood-Safe-Sweetener, existing Residents are left to their own Devices!

The over development of Canvey Island, proposed within the Castle Point Local Plan, has the potential to lead to an increase in the Island’s population of an extra 3,600+ new Residents.

Already there is an issue, in the event of a Flooding incident, Evacuation Routes would quickly become blocked, with the sole access to Canvey being at the Waterside Roundabout. As was suggested during the latest council meeting refusing the Adoption of the Local Plan, the junction would become blocked by Residents attempting to evacuate in one direction whilst the other direction would become blocked by idiots trying to get onto the Island so as to take photos with their mobile phones to post on social media.

Persimmon Homes, eager to build on the Canvey Dutch Village have recognised the Flood Risk to people and have approached CPBC with the hope that, in Partnership, they will be able assist and alleviate some of these concerns.

Persimmon are keen to provide their new Canvey Community with local infrastructure and / or commit Community Infrastructure Levy monies to be used alongside their new large development.

Announced by CPBC as an exciting ‘Good News Story’, Persimmon have come up with a novel scheme, one which it is hoped will compensate for the increased risk of flooding, and CPBC are equally eager to involve themselves with.

Persimmon, working in conjunction with CPBC , are proposing an initiative that could lead to new Residents on their Dutch Village development will be offered free quarterly passes to Waterside Farm Sports Centre for access to Free Swimming Lessons.

A grant has been found to supplement the costs, and all age groups will be able to avail themselves, Under 11’s upwards to gaining their Width badges and 11’s up to Adults, free lessons up to attaining their Length badges, free of charges.

Both Persimmon and CPBC LP Delivery Board, working in partnership on the Master-planning process of the new development, feel that new Residents taking advantage of these lessons and attaining / improving their ability to swim, will be better prepared to protect themselves, against the more frequent Flooding that is likely to occur once the new development is undertaken!

CPBC Emergency Planner Michael Take said; it appears in light of the levels of development proposed for Canvey, the lack of decent and safe flood refuges, the likelihood of Off-site Flooding and the impossible logistics of providing a safe Evacuation, the time is right for Islanders to take the initiative to consider more unusual and radical means to keep themselves and their families Flood Safe!

Preparing for Development at Canvey Island

    

Time to Challenge the Castle Point Local Plan! Too Much Development, Too Much Loss of Green Belt, Too Hazardous to Increase the Population! Time for Residents to be Considered!

5,500 New Houses due for Development across Canvey Island and Castle Point contained within the CPBC Local Plan, will be decided upon this coming Wednesday 23rd March at 7.oo pm!

The Local Plan, having been found “Sound” by the Planning Inspector within his Report, requires Challenging by our Councillors and Officers. I know that the Mainland Residents feel Strongly against the Plan’s Adoption at this meeting and will attend in numbers.

Canvey Island Residents should be aware that the Local Plan contains some Serious Flaws, including an Intent to Increase the Population at Risk of Serious Hazards on Canvey!

The possible consequences of which are not generally known despite there being a Local obligation to warn and inform!

With that in mind we, took the decision to contact each CPBC Councillor individually with the message copied in below.

We have pointed out Inconsistencies in the Inspector’s findings, the lack of use of legitimate Constraints on Housing Numbers, the Hazards of living on Canvey Island that have for too long have been disregarded.

Manifesting from the failure to provide clear evidence  based documentation, identifying the need to consider severity and consequences of a major accident.

We believe that the CPBC Local Plan is Flawed and should be scrapped, it is Not Fit for Purpose, and if Councillors refuse to put the current Residents Safety and Well Being at the forefront of their Plan-making they should step aside and make way for others.

Yes we were / are under threat of Government Intervention, but Government do not insist on the level of increase in the Population that the current Lead Group of councillors have proposed for Canvey and the Mainland, especially given the Points we have made below.

Time to Challenge the Local Plan!

Dear Councillor,

In light of the councillors forthcoming consideration of the Inspector’s report on the CPBC Local Plan and its Adoption.,

I would like, if I may, draw your attention to some apparent serious inconsistences, shortfalls and failings.

Firstly inconsistency between Inspectors;

Just 11 years ago the Inspector, Mr P.Crysell in his letter to CPBC dated May 2011, he wrote specifically;

“in an area of potential high flood risk at Canvey Island”……. “While I accept some development at Canvey Island may be required to meet local needs and to support services,”

In contrast, Mr P.Lewis referred to; “the Thames Estuary 2100 Plan sets out a policy for Canvey Island,

which is to take further action to keep up with climate and land use change so that flood risk does not increase for Canvey Island….”

A different less cautious view than the Inspector Mr P.Crysell took just 11 years previously!

3 Points

a) the TE2100 remains an Aspirational scheme, no Funding is as yet secured.

Financial issues and Climate Change will dictate which areas of the Country are prioritised for flood defence improvements.

b) the EA submitted a document during the LP examination that indicated the necessity to increase the Canvey Island Flood Defence heights by:-

“About 0.3 Metres in 2040”

And “A further 1.4 Metres in 2070”

This due to the latest Climate Change and Sea Level Rise estimates.

c) Despite any and all necessary Sea Defence Improvements, there will remain a Residual Flood Risk to the Island and its inhabitants,

being at or below sea level.

Inconsistencies within Mr P.Lewis’ LP Report;

It is considered that the Sequential Test has been passed, and yet it can be argued that the Test has not been properly applied, across the Borough.

It has been applied site specifically, that is, between sites Developers have proposed.

Canvey Island remains at Actual Risk of Flooding according to the Strategic Flood Risk Assessments.

Mr P.Lewis’ Report Para 76 reads, “to be effective Policies HO23, HO24, HO26, HO27 and HO31 should be amended, so that it is clear that self contained residential accommodation and bedrooms at ground floor level would not be permitted”.

Already on Canvey Island there is a large development underway of homes at Thorney Bay, classified as “Highly Vulnerable” to Flood Risk.

And yet, the Local Plan’s Soundness is reliant on Modifications, that brings forward Green Belt land in the same Flood Risk Zone!

Paragraph 11 of the NPPF clearly states that for Plan Making,

“strategic policies should, as a minimum, provide for objectively assessed needs for housing”

“unless,”

“the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale,

type or distribution of development in the plan area” see footnote 7.

Footnote 7, Allows for the protection of “land designated as Green Belt, Local Green Space,” and “areas at risk of flooding.“

Twice during 2012 and 2015, Castle Point Borough Council’s Cabinet Approved, Local Plan Sustainability Appraisal and Strategic Environmental Assessment Scoping Reports.

Within the documents it considered that with regard to Canvey Island;

“Given the risk to the population, various measures are required to deal with the concerns to human health and wellbeing.

These include:”

“The need to maintain the population living in the flood risk zone at current levels or lower;”

The Inspector Mr P.Lewis, in his report, quite clearly failed to avail himself of the Calor Gas Safety Report concerning Canvey Island, as was advised by us before and during the Local Plan Examination process..

If he had he would have been aware that an accident, or incident at the Calor Gas site would have the potential, to cause Damage, Harm and multiple Deaths across the whole of Canvey Island.

The potential to have a catastrophic Environmental and Sustainability impact upon the whole of Canvey Island.

Evidence of the Inspector’s failure to consider the extent of a potential Incident at Calor or OIKOS, can be found within his LP Report Para 163-167.

He restricts his considerations to the HSE’s Consultation Distances, ignoring Castle Point Borough Council’s obligations to Land Use Planning outside of the HSE’s zones.

These issues surrounding the Canvey Hazardous Industries, were this week brought to the attention of, CPBC Interim CEO A.Grant, Leader of the Council, cllr A.Sheldon and CIIP Leader cllr D.Blackwell, the ECC Emergency Planner representative and the CPBC Emergency Planner.

Similarly, an extract from the CPBC Strategic Flood Risk Assessment (SFRA) Level 2 summarises; Para 3.2 “The majority of the (Canvey) sites will rely on the provision of adequate emergency planning measures to mitigate the residual risk of tidal flooding

in the event of a breach in the tidal flood defences.  It is therefore strongly recommended that the suitability of locating more residential accommodation on Canvey Island and the capacity of the existing egress routes off the island is further discussed with the Emergency Planning Team at Castle Point Borough Council and/or Essex County Council prior to site allocation”.

During the meeting, attended by the Castle Point leaders and the CEO, named above, neither the ECC nor the CPBC Emergency Planners, were aware of the the existence of the requirements contained in the SFRA Para 3.2.

Nor, it appears, had they been consulted during the CPBC Local Plan Housing Site Selection process.

The then CPBC MP Sir Bernard Braine examined the issue of Tolerability of Risk on Canvey Island, and it is an argument that remains challengeable today.

These shortcomings of CPBC’s Local Plan-making, and the Planning Inspector’s Mr P. Lewis’ findings contained in his Report, at Para 27 listed as “constraints to development in Castle Point”, as “including the Green Belt, flood risk and habitats sites,” have clearly failed to have been fully examined!

CPBC submitted a Local Plan that they considered “Sound,” alongside their evidence base, this obviously allowed the Inspector to agree.

But that is not to say that the level of soundness, when legitimate Planning Constraints had properly been applied, would not have resulted in a Lower Housing Supply, a protection of Green Belt, and an equally Sound Local Plan.

Castle Point Council officers and councillors both have a Duty of Care to the Residents of Canvey Island and Castle Point.

We do not agree with this Local Plan’s Policies, and feel that the Cumulative Impact it will have upon residents of Canvey Island will be detrimental.

A Local Plan that intends to Increase the Population, already currently at Risk of Flooding, and Impact of an Incident or Accident from either of the Hazardous Industrial Sites is fundamentally and Morally, Unsound.

We fully believe that a Fair and Defendable Sound Local Plan, could be one that sought to Maintain the Population of Canvey Island at the current level, or lower.

The Emergency Services could not cope now with a serious Tidal Flooding Incident or an Incident at Canvey Island’s 2 Hazardous Industrial Sites.

This is Sound Reason;

“Given the risk to the population, various measures are required to deal with the concerns to human health and wellbeing.

These include:”

“The need to maintain the population living in the flood risk zone,

(and within the Hazard Range indicated by the Calor Safety Report Maps) at current levels or lower;”

As was previously proposed within the CPBC’s Local Plan 2012 and 2015, Sustainability Appraisal and Strategic Environmental Assessment Scoping Report.

This would allow the local Planning and Building Industry to remain active.

Whilst Canvey Island’s economy continues to be robust, given the Commercial, Retail and Industrial units being proposed and developed. The Island’s Economy is clearly Not Stagnant, nor will likely become so during this short Local Plan period.

Restricting Canvey’s Housing Supply would not impact upon the Mainland Local Housing Needs, as the Canvey’s issues, above, are all genuine Planning Constraints, and the Housing Supply should be adjusted accordingly to take into account Mainland issues.

Different Inspectors hold different views, as will Local Authorities, as to what makes a “Sound” Local Plan.

With respect, we feel this current version of the CPBC remains distinctly challengeable, and could be reasonably Altered.

We hope that you will be able to consider these points, ahead of your decision over the Adoption of the CPBC Local Plan.

Kind Regards,

Canvey Green Belt Campaign

Like a bad Smell, this just will not Go Away!