Dear Castle Point Council,
Regarding the Flats development in Foksville Road.
“The below issues are not within our remit, and therefore must be considered by yourself before determining the application.
The TE2100 Plan (to improve the Canvey Island sea defences) is an aspirational document, rather than a definitive policy, so whether the defences are raised in the future will be dependent on a cost benefit analysis and the required funding becoming available.
When determining the safety of the proposed development, you should take this uncertainty over the future flood defences and level of flood protection into account.
Please note that government funding rules do not take into account any new properties (residential or non-residential), or existing buildings converted into housing, when determining the funding available for new/upgraded defences. Therefore (as) the proposed development may reduce the funding available for any future defence work…
You are the competent authority on matters of evacuation or rescue, and therefore should assess the adequacy of the evacuation arrangements,
You should be satisfied with any emergency flood plan submitted and find it adequate for the purposes of the local authority flood plan (for example, possible rescue of inhabitants during a flood, temporary accommodation whilst flood waters subside and properties are uninhabitable). If you are not satisfied with the emergency flood plan, then we would recommend you refuse the application on the grounds of safety during a flood event,”
The Environment Agency
Converting “redundant commercial buildings” into living accommodation on the face of it may appear beneficial towards the supply of housing, however in a Flood Risk zone 3 within an area known for serious Surface Water Flooding problems, this clearly adds to the numbers of People put at Risk of potential Flooding.
Canvey Road gulley June 2016
The Environment Agency point out that Castle Point Council, alone, are responsible for adding to the numbers of People already at Risk, and they should be satisfied that Evacuation and Safe Refuge is Achievable and Adequate.
Looking at the Plans for the Development, clearly this is not the case!
Evacuation is accepted as logistically unlikely.
Safe Refuge is the advised actions in the event of Flooding on Canvey Island.
Strange then to see approved, a top floor Safe Refuge Area of just 13.65 square metres, to serve 9 future Ground Floor Residents!
This equates to just 1.5 square metres of space per person.
Well it would do if the area did not include a toilet facility, sink, worktop and inward opening doorway!
Standing Room Only?
Obviously size does not matter!
The drainage of the site and the proposed development drew some interesting comment from certain committee members.
It appears that the expectation is that drainage will be improved as the existing building is unconnected to the drainage system, the new development will be connected to the system.
During the flooding of 2014 the drainage system was overwhelmed by the levels of flood water, this development will be producing extra drainage and sewage water from those living in the proposed accommodation.
The “hope” is that an underground attenuation tank may be employed to slow the flow of drainage water into Canvey’s drainage system.
This we must assume will require mechanical pumping into the nearby drains.
Interesting to know whose responsibility the maintenance of the pumps would become.
We all know the reliability issues with mechanical pumps from the failings of the EA’s main pumps during the 2014 Canvey Floods.
The efficiency of storing drainage water in an underground attenuation tank is also questionable, given the High Water Table that we have across Canvey Island.
Surely if you were to create space for an underground tank, within the normally saturated ground of Canvey Island, you simply create a further need for space for the displaced water elsewhere?
The Questions that remains unanswered is, Will the Ground Floor Flats be Insurable against Flood damage over the length of their Lifetime?
Will there / should there be living accommodation provided for disabled persons, in Flats on Canvey Island and how can their safety be guaranteed in the event of a Flood?
Furthermore, it has come to light that development committee members may have been misled by certain statements issued during the planning meeting!
Concerns were raised regarding the number, or lack of, parking spaces to be provided for this number of Flats, 16 bedrooms plus visitor spaces, requires an allocation of 19 car parking paces.
The developer proposes just 12 spaces, in this busy location!
The officer, as seen on webcast, appears to support this shortfall by referring in one instance to the Essex County Council Parking allocation standards as being a “Maximum” requirement.
This is unfortunate for members, as they should have been aware that ECC parking space requirement for Flats are expressed as a “Minimum” requirement!
The officer then appeared to refer to a London Road, Hadleigh flatted development being lost at Appeal. Finding against Castle Point Council, the Inspector felt that an under allocation of Car Parking Spaces was not serious enough Grounds to dismiss the developers claim!
However, at present, we can find no record of this Appeal case.
Could the lack of Car Parking spaces, supported through this allegedly unsupported guidance and possible “slip of the tongue”, have swayed the final decision?
Going by previous decisions on proposals for Flats on Canvey Island, most probably NOT!
This piecemeal decision making moves us further and further away from the aspirations of what is now appearing a remote chance of Regenerating the Town Centre and making Canvey a Safer Place.
Essex County Council Parking requirement for Flats and Houses can be seen on Page 63 of the Standards Document HERE.