Constraints on Housing Development in Castle Point was the last topic under consideration by the Local Plan Task and Finish group last evening, the 25th August, ahead of the Jotmans Appeal.
Most councillors appeared to relish the opportunity to debate, following the officer’s introduction.
It is clearly apparent there is a split in how the local Plan process should proceed, with many councillors uncomfortable with being “locked” into the current Local Plan documentation and policies.
Whilst residents were promised an Open and Transparent Local Plan process, last night’s debate illustrated how far from this approach the actual process had reached!
Well obviously a lot of digging around and research had taken place to turn the evening proceedings into an uncomfortable time for both officers and chairman, as they failed to steer the meeting in their expected direction.
The official approach was to take a strategic approach to constraints, for instance Green Belt concentrating on and protecting the main Green Belt corridors that feature in and around the Borough. However due to the desire to have one or more extra meetings, so as to focus more on these important topics, Green Belt, Flood risk, Hazardous Industries and Infrastructure, the strategic approach was abandoned and now each possible Housing Site will be focussed on at the rate of 4-5 per meeting!
The chairman obviously focussing more on a fixed timetable than the importance of Constraints!
The meeting started badly with a piece of surface water flood risk late Consultation evidence being drawn to the committee’s attention. A letter from the Environment Agency in a follow up from the July 2014 flooding suggesting important changes of wording to the draft Local plan proposed housing site consideration, that had not been drawn to the committee’s attention nor been entered into the Local Plan draft! An apt time to produce this evidence by the councillor, whilst debating Constraints, shame on officers for suppressing it!
Another piece of evidence was called for, a Hazardous Industry’s safety Report. Again UNAVAILABLE!
Apparently, despite the Castle Point Council Development committee doubling up as the CPBC Hazardous Substances Authority, the local authority do not have a copy of these Safety Reports! As unlikely as this sounds councillors were told that the Safety Reports are held by Essex County Council!
A group debating Housing Constraints needs to know the potential for an incident and the size of area this incident could impact upon.
We felt the evening’s Agenda Paperwork contained misleading and contradictory evidence. Throughout the Core strategy and Local Plan process there appears a preference for in-house terminology and wording used to support the preferred Party line of the day!
Below are a few Extracts from the Agenda Paper with concerns of ours that require attention. Agenda paperwork in Bold;
Constraints Agenda, Page 1“a maximum of 2,469 homes being delivered in the next 15 years (SHLAA 2013)”
Remember that the 200 dwelling per annum target figure has not altered since the days of the Core Strategy, 2,469 is equivalent to 164 dwellings per annum across the 15 years.
Is the SHLAA 2013 considered to be a “sound” document for T and F members to be considering especially as a 2014 update has been published?
Constraints Agenda, Page 2
“viability assessment work undertaken by Peter Brett Associates, indicates that higher density flatted development is likely to be unviable in Castle Point, particularly during the early plan period, and particularly on Canvey Island.“
Evidence from Development Committee findings would suggest otherwise, where Canvey is concerned there have been many flatted developments applied for and approved.
Constraints Agenda, Page 3
“Whilst benefiting from some of the best sea defences in the country, Canvey Island is nonetheless located within flood risk zone 3.”
Canvey sea defence was built to provide protection to 1 in 1,000 year standard. Funding for improvements are not secured.
Contrast this with Climate Adaption EU Netherlands state; “The safety standards indicate a minimum level of safety. A safety standard of 1/10,000 per year means that the coastal flood defence must be high and strong enough to withstand storm surges that have a likelihood of occurrence of 1/10,000 per year. Approximately 2/3rds of the Netherlands defences meet this standard.”
There are NO statutary levels of Flood Defence adopted for the Thames Estuary. The confidence in the abilities of the Canvey sea defence is limited, especially when compared with the Dutch defences, therefore a more cautious approach is required.
Constraints Agenda, Page 5
“The escarpment rising up from Benfleet Creek to Hadleigh, known locally as Hadleigh Downs “…. “Additionally, this open landscape affords spectacular views across the wider Thames Estuary.”
Would officers be suggesting that considerable harm would be cast upon these “spectacular views” if development were to be allowed at the Dutch Village? The Dutch Village being within 1.5km of Hadleigh Downs.
Constraints Agenda, Page 6
“Whilst the Council is normally supportive of the redevelopment of previously developed land on Canvey Island in order to ensure that the built environment is of a high quality and contributes towards community well-being, development of open Greenfield land is not supported in the same way. In accordance with the NPPF, the Council would expect the sequential approach to be applied, and therefore open greenfield land on Canvey Island would not be available for development unless land in other parts of the borough had been developed, or was otherwise unavailable for development.”
Question 1. Why was the Dutch Village identified by this authority as the single large Green Belt housing site in the Core Strategy?
Question 2. The Agenda refers to “in the short to medium term a further 39ha of greenfield land on Canvey Island” then in the following paragraph refers to Green Belt land “an additional 39ha for consideration in addition to this in the longer term.” Is this the same 39ha of land mentioned in both paragraphs? Which area of land is this? Is it identified as being Green field land, due to the CPBC Boundary review being assumed as already approved and decided, despite the wording of the last paragraph of Page 7? Is the 39ha of land considered to be available in the short, medium and long term? If not, which?
Constraints Agenda, Page 7
“Given the need to review the Green Belt boundary to accommodate the identified needs for sustainable development, it is necessary to step away from localised assessment of Green Belt function, and to consider the strategic role of the Green Belt.” Continued onto;
And Page 8
“Strategic Green Belt Corridors within Castle Point: Daws Heath “Ring”: A ring of Green Belt around the settlement of Daws Heath.”
We would refer you to two Paragraphs in the Baker Associates, Sustainability Appraisal CS October 2009 that suggests;
“4.6 The Spatial Strategy also allocates three sites for development on Green Belt land. There is the potential for adverse sustainability impacts related to the loss of greenfield land from these allocations.”
“4.7 Part of the SA was to review the sustainability assessment method used by Castle Point to help select sites for allocation. The review of the outcomes of the site assessment revealed the site scoring highest against the assessment sustainability criteria has not been allocated. This site is greenfield land to the east of Rayleigh Road. Neither the DPD or site assessment process gives a justification for this site not being allocated. The SA suggests that the allocation of this site could have preferable implications for sustainable development than other ‘mainland’ allocations.”
CPBC appear to have an inconsistent approach to Sustainability issues, why then should we choose to adopt a Strategic Approach to protect Green Belt sites at this late stage, when previously this Council chose the exact opposite? Whilst we may be challenged as being divisive with this statement readers must remember how the Canvey Green Belt Campaign were initially treated, isolated as the sole selected large Green Belt area for development. We are simply using this extract to indicate one difference in Consultants Assessment and the work of the local authority. We suggest in densely urbanised areas, the GB function in “Preventing Sprawl” remains equally, if not more important!
Constraints Agenda, Page 8
“Strategic Green Belt Corridors between Castle Point and other Boroughs:
Western Green Belt: The Green Belt to the west of Castle Point …… also prevents towns in Castle Point merging with settlements to the west in Basildon and Thurrock.”
Officers should have been asked what width of green belt strip is considered necessary to Perform this Function, this may have put some mainland residents minds at rest!
Constraints Agenda, Page 10
“Competing Needs and Uses for Land.
The loss of the Green Belt will bring these uses into closer proximity with the urban area, causing disturbance to both the animals housed, and to neighbouring properties.”
Do officers recognise the close proximity on Canvey Island of the urban fringe and the important ecological sites, and the potential damage that vandalism and fires are causing? Do officers recognise the value of sites such as the Dutch Village area in acting as a buffer between the urban area and the important ecological sites on Canvey?
Constraints Agenda, Page 11 Surface Water Management Plan
The wording (in the last paragraph on Page 11, and first paragraph of Page 12) refers to “throughout the Borough” and goes onto refer to “control the flow paths of surface water.”
The officer would fully realise the irrelevance of surface water flow paths in respect of Canvey Island, can he explain why the reference to “throughout the Borough” was made?
- Extract From:- Strategic Housing Land Availability Assessment 2014
“Where a planning application has been approved without objection from the Environment Agency then it is considered that flood risk issues have been resolved.”… “However, those sites in Flood Risk Zone 3 are only considered to be appropriate in terms of flood risk if they are suitable in all other regards. A site which is at high risk of flooding, and would also have other negative consequences would not pass the exception test set out in the NPPF.”
Regarding “without objection from the Environment Agency then it is considered that flood risk issues have been resolved.”…”this is not strictly true. Often the EA will draw the Council’s attention to concerns such as the opinion of the Emergency Planner or to the Council being confident that Insurance against Flooding can be obtained over the lifetime of the property. This is never discussed by the Development Committee nor can guarantees be given!
Regarding: “However, those sites in Flood Risk Zone 3 are only considered to be appropriate in terms of flood risk if they are suitable in all other regards. A site which is at high risk of flooding, and would also have other negative consequences would not pass the exception test set out in the NPPF.”
This appears to cast suitability, sustainability and soundness doubts over the Canvey Island sites identified as suitable for development contained in the New Local Plan!
Constraints Agenda, Page 3
“Open spaces – open space provision is highly valued by local residents, and also important to their health and wellbeing. It also helps to alleviate pressure on areas of nature conservation importance by providing opportunities for outdoor sport and recreation away from nature conservation habitats.”
Given the tight constraint around Greenfield areas on Canvey, created by the busy outer road network, does this strategy not contradict further the suitability of the identified housing supply sites on Canvey Island? There is no opportunity to provide compensation for any loss of open space provision!
Many of these issues concern other Green Belt sites right across the Borough. The inconsistent and questionable evidence supporting the Local Plan will not assist their defence at appeal.