Tag Archives: constraints

Stagnation at Castle Point Council, whilst other Local Authorities take the Local Plan Fight to the Inspectorate!

It appears that Castle Point Borough Council are far from being the only Local Authority struggling to meet its Housing Needs. Whether the Government step in to scoop up the left-overs of the various Local Plan versions devised within CPBC Runnymede Towers, or whether CPBC are Actually Attempting to resurrect a Local Plan, rather than twiddling their thumbs waiting for the Government Chief Planner, Residents remain in the Dark!

With the last version of the Local Plan 2018, voted down at the Special Council meeting, it may have been appropriate for a councillor, or a group of councillors, to have proposed a return to the 2016 version, and seen whether a concensus could have been gained on that within a council members meeting.

At least the CPBC Local Plan process would have been seen to be advancing rather than the pathetic Standstill we appear to be held in.

Whether CPBC have had word of Bad News from the Secretary of State for Housing, Communities and Local Government, James Brokenshire, but we will not be hearing officially his verdict on Intervention ahead of the May local elections, we can only surmise.

But with news from Manchester that Government Ministers and The Planning Inspectorate not appearing to be on the “same page” where the calculation of Housing Targets and indeed the Supply of Land is concerned, CPBC may well have missed a trick in not continuing to at least try to advance its Local Plan!

We have to assume that CPBC council officers have been working to fulfil the Duty to Cooperate part of the Local Plan process, if not, why not, so why haven’t councillors taken it upon themselves to work on the Local Plan itself?

A Local Plan, whether fully Sound, but at least Agreed upon, could be considered and possibly consulted upon, outside of Intervention. The Green Belt, Flood Risk and the Hazardous Industries could be debated in open Examination, rather than in private!

The Local Government Chronicle Reported on the 26th February 2019:                                         

Greater Manchester CA mayor Andy Burnham has accused the housing minister Kit Malthouse of being ‘at best partial and at worst misleading’ over comments made regarding Greater Manchester’s plans for new homes.                                                                                                                

The issue of whether it is really necessary to build on greenbelt land in Greater Manchester is a contentious one right now. After being beset by delays, the latest consultation on the Greater Manchester Spatial Framework opened last month and runs until 18 March.                         

Greater Manchester has calculated how many new homes it will require by 2037 based on 2014 household projections, in accordance with the government’s proposed methodology for calculating local housing need.                                                                                                                         

This required Greater Manchester to plan for 73,500 more dwellings than had it used more recent 2016 projections. In order to meet these targets the combined authority has earmarked nearly 64,000 dwellings on a series of greenfield sites, predominantly within the green belt.       

The mayor claims that the government’s insistence on using these “outdated housing targets” had left him with “no choice” but to plan to build on green belt land. But housing minister Kit Malthouse denied that the government’s targets were mandatory.                                                     

Mr Malthouse stated that any inspector will accept a “properly evidenced and assessed variation” from that target.                                                                                                                                 

“If, for example, you have constraints like areas of outstanding natural beauty or green belt, or whatever it might be, and you can justify a lower number, then an inspector should accept that.”                                      

Mr Burnham claims that Mr Malthouse’s comments, which were made during last week’s parliamentary debate on the framework came as a “surprise” to him.                                                    

They do not reflect current government policy,” he said. “They give a very different impression to the one offered in private by civil servants.”                                                                                          

“Under pressure from Conservative backbenchers, it would appear that the Government is trying to soften its line on housing numbers and greenbelt and deflect blame towards councils…It is unfair and dishonest.”                                                                                                                      

Mr Burnham claims that Greater Manchester does not believe it has discretion over housing numbers, because the government’s planning guidance says local authorities are “expected” to use the government methodology to calculate housing need and will be required to “demonstrate exceptional circumstances” to deviate from it.                                                                

The government’s target, based on its standard methodology, is to build a million homes by the end of 2020. But a report released this month by the National Audit Office, ‘Planning for New Homes’, admitted this target will be “challenging to meet”, and found the standard methodology approach has “weaknesses” and “as a result will be revised”.                                                             

Although local authorities in the South and East of England are being pushed to build significantly more new homes, the report explains that the latest standard method of assessing housing need specifies that the minimum numbers of new homes needed in some areas is now less than the local authorities had previously assessed – in the North West, by 24%.          

Responding to Mr Burnham’s comments, Mr Malthouse said: “We need more homes in the right places and we are reforming the planning system to ensure this occurs. “But we have been clear that the use of green belt land should be a last resort, with the standard method not providing a mandatory target.                                                                                                               

“That’s why we strengthened green belt protection with councils now having to show they have exhausted all other reasonable options to meet development needs before even considering changes to the green belt and then evidence exceptional circumstances to justify development.”                     

Copyright: Jessica Hill, Local Government Chronicle

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Further Signs of Erosion of Canvey Island Sea Defence. Environment Agency with Repair, Access issue.

Canvey Island Sea Defence continues to cause the Environment Agency a problem.

Sea Defence location Labworth

Pictured above is the latest signs of wear, requiring inspection and repair by the EA. This time in the Labworth seafront area.

On enquiring the EA attendee confirmed, that there is a problem.  

It was also mentioned that the ground, land side of the sea wall, was too soft for a crane needed to dig out the seaward side of the wall, so as to make repairs, due to the water getting under the wall.

No acknowledgement is indicated by Castle Point Borough Council, the CPBC Development Committee and Planning officers, Essex County Council nor the Lead Local Flood Authority, to the levels that tidal water seeping under the Sea Defence, influences the height of Ground Water Levels on Canvey Island!

Castle Point Borough Council, the Authority that uses Canvey Island Flood Risk as a Constraint to Limit Housing Growth, across the Whole Borough!

Canvey Island residents lay claim that they are treated unfairly by Castle Point Council. In turn CPBC claim they are being treated unfairly by the Government, by being threatened with Intervention due to their Tardiness with producing a Local Plan!

Apparent outrage from the CPBC leader and chief executive, at those Councillors brave enough to Reject the draft Local Plan, did not disguise the fact that the emerging Plan deserved closer Scrutiny and Challenge from Councillors, than those Reasons given for their votes of Rejection during the December Council Meeting.

Whether the Failure of the Local Plan 2018 is due to CPBC Incompetence, or whether some perceived levels of Immorality, or political corruption, is involved in the selection of the Canvey Island Green Belt sites for Housing Development, especially in the approach to the application of the Sustainability Tests involved, we leave the Reader to decide.

As you are probably aware, the whole of Canvey Island is regarded as being in Flood Zone 3a. Housing in this Zone is considered as being Vulnerable development.

The whole of Canvey Island is also considered to be a Critical Drainage Area.

For ease and to avoid confusion wording highlighted in Blue are those of CPBC whilst wording in Red is official Government Guidance.

The Castle Point Local Plan 2018 version at Paragraph 17.4 states “planning policies should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes and policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts”

Typically though, of CPBC, and despite their Officers and some members,  insisting that the NPPF should be “Read as a Whole”, the Local Plan 2018 version Craftily fails to include the final, and most Important part of the NPPF text of the above Paragraph 17.4.

That is; “ , such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.

CPBC Sequential Test Page 2

This Local Plan Evidence document almost immediately sets out to justify, carte blanche, large scale Housing development on Canvey Island.

Bear in mind that Housing and Residential care Homes are considered to be a “More Vulnerable” uses of Land in Canvey Island a Flood Zone 3a area.

“The NPPF recognises that following the application of the sequential test, it is not always possible, consistent with wider objectives, for certain development proposals/requirements to be located in lower ‘flood risk zones’. It therefore also sets out a test that needs to be passed if certain types of development are to be exceptionally allocated in a local plan”

Exception Test

All of the Canvey Island Housing Sites are considered by CPBC to Pass the Exception Test, “This site has significant positive impacts related to the sustainability objective concerning the provision of housing, including affordable housing.”

Affordable Housing being considered practically Unviable on all Housing Development Sites, even those not requiring the Surface Water Management measures, and Sustainable Urban Drainage schemes, and Raised Floor Levels that are now required on Canvey Island.

Additionally the CPBC Sequential Test found that, NONE of the 9 Housing Development Sites allocated for Canvey Island is considered to be “Within a Potential Surface Water Flooding Hotspot”, whilst 4 of the Mainland Housing Sites were within a potential flooding Hotspot !

Clearly the evidence found in the Reports, on the Canvey Island Summer Flooding 2014 and 2013, has been discounted, ignored and will be hidden from the Government Chief Planner and Planning Inspector examining the Next CPBC Local Plan!

Groundwater Flooding

“All the deliverable and developable sites assessed in terms of their risk of groundwater flooding were found to be appropriate for development, at least in this respect.”

We would ask CPBC “what Tests and Reports  were their Assessments based on?”

Once again only certain Mainland Sites were considered to be “Within an Area Susceptible to Groundwater Flooding”, NONE of the Canvey Island Sites allocated for Housing Development were considered to be affected!

This goes Against common local knowledge AND written evidenced Reports to be found on CPBC’s own website!

Recommendations

“Subject to other considerations, it is recommended that when selecting sites for development in the New Local Plan, preference is given to those sites within the highest preference ranking groups over those in lower groups. This will reduce the exposure of new development to flood risk.

It is recommended that housing sites on Canvey are only allocated as a means of providing flexibility to the housing land supply. If sites on Canvey are included within the New Local Plan, a sequential phasing requirement should be applied within their allocation policy to ensure other sequentially preferable allocated sites are brought forward first. Additionally, requirements in the allocations policies should include the provision of flood resistant and resilient design.”

Quite clearly the Housing Development Site Allocation process, of Castle Point Borough Council, applies considerably more Weight on Green Belt protection over that of Flood Risk. The local authority Actively Chooses to adopt this approach despite some sites on Canvey Island being both Green Belt, within a 3a Flood Risk Zone and a Critical Drainage Area!

Government Guidance in the NPPF continues to point out;

“11. Plans and decisions should apply a presumption in favour of sustainable development.

 For plan-making this means that:

b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i. 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 6

Footnote 6 The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.”

“Incompetence”, perceived “Political Immorality”, or a “Corruption of Facts”, you decide, if not the Examining Planning Inspector most certainly will!

Canvey_060309_1

Canvey Island, densely urbanised yet always room for more!

 

Canvey Residents, Local Plan 4,000 new Dwellings! A Must Attend Meeting, for US All! Make Your Councillor Aware of your feelings! Think the Paddocks and Jellicoe are bad, you wait until this Plan is implemented! Another fine Mess we are Left In!

Canvey Islanders, this time next week our Fate will have been decided!

A meeting to consider the CPBC Local Plan 2018 with sites identified for 4,000* new dwellings, and the release of vast tracts of Green Belt and green field sites will have been held and a decision made!

Benfleet Residents will be mobilised to attend the meeting on the 28th November to influence their councillors.

Canvey Island Residents should be prepared to do the same!

Details of the meeting are below.

Cllr Smith and the Chief Executive of CPBC will be giving the Green Light to developers in areas such as the Dutch Village cornfields, the Triangle, the Paddocks, Thorney Bay and Jotmans farm!

This decision will have a fundamental affect on our daily lives if allowed to happen!

Whether your current concerns are the daily Traffic Congestion, the removal of the Rapid Response Vehicle, the NHS “reorganisation” in our area, access to Doctors, Schools, the loss of Green Fields, Flooding of our Homes, be certain that if our Councillors vote to Approve the Local Plan as it stands, these issues will intensify!

We must Urge our Councillors to actively Vote Against this Local Plan, even if Intervention is the only option.

As it was explained in the previous POST the threat of Intervention may not be quite as bad as portrayed by cllr smith and ceo marchant. Certainly the removal of local input, was exaggerated.

Back in June Castle Point councillors were threatened by the effects of Intervention and the benefits of CPBC retaining control of the Local Plan;

By the cpbc ceo: with intervention “Council with no say over Plan making locally, and no influence over the outcome”

By Cllr smith said: “keeping the plan making process in members control is of paramount importance for cllrs and residents to keep control of the shaping of our future Borough.” “Green Belt assessment a set process and promised member involvement in that process.

“By cllr Stanley: “give confidence to the gov minister that he can leave the job safely in our hands.”

I wonder how worse it could have been?

We must Urge our Councillors to actively Vote Against this Local Plan, even if Intervention is the only option.

Part of the Local Plan is to consider Constraints against development. Across the Borough Green Belt is a major Policy Constraint against development.

On Canvey Island, in particular, a second major Constraint is Flood Risk. CPBC have consistently used Flood Risk as a Constraint against development Housing Numbers across the Borough.

Where Flood Risk actually threatens, on Canvey Island, the Constraint is Not applied to development. In effect the Borough Housing Supply Numbers are reduced, but not on Canvey Island specifically.

We must Urge our Councillors to actively Vote Against this Local Plan, even if Intervention is the only option.

The population of Castle Point increased over the previous Census Period 2001 -2011 by just 1.6%.

However, the distribution of this increase is interesting, Canvey Island, where Flood Risk is an Actual Threat, was 2.6% up, whilst the Mainland saw just a 0.8% increase!

We covered this in more detail HERE.

We must Urge our Councillors to actively Vote Against this Local Plan, even if Intervention is the only option.

With the development of Jotmans Farm, of 900 dwellings, comes a Link Road, wait for it, ONTO CANVEY WAY !

The intention is to form a junction from west Benfleet to meet Canvey Way halfway along.

Canvey Island Commuters will only have to envisage the effects of traffic having priority from the right at junctions to imagine how this will effect the Island!

It is clear this Local Plan 2018 is a Bad Plan.

We must Urge our Councillors to actively Vote Against this Local Plan, even if Intervention is the only option.

At least the possibility of a Neutral view on development distribution may be applied, rather than this biased version!

A list of our CPBC councillors contact details can be found HERE.

The Local Plan meeting to decide where and when development across Canvey Island will take place Wednesday 28th November start 7.30pm at Council Chamber, Kiln Road, Thundersley, Benfleet, Essex, SS7 1TF.

*mainland residents group claim.

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

Canvey Island in the lap of the Gods, otherwise known as Castle Point Council Leader and CEO! Better for CPBC to Control the Destiny of Canvey Green Belt, or the Government Chief Planner?

Canvey Island and Castle Point residents should be concerned to know that in exactly 4 weeks time, to the day, we will learn whether the desperate attempts by our councillors, and professional officers, to avoid Government Intervention over the debacle of the cpbc Local Plan has been worthwhile.

We were told that Intervention, “Takes away the ability for us (cpbc) to control the destiny of land in the Borough for our residents”

Previously in the Local Plan process Canvey Island was the ONLY area within the Borough that these, mainly, same councillors could agree to the release of Green Belt land for development, during the whole Plan period!

Obviously the Inspector rejected this idea, stating quite clearly “some development at Canvey Island may be required to meet local need”.

Plain to see then, that the level of land needed for Housing Development on Canvey Island, did NOT require the release of Green Belt!

BUT NO, cpbc chief executive, in his infinite wisdom, thought the opposite, and further proposed that, Canvey Island Green Belt, should remain the single area forming the nucleus of the Green Belt Housing Growth in the Borough’s Local Plan, whilst adding the mainland Green Belt sites for the 2014 version.

This belying the Inspector’s clear intentions, contained within his critical letter, addressed to cpbc Head of Regeneration & Neighbourhoods, strongly suggesting the Withdrawal of the Core Strategy plan!

Canvey Green Belt was only removed, gratefully, from the 2016 version of the cpbc Local Plan’s Housing growth sites, to add support to the politically driven protection granted to, selected sites identified as, “virgin” Green Belt land.

Now we have just 4 weeks to wait to learn how, and why, the Local Plan process, is better in the hands of our local councillors, rather than the government Intervention team.

In CPBC’s own words; “the Secretary of State wrote again to the Borough Council in March 2018, indicating that he was minded to continue with intervention since there was no clear timetable for preparing and adopting a local plan for the Borough.”

“Intervention by Government in any area of local government business is a last resort and follows poor decision making and failure to follow Government direction and advice.
Members of the Council will not be involved and will be excluded from the plan making process.
In terms of decision-taking, the Government will wish to make certain after intervention that the statutory development plan and policies for the Borough will be implemented and will not allow the local plan once agreed to be frustrated by the Development Control process.”

“As one of the very few planning authorities under intense scrutiny by MHCLG, (ministry of housing community and local government,) the Council remains at great risk of intervention and this will lead to considerable reputational damage on a national scale. This may cause other non-intended consequences such as the inability to attract staff”

The mood of Residents, particularly mainlanders, suggest that only if substantial Green Belt is protected from development, will it have been worthwhile staving off Intervention.

Canvey Residents can be sure that the extra Constraints that should have been applied to Canvey Island in isolation, would ONLY have been applied correctly by Government officials. History has proven that lead group councillors, in collusion with certain officers, have only sought to use these Canvey Constraints, to lower the OVERALL Housing Supply figures ACROSS of the whole Castle Point area!

In effect cementing the lead group’s controlling status quo in the follow up local election by quelling the mainland unrest by removing the contentious Green Belt sites from the 2016 local plan.

Look also at similar protectionist decision-making at Brentwood council, with their plan to develop a Garden Village at Dunton.

Note also the effects the Brentwood plans will have on Castle Point residents, with the amount of proposed housing development alongside the main A127 commuter route adding to the Basildon planned development.

Divided by the A127, Dunton Hills Garden Village will have little or no impact upon Brentwood. Those of us living south of the A127, especially in Castle Point and Basildon, will bear the brunt of the strain on infrastructure and commuting issues.

Dunton Hills Garden Village, which Brentwood Borough Council says could initially deliver about 2,500 homes, with the potential for another 1,500, has come under the most fierce criticism from Thurrock Council, that along with Basildon, borders the borough close to where the development would be built on 260 hectares of land south of the A127. *
Brentwood Borough Council is meeting on Thursday, November 8, at the Brentwood Centre to discuss the next stage of the borough’s Local Plan – principally how and where to cater for the 7,752 new homes the borough needs to find between 2016 and 2033. (yourthurrock.com)
*wasn’t we informed by cpbc that in the case of a Garden Village proposal at the Blinking Owl site, North Thundersley, that 8,000 dwellings would be needed to make the installation of infrastructure financially viable?

Look at these statistics, area, population etc and judge whether there is a balance of growth distribution across ours and Brentwood boroughs.

Brentwood: Area: 153.1 km², Population 73,600 (2011). 7,752 new homes.
Castle Point: Area 45.08 km, Population 88,011 (2011). new homes tbd (see below)

The expectation, is for cpbc to capitulate to the Government Chief Planner, and reintroduce the 2014 daft Local Plan with these implications for us;

The council has identified 13 locations for housing development, with 4,000 more homes required in the period to 2031 to meet growing demands of our community. This means around 200 new homes a year would be built across the whole borough. Without the plan, it is feared that there would have to be at least 7,000 more homes.

Don’t forget that the cpbc lead group and some independent councillors, agreed this daft Plan. Only under the threat of a Mainland residents backlash at the Polling Station, was this Plan rejected!

Below are Maps of the Brentwood and Thurrock boroughs, the implications on Canvey Island and Castle Point, by the population and Industrial growths of these two neighbouring areas, can be easily imagined if complimented by similar growth in Castle Point!

What of cpbc leader’s promise of infrastructure before development? With growth in the neighbouring areas and no realistic likelihood of Highway improvements, new access to Canvey, dualling of Canvey Way, Somnes Avenue widening, Roscommon Way completion etc, the likely announcement of many large developments sites bodes ill for Canvey Island!

Castle Point Residents will be eager to learn, the benefits of “control of the destiny of land in the Borough for our residents”, over the dreaded Government Intervention!

Screenshot (18)

Screenshot (19)

To Intervene or to Not Intervene, that is the question: Whether ’tis nobler in the mind to suffer, as Simple Minded and Disobedient Canvey Folk suffer, Or to take arms against a sea of troubles.

Much will be read and disclosed over the next year or so, when it will be wondered whether the June 2018 decision by Castle Point council, to rush into a Local Plan schedule, with the prospect of a New Local Plan approved by Council for publication by November followed by submission to the Inspectorate in April 2019, or alternatively to face the prospect of Government Intervention, is the best path to tread, especially where Canvey Island is concerned.

“sometimes orders given to the simple-minded have to be reinforced with a threat, a suggestion that something terrible will happen to the disobedient,”

And so it was, when the cpbc chief executive, the council leader and his deputy, stated the case for cpbc seeking to retain control of its Local Plan making, rather than allow Intervention from the Government Planner.

The councillors and residents were not permitted an address from the Government chief planner, choices and their consequences were expressed only third hand delivered by the cpbc triumvirate.

But whilst keeping control of the Local Plan process is in the very best interests of parts of the mainland, is it also in the best interests of Canvey Island, a reasonable question to ask?

Harking back to the Core Strategy we exposed a Plot by the “Ruling” mainland party to sacrifice Canvey’s Dutch Village Green Belt site, as the sole Green Belt site released for development, so as to appease their mainland concerns and allow publication of a cpbc Core Strategy, local plan!

We remember well, the mainland residents Green Belt campaign group, during the council Task and Finish group meeting, standing to address council members confirming that they agreed and supported the Plan “in its entirety!”

Where was the “united” Borough then?

When the Core Strategy was rejected by the Examining Inspector due to the unreasonable Housing Growth Distribution and the Dutch Village site being, a Green Belt site within a Flood Risk Zone, the cpbc ceo made sure that the Dutch Village remained within the list of Green Belt sites for development, whilst adding some mainland sites to meet the Housing Need of the Borough, within the 2014 daft Local Plan!

Of course the retention of the Canvey Dutch Village site, despite the Inspector’s opinion, meant that one large mainland site would be saved from development.

Now by returning to the 2014 draft local Plan as a starting place for the 2018 Local Plan, concerns return as to whether it is intelligent and responsible for Canvey residents to put their faith, as we are being told and advised so to do, within the “Ruling” party’s successful motion to Control the 2018 local Plan.

“sometimes orders given to the simple-minded have to be reinforced with a threat, a suggestion that something terrible will happen to the disobedient,”

The threat has been delivered and something terrible may still apparently happen!

We are reminded that the Dutch Village site is owned by Persimmon, implying that this would speed the process through Planning resulting in an early supply of Housing, For The Borough!

Meanwhile, the more lucrative development sites elsewhere in the Borough would, following this logic, remain undeveloped for longer, especially when the ongoing development of approximately 900 Sandy Bay Park Homes, also on Canvey Island, are put into the equation!

This may encourage some conspiracy theory, has the call for sites from cpbc entailed dealings between officers members and developers as to which site or sites would be released in which order, specifically if the developer were to agree to initially focus on Dutch Village first?

As it stands in practise cpbc focus on applying constraints on development in the so called “virgin” Green Belt areas of the Borough. Canvey Island Flood Risk is also applied to the constraints so as to limit numbers, but that constraint is applied to housing Need numbers across the whole Borough, rather than Canvey Island in particular!

Making cpbc’s approach to the application of the Sequential Test simply contrived and, a Farce!

But can Canvey residents be certain that the Government Planner would apply to Canvey Island, the supposed Constraints on Housing Development such as Flood Risk, the threat to what remains of its Green Belt and the Hazardous Industrial sites any less fairly than the cpbc “Ruling” party and officers?

Especially going by their proven Local Planning track record!

Under Cllr Riley’s regime Canvey fared better than during any of the previous attempts at Plan making.

Now Cllr Riley has been side lined by the Triumvirate now in control, and previously chiefly responsible for the 2014 daft Local Plan, despite two of them apparently also claiming to support the 2016 Plan’s attempt to constrain the borough’s Housing Numbers!

To mainlanders these thoughts may sound pessimistic and overly cautious, however being fed rumours and not having the access to decision makers that some residents appear to have, however furtive, leads to a lack of an Open and Transparent Local Plan process.

Faith in Leaders must be Earned, Blind Faith is a dangerous option.

PLANING-APPEAL-SIGN

 

Castle Point Council face Testicular Examination Ahead! Whilst Nuneaton Council act as Local Plan Pathfinders?

Having promised to stand firm over Infrastructure before more Housing, the new Castle Point Borough Council regime will now have their resolve fully tested by the Government’s team sent into the Borough to oversee progress on the Local Plan.

Riley+marchant

Residents, having shown confidence in the Lead group of councillors by giving them an increased majority at the May 2018 local elections, will be expecting them to be able to revive the latest withdrawn Local Plan following 12 months of intensive and “tireless” Duty to Cooperate work following the Examination inspector’s criticisms.

The protection of Green Belt was paramount to Residents concerns, and any backing away from the local authorities position will be open to criticism!

This may be particularly so in the light of promises to overturn the Borough Plan made in another area, Nuneaton, where the successful Conservative group promised to:

“Protect existing communities and deliver the roads, health and school services we need.
 Reduce the housing numbers based on new government guideline figures.
 Withdraw from Labour’s secret agreement to take Coventry’s overspill.” 

“Distribute housing more fairly around the Borough to enhance not destroy existing communities.”
 “Ensure our communities finally receive the much needed road improvements, schools, GPs, shops and essential facilities they deserve, 
 Prioritise Brownfield sites first, protecting our existing communities by removing unsuitable and unsustainable sites from Labour’s broken Borough plan.”

Andrew Lainton, of Decisions Decisions, Decisions blog suggests:

“However the Borough Plan is mid examination with initial findings due to be published this month.

As the inspectors findings are binding the only alternative to fulfill the manifesto would be to withdraw the local plan.

This would put the Council in special measures.” 

The Nuneaton Tory Group’s reference to Unsuitable and Unsustainable sites is interesting and should, but doubtfully will, provoke examination at Castle Point.

The wholesale blanket application of the Sequential Test across Canvey Island would, elsewhere, be expected to be deemed Unsustainable.

In effect despite being a flood Zone 3a, any Housing Development proposed for Canvey Island is deemed appropriate!

This is evidenced in each and every Application paperwork by officers, following councillors instruction, having “persuaded” the Environment Agency that Canvey Island is a Special Case!

An illustration of this, taken from the cpbc Annual Monitoring Report 2016-17 states; “It should be noted that there is no specific policy on flood risk included within the Local Plan (1998 adopted version) and therefore the Council relies on national policy set out in the National Planning Policy Framework and its technical guidance in respect of such matters.

Of course since then the Strategic Flood Risk Assessment has recognised that Canvey Island is at Actual Risk of Tidal Flooding and the Integrated Urban Drainage Study was researched and published following the 2014 Summer Flooding of Canvey Island!

Castle Point councillors, those involved on the development committee at least, appear willing to accept responsibility for future Flooding of housing and danger to residents, whether from Surface Water or Tidal.

So far that has paid handsomely. Over time and following Flood events, that may prove less so, as Housing built since the 1st January 2009 is not eligible for the Flood Re Insurance Protection that makes available affordable insurance.

Should this problem emerge mortgages on “new” builds may well be denied due to insurance issues. New Canvey Island House Buyers may well be walking into this trap unaware.

The development of Canvey Island both Industrial and Housing continues unabated, this will intensify the pressures on the already broken drainage system, and road and health service infrastructures.

The cpbc Annual Monitoring Report also states, “the proportion of new homes provided on previously developed land to remain lower than in earlier years.”

and that, even more worryingly; 

“16 affordable housing units were delivered in Castle Point in 2016/17, representing 14% of total housing provision (114 dwellings). This level of provision is an improvement on the annual average provision for the period 2001 to 2016 of 11.5%,”

An example of the inadequacy of our local authority is illustrated within the cpbc Sequential test documentation to support the first of the local plans, the Core Strategy, in which it was admitted “The Environment Agency met with the Council in 2007 to identify criteria under which they would allow development to proceed on Canvey Island. The final criterion was the need to ensure that the Emergency Planners and Emergency Services were satisfied with the measures in place to ensure safety in the event of a flood.

These services had not been consulted in the preparation of PPS25, and as such this requirement was a surprise to them, for which they were not prepared.

A typical approach by developers to overcome the Constraint on Housing by Flood Risk on Canvey Island and acceptable to CPBC is demonstrated here;

  • “The application site is located on Canvey Island, which is situated entirely within Flood Risk Zone 3a,
  • The Council has undertaken an annual review of Strategic Housing Land Availability (SHLAA) since 2011. This process has consistently indicated the need for a greater supply of housing land to meet the objectively assessed housing needs of the borough.
  • When applying a sequential test it is important to have regard to the local context. Canvey Island is a distinctive community, accommodating 43% of the borough’s population. It has specific identified needs in terms of social, economic and physical regeneration, as well as housing.
  • In order for residential development to serve the community of Canvey Island it is considered that it needs to be located within that settlement.”

The Level of delivery of Affordable Housing and the continued influx of new Residents from outside of the Area onto Canvey Island suggest that “residential development to serve the community of Canvey Island” is simply too broad a sweeping statement intended to be a means of simply granting Planning Permission to bolster the BOROUGH’s Housing Supply in an Unsuitable Location!

It would appear unusual, if not unreasonable, for a local authority to seek to increase the Urban Density by developing Green field land and intensifying Brownfield development,  supposedly under the guise of satisfying the Need of the Canvey Island Community, when in effect it simply intensifies Inward Migration, in an area specifically under the threat of both Tidal and Surface Water Flood Risk!

We eagerly look forward to learn what Resolve, Metal, Determination and hopefully Fairness, the new administration at Castle Point council are able to apply to the ongoing Local Plan process in the shadow of Government Intervention!

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

The full Decisions Decisions, Decisions post may be read HERE.