Tag Archives: Core Strategy

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

 

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Canvey New Access Road, and the Promised Yachting Marina just a Dream! Any wonder Islanders take a Pinch of Salt with the Promises?

It is usual prior to Elections that Canvey Island residents are subject to certain infrastructure Promises from Castle Point Lead Group representatives.

This year has been slightly different in that Little, if Anything, has been raised about the proposed new access road to Canvey Island, via the Manor way to the promised land that is Thurrock!

Waterside Farm

Waterside Roundabout – Unusually clear!

Even though the Leader cllr Riley did touch upon no Housing prior to improved Infrastructure in an Echo interview, this was under the duress of imminent Government Intervention in the Castle Point Local Plan process.

More Telling with respect of Road Infrastructure and new Access to Canvey Island is contained in a personal response from Essex County Council (ECC) regarding unadopted Roads.
The ECC made perfectly clear the dire straits they feel they are in where finance for Highways is concerned.

It appears that even if Government finances were made available to construct a new Canvey Island Access Road, ECC may well be extremely reluctant to go ahead with the road’s construction, due to it being their responsibility to maintain!

Essex County council wrote;
“we have limited funds available to maintain those areas for which we actually are responsible.”

Canvey Island Residents should really be far more sceptical where promises from both Essex County Council AND Castle Point Council are concerned.

We, the Canvey Green Belt Campaign were subjected to fanciful promises from no less than a team headed by the Castle Point Chief Executive and two Senior “professional” Officers, when it was arranged for us to meet following our successful Referendum on protecting Canvey Island’s Green Belt in the summer of 2009.

Having made clear to the cpbc representatives that, by a 99%+ majority, Canvey Residents were concerned over the cpbc plans to develop Housing on the Island’s few remaining patches of Green Belt, we were treated to a presentation of the proposed RSPB site on Canvey West Marsh and then an attempted engagement over the planned redevelopment of the Town Centre!

This we had to rudely interrupt the meeting over as they were distracting asides, only to then hear of cpbc’s intentions to convert the OIKOS hazardous Industrial site – into a Yachting Marina !!!

“The Council has a long‐term ambition to see operations at the Hazardous Installations at South Canvey cease, improving the safety of existing and future residents living on Canvey Island.”

“With regard to the deliverability of this ambition, the council’s Policy CP9 is a long term policy which looks beyond 2020 to a time when dependence on gas imports and fossil fuels in general is significantly reducing.”

The levels of intelligence that Castle Point Council credit Canvey Islanders with is woefully inadequate and insulting.

It is undoubtedly this arrogance that has taken cpbc to the threshold of Government Intervention following 3 attempted publications of a Local Plan, each ignominiously either forced into Withdrawal or Rejection, further endangering the Borough’s Green Belt and increasing the levels of population at Risk of Flooding or Industrial Accident.

Update.

Since this Post was published, an election leaflet has been delivered from the controlling group. 

It states that “Plans for the final stage of Roscommon Way are in progress.” and our MP and her colleagues “are demanding Government funds the third access road”.

Photograph Courtesy: Echo Newspaper and Google 

Canvey Housing to replace Garages. The Borough’s Housing takes Priority although Officers need to Get a Grip of Fact over Fiction!

It might be Funny, if it wasn’t Canvey Island!

More Canvey Development will be the Agenda, for the Castle Point planning committee this week. This time demolish garages and replace with 4 houses at Church Close, Canvey.

This time around the Development Applicant is Castle Point Borough Council themselves!

Canvey Big Local £1 million

Fair enough, the Borough needs Housing and we have the Chief Planner to please, if Intervention is to be avoided. However the context may be worthy of some consideration in this instance.

Church Close, Canvey Island, falls within the “Canvey Big Local” area, the area allotted £1,000,000 as an area in west Canvey with social and deprivation issues.

“The area does suffer from some levels of deprivation with approximately 38% of children under 16 being classed as ‘in poverty’ compared to 18% on average for both Castle Point and Essex and 5.9% of households within the area deemed to be in fuel poverty.

Residents have reported that a key issue for them is crime and antisocial behaviour.” 

The thought did occur that the land the garages are sited on might have been better used as an area the “Canvey Big Local” scheme might have been able to utilise for the betterment of the youth of the area rather than Housing, especially as the garages are little used and must bring in little income to the local authority.

But Housing Numbers for the Borough is the tunnel vision focus and Canvey must take more is the order of the day!

Taking this focus forward cpbc case officer comments;

“The application site is located within Flood Zone 3a, which has a high probability of flooding.

Looking at the whole of Castle Point District it would seem that there are areas within Flood Zone 1 that could accommodate this form of development. However, given that the only areas of Flood Zone 1 in the district are on the “mainland” part, such an approach would direct all new development towards Benfleet and Hadleigh.

Canvey is a self-contained community with its own housing needs and directing all new development towards Benfleet and Hadleigh could have an adverse impact on Canvey socially and economically.

Furthermore, a need for housing on Canvey cannot be met by building around Benfleet and Hadleigh due to other constraints such as the Green Belt. 

Taking these factors into account it is considered that the ‘catchment’ for the sequential test ought to be drawn around the boundaries of Canvey Island, the whole of which is within Flood Zone 3, so there are no reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding, and the application is considered to pass the sequential test.”

Some might suggest a little bit of a “giveaway” that council members have at some stage exerted their own preferred policy over officers’ ethical planning guidance.

Bordering on the comical is the case officer’s attempts to justify his/her decision Advice for committee members!

“The Flood Risk Assessment contains structural calculations at Appendix B, however, notwithstanding the illegible handwriting, it does not appear that these contain a non-technical summary explaining what the calculations demonstrate.

If members decide to grant planning permission, a condition is necessary to require the developer to submit demonstration that that the buildings will be able to withstand the hydrostatic and hydrodynamic pressures likely to act upon them in modelled flood events.”

“The proposed surface water drainage strategy states that attenuated discharge will take place to the existing surface water drainage infrastructure. The planning authority are aware that ground conditions in the area (clay soils) are fairly impermeable which means that infiltration techniques are unlikely to work effectively. There are no surface water bodies on or in the vicinity of the site which could receive surface water from the proposed development and the drainage of surface water to the surface water sewer would therefore seem to be an appropriate option.
The site is not considered to be at risk of flooding from other sources except from surface water. This form of flooding can be a problem on Canvey Island, although the site is not highlighted as a particular hot spot.

The proposed discharge rate is, however, not known, and there is no demonstration of permission in principle from the relevant water authority to connect to the surface water drainage infrastructure”

In normal circumstances one would expect finalised plans for flooding to be included in the proposal, especially as cpbc are the applicant and supposedly being fully experienced and informed of such local matters, rather than allowing plans to follow as a Condition!

All looking very Professional so far then?

So, being in a socially deprived area, what form of Housing would improve matters?

Certainly not Housing that offers;

“There are no first floor windows in the rear or other side elevations.

The proposed dwellings would be located 1m from the rear boundaries of the existing properties”

Will this standard of Housing do anything to alleviate the socio economical blight of the area?

And if this wasn’t all embarrassing enough, remember in this case Castle Point Council themselves are the Applicant, the proposal’s paperwork uses the withdrawn and ridiculed 2010 Core Strategy as evidence to support this application;

“The Castle Point Borough Council Core Strategy outlines a housing requirement of 5,000 new homes between April 2001 and March 2026. Most of the requirements can be meet by housing provision in the urban area, particularly town centres, main route corridors and other undeveloped land. However, it is not considered possible to meet the entire boroughs housing needs from the above sources, particularly on Canvey Island.

The proposed site although not in an allocated development area is surrounding by housing and lies equidistant to the proposed development areas of ‘East of Canvey Road’, Castle View School’ and ‘Canvey Town Centre’. The site can be considered a windfall site.”

The Core Strategy document is something even cpbc refer to as: “It should be noted that the Submission Core Strategy does not represent Council policy.”

Stand by for more committee member Hand Ringing tomorrow as they reluctantly give their Approval!

No, You Really Could Not Make It Up!

 

Canvey Island Nimbyism? RTPI attack on Ageism amounts to Stereotyping – who else to “Watch this Space”?

Protest against Green Belt development in Castle Point, is definitely not the sole domain of Canvey Islanders.

Whilst we feel we have more to protest about than most, despite being considered to be “not living in the Real World”, even by some of our own representatives, it cannot be argued that issues facing Canvey Island are not unique.

Whether it be the fact Canvey Island is the most densely urbanised part of the Borough, the removal of Canvey’s Rapid Response Vehicle, the 3rd access Road saga, the broken drainage system, the Roscommon Way Racers, lack of street lighting on unadopted roads, or living alongside 2 major Hazardous Industrial sites, concerned Canvey residents are often greeted with a “them again?” luke-warm welcome!

But that is not to exclude our mainland neighbours who are equally willing to object against planning issues where Green Belt and other supposedly worthy development proposals are concerned.

Now it appears it has been recognised that the majority of those willing to get involved in the planning process are of a certain age group.

“Currently, the majority of those who engage in planning are over 55 years. Response rates to a typical pre-planning consultation are around 3% of those directly made aware of it. In Local Plan consultations, this figure can fall to less than 1% of the population of a district. Yet planning decisions are based upon this sample.
Well-managed consultations start early, seek a more balanced engagement and encourage the ‘strategic’ thinkers to engage, but they too frequently fail to engage with the younger age groups – yet we are planning their future. What other organisation would base important decisions on this level of response without checking to see if it was ‘representative’. Yet this is what happens in planning decisions.”

So says Sue Manns, the Regional Director of national planning consultancy Pegasus Group, in an article for the Royal Town Planning Institute. Pegasus being the planning group involved in the Jotmans Farm development Inquiry.

The article appears to suggest that through the lack of engagement with a “younger” consultee audience, modern development plans struggle to be adopted through the objections from those more senior amongst us residents.

“We need to start a nationwide conversation around the spatial impacts of technology change, embrace young and dynamic thinkers and those who see change as exciting, and let’s rebalance the objection-driven engagement culture which has dominated planning over the past 50 years.”

Whilst Canvey residents may not be considered by cpbc, and perhaps Sue Manns, to be dynamic thinkers, they would be wrong in their assumption to consider us as not recognising change when it is exciting, as long as it is realistic!

The cpbc promise of the grandly titled “Canvey Island Town Centre Regeneration Masterplan” is a case in point. Unfortunately scepticism was well founded, as the lack of tangible progress alongside the failure to incorporate the proposed Dutch / seaside architectural features into new proposals, has led to blandly designed and cramped Flatted and Retail developments to pass approval!

 

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Building materials to reflect the overall palette, drawing on the Dutch, Coastal Town and Art Deco influences to create a scheme with a unique identity.
Colours should be vibrant to establish the new retail area as a destination. Shop front improvements along Furtherwick Road should be designed with the distinctive features of an English Seaside Town.

With prose being used, similar to that above, to encourage support for aspirational design schemes, it is hardly any wonder that Sue Manns has identified a failure of the industry to engage with a younger audience in planning consultations. The lack of younger generation involvement may be true, but that is not a reason to support the thought that adult and senior views should be ignored simply to support any particular development plan that may indeed, not be suitable for a particular area.

We on Canvey Island have seen the value of “local knowledge” within the Plan making process!

When the 2009 cpbc Core Strategy attempt at a local plan was published the Canvey Green Belt Campaign, through “local knowledge” recognised the attempt to mislead the Examining Inspector with its “inappropriate housing site selection” policies, which “commits to Green Belt release in an area of potential high flood risk”, as well as it being obvious he would not be “convinced that maintaining the current distribution of development across the Borough is justified given the existing constraints”.

This despite cpbc officers being party to the clear intent of the mainland lead group to allow themselves to be influenced by, and produce a local plan driven by, what the Inspector politely described as “Local Factors”!

In this light, of course we HAD to get involved, despite being within the age bracket that Sue Manns and her planner colleagues have an issue with!

Committing to attending a 2 week Examination following production of a lengthy consultation submission is not achievable by all, however when your own local authority have schemed and approved such a discreditable document, it must be challenged and exposed for what it was. Not everybody is in a position, or willing to commit to taking part in plan making process, as it bound to require taking unpaid leave or using holiday periods. Something those with young families for instance may be unwilling or unable to commit to.

Perhaps Planners and developers would prefer that no residents, whatever age bracket they fall into, take part in the planning process? One thing we did find was that the Examining Inspectors appear to welcome local input!

The feedback from our Referendum equally challenged Sue Mann’s assumption that a younger demographic would automatically give the different response that she and her  planner colleagues would hope for, by achieving “a more balanced engagement and encourage the ‘strategic’ thinkers”.

Castle Point council gave evidence, indeed if it can be considered of value, that they extended their consultation to specifically target established groups of youngsters as part of the Core Strategy consultation.

What the Canvey Green Belt Campaign witnessed however, was perfectly clear. By calling on residents at their homes and putting to them our Referendum question, it was absolutely clear, that the loss of yet more Canvey Green Space to the Borough’s Housing Need was indisputably opposed across generations!

Planners may begin to achieve the respect they crave if they were more driven by an local area’s actual needs. Aspirational architectural computer imagery with green spaces screening dense urbanisation deceive nobody.

Equally the promises of Affordable Homes, later challenged as being unviable, is a deception we are getting more and more familiar with, especially in the light of Green Belt release and sky high housing prices.

RTPI and Sue Manns, nice try, but must try harder!

ps Lets not feel too much sympathy for the industry: “The chief executive of housebuilder Persimmon has insisted he deserves his £110m bonus because he has “worked very hard” to reinvigorate the housing market.” (Guardian)

A link to the Canvey Island Town Centre Regeneration Masterplan can be found HERE.

The full blog post by Sue Manns can be found via this LINK.

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Oh the Irony! Councillors Propose a Referendum!

Canvey Islanders feel they are Not Listened to!

Hence they held a Referendum to Protect what is left of the Island’s Green Belt, then a Petition was completed objecting to large scale development.

All to No Avail.

Both Referendum and Petition were Ignored by castle point borough council!

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Now we learn that it is the intention of Rochford councillors to carry out a Referendum over the district’s Local Plan.

Councillor John Mason, leader of the Green and Rochford District Residents Group said that during the early stages of the new housing plan, residents have complained “they feel that they will not be listened to” about their council and councillors.

No doubt Rochford council will spot the opportunity of the “Tick Box” exercise, as have castle point council, in suggesting this fills the community involvement requisite!

You may well remember that the Canvey Green Belt Campaign supporters went out in 16 groups of 2, over a two week period seeking the views of residents about cpbc plans to develop Canvey Island Green Belt.

Over 6,500 votes were cast and under MP Rebecca Harris, cllrs Ray Howard and Dave Blackwell’s observation an objection via 99.13% of voters was recorded!

Typically the daft Local Plan 2014 ignored these views!

Following this a Petition was raised by a group of 6 Canvey Ladies and a total of 12,000 names were added to their Petition list. The Petition was against large scale development on Canvey, whilst the opportunity to protect the local builders could remain.

The Petition has also had No Impact with those controlling cpbc!

This despite the constraints that would normally be applied to development in areas such as Canvey!

Whilst Rochford does not have constraining issues, such as 2 Hazardous Industrial sites, being in a Flood Risk Zone 3 area, having the access issues that Canvey is restricted by nor the whole of the town being a Critical Drainage Area, we do wish the Rochford councillors success in their Referendum.

Far greater success and acknowledgement than Canvey Island residents received by the controlling group of our local authority!

The Echo article on the Rochford Referendum news is available via this LINK HERE.

Castle Point Councillors – Intervention and Fear, should they continue defying Logic! Local Planning under Duress. UPDATED

Fear and Intimidation appeared to be the message to Canvey Island and Castle Point councillors as they come to consider in Secret, the implications of being listed by Secretary of State Sajid Javid over their lack of progress on a Local Plan, and being  in danger of Government Intervention!

At the December 2017 council meeting the cpbc Chief Executive made clear that unless either good progress is being made regarding the Duty to Cooperate, or clear constraints are recorded in the reply to the Secretary of State as to why progress isn’t being made, Intervention is likely.

The CEO stated that he neither wished to, nor expected to be put in the position of drawing up the new Local Plan, whichever version is now being worked on.

Instead Intervention would likely be taken by an outside body, for instance the Planning Inspectorate, a specialist organisation or perhaps even those south Essex councils working collectively on the Duty to Cooperate.

If it doesn’t already this should Ring Alarm Bells for those Residents living on the mainland!

You may ask why those Residents in particular?

Well, during the cpbc Core Strategy process, during 2009 Baker Associates appointed to consider the Sustainability Assessment on the Housing Site selection process drew attention to their being puzzled, as to why cpbc should overlook choosing for development, the Borough’s Highest Scoring Sustainable site. They wrote;

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 Sustainability Assessment suggests that the allocation of this site could have preferable implications for sustainable development than other “mainland” allocations.

This Appraisal extract gives clear indication of how a planning consultant, and most likely the Planning Inspectorate would apply a logical approach to Housing Site Allocation, should they be appointed as a Local Plan Intervention measure!

Similarly, as Baker Associates were responding to a cpbc report, one must consider it most likely that a similar approach would be taken by cpbc officers if they were appointed to undertake compiling the next version of the cpbc Local Plan!

An Inspector, should one be required to Intervene and produce a Local Plan may likely produce one completely undesirable to mainland councillors preferences. Remember these comments from an Inspector;

Additional material…

“An exercise was then carried out to objectively assess these sites against a number of criteria. I have reservations about the methodology employed and the way in which it appears to have been used, leading to inconsistent and inappropriate site selection. For example, the Council’s own Sustainability Appraisal is unclear as to why the most sustainable Green Belt site was discounted.”

“I therefore consider the Council needs to revisit its assessment of Green Belt locations paying particular regard to the five purposes of the Green Belt as set out in PPG2. I accept that other considerations will also influence the choice of sites but potential locations should not be dismissed because local factors are given too much weight. This appears to have happened previously.”

“The Council’s desire to protect its Green Belt areas is understandable but its approach has also had a considerable bearing on the overall distribution of growth promoted in the Core Strategy. In this respect, I consider it would be difficult to endorse a strategy which commits to Green Belt release 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, I am not convinced that maintaining the current distribution of development across the Borough is justified given the existing constraints.”

The above comments highlight the desired distribution of Housing Growth across “certain” parts of the Borough of lead group members and is indicative of the perceived use of Canvey Island to their retention of control of cpbc.

The latest drive is to seek out Brownfield sites to supply the new Housing Allocation.

The Brownfield site list drawn up by cpbc and included alongside the council meeting’s Agenda paperwork indicated a minimum of 254 dwellings on sites achieving the required criteria.
This supply was contained in Part 1 of the Brownfield Register.

No sites were put forward as being eligible for Part 2 of the Register, those having been granted by cpbc, Permission to develop in Principle.

The chief explanation given for this being;

“Canvey Island is within Flood Risk Zone 3a, and as such planning applications for residential development normally require a Flood Risk Assessment. Advice is awaited from the Environment Agency as to if and how the Council could go about addressing this requirement before proceeding to consider any sites on Canvey Island for inclusion on the Part 2 of the Register”

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It appears that behind the scenes there remains a refusal to apply development Constraints equally across the Borough, the focus has been and remains Canvey Island, where development is concerned!

Interestingly no specific reasons for sites in other areas of Castle Point not being granted Permission in Principle and inclusion in Part 2 of the Register were given. Presumably they were covered by the caveat “a decision on whether to grant “Permission in Principle” to a site must be made in accordance with relevant policies in the development plan unless there are material considerations”

For the record the Brownfield list may, just, fulfil one years development supply of Castle Point’s required 5 Year Housing Supply requirement!

The Paddocks site, was not included in the Brownfield site Register, possibly because, as we were informed by Cllr smith, all options are open and no decision has yet been made whether to demolish or carry out much needed work on the building!

Interestingly during the council meeting a question about the total sum estimated to renovate the Paddocks was raised by Cllr Campagna, to which we the council leader explained that the £1million+ is a figure estimated to be required spending over the next 20 Years, and NOT as we were allowed to believe by Cllr smith at the Canvey Community meeting, required immediately!

The Blinking Owl site, seemingly the answer to the mainland’s Housing Supply requirement is excluded from the Brownfield Register.

This site first made public during March 2014 appears yet to have had a firm development application proposed to cpbc.

A Local Plan Examiner would be more likely to take the Blinking Owl venture seriously, should there have been some development proposals for parts of this site already on the table, but there is not!

Duty to Cooperate work is ongoing with cpbc being represented by the council leader, his deputy and senior officer/s. It appears that officers are applying the results of the DtC work into a newest Local Plan.

Should the efforts of this cpbc delegation be found worthy and Government Intervention be avoided, in the least the cpbc Local Plan will represent a localised extract of a South Essex Regional Plan. Ironically Regional Spatial Strategies were abolished after 6 years in 2010.

The newest Local Plan version may bear severe repercussions should the cpbc council choose not to approve, given the Duty to Cooperate work being carried out by cpbc leader and officers.!

A meeting will be held in secret at cpbc, to presumably inform councillors of the Duty to Cooperate progress and the Fears of Intervention, during this week.

Castle Point is not the only local authority failing to find enough Brownfield site to fulfil their immediate Housing Needs. More can be read via this LINK.

Can the Principle of “Localism” survive the Duty to Cooperate between Castle Point and Neighbouring Authorities attempts at Cooperation?

Local Development Scheme July 2017
This Local Development Scheme (LDS) sets out the programme for preparing planning policy documents in Castle Point. This version replaces all earlier versions of the LDS, including that issued in March 2016.
By giving this a new title will not hide the fact that there has been failing via the Core Strategy and two other versions of a Local Plan!

Castle Point Borough Council seeks to prepare a local planning framework based on a series of statutory and non-statutory planning documents as development plan documents and supplementary planning documents, covering strategic and local matters.

The LDS sets out the Council’s programme for achieving this.

Perhaps an indication as to why other plans have failed, let’s investigate;

In order to ensure that the planning policy documents that are prepared by Castle Point Borough Council are robust, and do not come under criticism at examination or appeal, the Council will be seeking to ensure that its evidence base is complete and that all work has been carried out in accordance with the relevant legislation and guidance.

Is this a suggestion that all other works have not been ROBUST and therefore unable to withstand criticism?
Or, worse still;
That the previous works were not carried out in accordance with relevant legislation and guidance!

This includes ensuring that consultation is effective, and also ensuring that opportunities to work with our neighbouring Councils, Essex County Council and other service providers have been fully considered and integrated into the documents where appropriate, consistent within the “Duty to Co-operate”

A Robust Evidence Base
Any development plan document must be based on adequate, up to date and relevant evidence about the economic, social and environmental characteristics and prospects of the area and takes account of relevant market and economic signals to inform judgements about demand.

Having an up to date local planning framework reduces the risk that the presumption contained in the NPPF will apply, to grant permission where the existing Local Plan is absent, silent, indeterminate or out of date.

This statement unfortunately speaks in-itself.

Some of the documents listed as being complete, are quite simply, out of date!

Not everyone within the local community engages with planning consultations regardless of the amount of effort taken by the Council. As a result, it is also necessary to use empirical evidence to ensure that the needs of everyone represented by the Council are fully considered.

Clearly there has been a huge failure on the Councils part to engage with our community

Community Engagement
Every planning policy document will need to be the subject of consultation in accordance with the Town and Country Planning (Local Planning) (England) Regulations 2012.

In practice, before each consultation, a consultation plan will be prepared by the Council detailing how the Council will:
• Promote the consultation; • Make information available; • Engage with residents; and • Manage consultation data.

It is the aim of the Council in all cases to engage as widely as possible with “duty to co-operate” bodies, statutory and non-statutory consultees, local residents and businesses on plans and proposals that may affect them.

Clearly there has been a huge failure on the Councils part to engage with our community despite seemingly its best efforts. CPBC blames the community for its failure of a successful community involvement outcome.

What CPBC appear to have missed is that the community feel, done too, by not being asked.

A petition of over 10000 signature demanding infrastructure prior to any further large-scale housing development, not being recognised by CPBC as community engagement is rather typical!

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Largest ever Canvey Island Petition: Ignored by Castle Point Borough Council!

Empirical evidence (based or acting on observations or experience NOT ON THEORY) has been the fundamental failure of the content of several of the evidence based documents used to support the previous debacle of CPBC Local Planning. To continue with this style of documentation will once again make the CPBC Local Development Scheme not only challengeable but unsound.

The NPPF explains that, to be sound, policies must be justified. The evidence will play an important role in ensuring that this is the case and that the local planning framework is sound.
The evidence base requirements for each of the documents in the Local Development Scheme are set out in the detailed programmes. Once a piece of evidence is completed, it is published on the Council’s website for inspection.

MEMORANDUM OF UNDERSTANDING FOR STRATEGIC PLANNING IN SOUTH ESSEX.
CPBC will, in its response letter to the SOS, as to why intervention is not required in the formulation of its Local Plan, suggest that considerable weight be given to the fact that CPBC partakes within the protocol of the MEMORANDUM OF UNDERSTANDING FOR STRATEGIC PLANNING IN SOUTH ESSEX ( MoU)
This despite declaring that its Local Development Scheme 2017 will not come to fruition until late 2019. This in the hope that other neighbouring Authorities may take some of its housing needs.
The National Planning Policy Framework encourages authorities to prepare joint, non-statutory documents, particularly where this provides evidence of having effectively cooperated to plan for issues with cross boundary impacts.

Whilst the Duty to Co-operate is not a duty to agree, local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before they submit their Local Plans for examination. Compliance with the Duty to Cooperate will need to be demonstrated at examination, prior to assessment of compliance with the tests of soundness.

The legal requirement of the Duty to Co-operate is noted as being separate from, but related to the Local Plan, Tests of Soundness.

In keeping with the principles of localism, this MoU respects the principle of the individual local development plan-making functions of the South Essex local authorities. Therefore, it will not seek to determine the locations for development within local authority administrative areas.

Furthermore, it will not seek to include prescriptive or directive policies which would limit the ability of the individual local authorities to meet their development needs in a locally appropriate manner.