Tag Archives: CPBC

Persimmon Homes Refused Permission for Change of Use of Land, and to Build on Canvey Island Green Belt!

Persimmon Homes have again been Refused Planning Permission for a Change of Use of Land and the Erection of a Stable Block on Canvey Island Green Belt, to the rear of the Dutch Village Estate, the Cornfields.

This latest attempt follows a previous Application, also Refused. It is seen to be an attempt to establish a Built Development on Green Belt land, ahead of the CPBC Local Plan!

Despite CPBC Planning Officers giving Scant regard to Residents objections;

“The site is private land, the only public access is a footpath which runs along the southern edge of the land. Any use of the site for recreational purposes is unauthorised.

o Access for fire engines is not a planning matter

o It is noted that some objectors are concerned for the Roman Saltern (ancient monument) on adjoining land if it is used for grazing or turning out horses, but the application site does not include the land containing the Saltern, this would need to be the subject of further planning permission

o The highway authority has been consulted on the proposed development and has raised no objections on the ground of traffic safety. The conditions requested by the highway authority would be imposed on any permission granted where reasonable and necessary

o Any other relevant planning matters are discussed in the evaluation of the proposal”

….was all CPBC officer’s had to say in response.

The CPBC Case Officer Concluded;

“My Recommendation is Refusal for the following reasons”

 1 The proposed development is situated within an area of Green Belt as defined in the Council’s Adopted Local Plan where inappropriate development is only permitted in very special circumstances. The proposal, by reason of the provision of a new building and area of hardstanding, would not preserve the openness of the Green Belt and is therefore considered to constitute inappropriate development. No very special circumstances to outweigh the harm to the Green Belt by reason of inappropriateness, and any other harm, have been demonstrated and the proposed development is therefore contrary to government guidance as set out in the National Planning Policy Framework.  

2 The proposal seeks to provide a stable facility within Flood Zone 3, an area identified at risk of flooding. There are considered to be sequentially preferable sites available for the proposed development in areas with a lower probability of flooding, and the proposal does not meet the requirements of the sequential test. The proposal is therefore contrary to government guidance contained within the National Planning Policy Framework and Planning Practice Guidance.”

Canvey Island Town Council’s, local Residents’, and the Canvey Green Belt Campaign’s 7 Page objection, as well as the Environment Agency’s response, are hidden from Public View on the Castle Point Borough Council’s Planning Portal!

However, The full Planning Officer Report can be found HERE. �

Riding Roughshod through Planning Policy

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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!

Residents of Canvey Island left to Face the Risks, whilst Castle Point Council, Fail to Develop an Adequate, operable Emergency Plan!

38,459+ Residents living on Canvey Island, seemingly oblivious to the everyday Risks and potential Harm facing them!

Whether the Risk is Tidal from the Estuary, Surface Water flooding or from the Hazardous Industries on the Island, a suitable Emergency Plan involving the Residents is essential.

The old Adage “we are safe from the Sea” is bunkum, as Castle Point Borough Council’s own evidence Highlights!   

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

• The need for an emergency plan to be in place;

• The need for sea defences to be maintained and improved;

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

• The need for existing homes to be made more flood resilient, and include areas where people can remain safe in the event of a flood;

• The need for new development to incorporate design elements that make them safe in the event of a flood for occupiers;

• The need for building techniques to be used that enable easy restoration in the event of a flood.” (1)

Further CPBC Local Plan Evidence Documentation enforces the issues;

10.4 Tidal and fluvial flooding poses the most significant flood risk to the Castle Point Borough, in particular Canvey Island and Hadleigh Marshes. The topography and location of watercourses on Canvey Island means that the whole island is at risk from tidal and fluvial flooding. Although much of the Island is protected by the presence of defences, the island is still at residual risk of flooding if the defences were to fail or to be overtopped.

10.5 In the event that a breach in the existing flood defences was to occur, or a failure of one of the existing flood barriers (residual risk), significant depths of floodwater would be experienced on Canvey Island and the southern portion of the mainland.  Given the low lying nature of these parts of the Borough, floodwaters would propagate rapidly across Canvey Island thereby reducing the time for warning and evacuation of residents. (2)

During the Local Plan Intervention fiasco, CPBC informed the Secretary of State of particular physical circumstances of the Borough, considered to be legitimate constraints as to why the Authority could not provide for its Housing Development Needs.

“Of the urban areas of the Borough, Canvey Island, with approximately half of the Borough’s population, is defined by the Environment Agency as Flood Risk Zone 3a, being at or below sea level.

Further land is likely to be required on Canvey Island by the Environment Agency for improvement to existing sea defences in the lifetime of a Local Plan, further restricting opportunity for development

The Health & Safety Executive require significant exclusion areas to be maintained by the Local Planning authority around two top-tier COMAH sites on Canvey Island’s Thames Estuary frontage”, (3)

Direct Recommendations detailed within the CPBC Strategic Flood Risk Assessment state:

“The majority of the sites will rely on the provision of adequate emergency planning measures to mitigate the residual risk of tidal flooding in the event of a breach in the tidal flood defences.

It is therefore strongly recommended that the suitability of locating more residential accommodation on Canvey Island and the capacity of the existing egress routes off the island is further discussed with the Emergency Planning Team at Castle Point Borough Council and/or Essex County Council prior to site allocation” (4)

Remarkably, CPBCs Development Control Committee has taken responsibility, (having only aspirational resolutions for the various preventative requirements), for successfully seeing-through Housing developments at Canvey Island since January 2012.

In doing so exposing an increased number of residential and commercial population to Residual and/or Actual Societal Risks.

Emergency Plans supporting increased development on Canvey Island are seemingly only “Generic”, where by dealing with a wide range of possible scenarios such as for example Influenza Pandemics, with no “Specific Plans” that relate to a particular emergency.

Specific Plans are a detailed set of arrangements designed to go beyond the generic arrangements, when the latter are likely to prove insufficient in particular cases such as breaching of flood defences or total LPG tank failure. (5)

It would appear that CPBC have not considered the value of Specific Planning in relation to Canvey Island, if they have, they have not included the involvement of the community in the production of specific planning for viable emergency incidents.

Editor, I will leave the reader with an opportunity to provide a Rationale as to how our local authority, Castle Point Borough Council has managed “Residual Risks” via its Local Planning strategy.

Document References

  1. The CPBC Sustainability Appraisal and Strategic Environmental Assessment Scoping Report, New Local Plan January 2012
  2. Castle Point Borough Council New Local Plan 2018 Technical Evidence: Summary Document June 2018
  3. CPBC Response letter to Sajid Javid 31st Jan 2018, regarding why Government Intervention in the Local Plan process was unnecessary.
  4. Revised Castle Point 2018 Strategic Flood Risk Assessment
  5. Chapter 5 Cabinet Office Revised Emergency Preparedness. Definitions of “Generic” and “Specific” Emergency Planning.

The Big Stick raised to Fall across Castle Point Council’s Knuckles! Government yet to send Letter, as the Wirral and Thanet hear their Local Plan Bad News!

Castle Point Council are now the sole Council awaiting the Government response to their “protracted” efforts towards producing a Local Plan.

Back in March 2018 CPBC were one of just 3 Local Authorities singled out for criticism at the lack of response and effort towards forwarding Local Plans amongst the 15 most feet dragging authorities threatened by the then Housing Minister.

In letters dated 28th January 2019 the Wirral and Thanet Councils have received further instruction on what is now required towards producing their Local Plan. Basically a streamlined group, consisting of a designated lead councillor and lead official, will be charged with responsibility of progressing their Local Plans.

No word as yet of Castle Point Council’s Fate!

In his letter to the Wirral Council, the Secretary of State, JAMES BROKENSHIRE wrote; “We note that in the Wirral’s case the Housing Minister points out “at least two communities in Wirral are currently preparing neighbourhood plans: Leastowe and Birkenhead North. Two further communities have neighbourhood plans in force: Devonshire Park and Hoylake. Communities can bring forward neighbourhood plans in the absence of an up-to-date Local Plan, but doing so can be more challenging for communities.””

Previously Housing Secretary SAJID JAVID had stated; “The government has abolished top-down regional planning. But a locally-led planning system requires elected local representatives to take the lead, listen to local residents and business, and set out a clear framework to build new homes, provide key infrastructure, support the local economy and protect the environment.”

The Canvey Green Belt Campaign group maintains the opinion that Canvey Island, as a whole, would have been better represented if we had made efforts to, at least, commence a Neighbourhood Plan.

This is no less relevant, now that we learn that within the next stages of a CPBC Local Plan, we will be represented by a Lead Councillor more likely to propose inappropriate development on Canvey Island.

A Canvey Island Neighbourhood Plan would have been a vehicle to illustrate the issues facing Canvey Island, in the process to produce a fair Castle Point Local Plan.

Instead we will likely be represented by a Lead Councillor supportive of the rejected 2018 Local Plan, and all of the Development that document proposed to deliver on Green Belt on the Flood Zone and away from politically sensitive areas!

Sources inform us that no Local Plan work is on-going at CPBC, they appear to sitting like ducks in the water, oblivious to the shotgun about to be fired at them!

Admittedly it is strange that of the 3 councils in most serious trouble with the Secretary of State, only CPBC have yet to receive a letter. Either way none of the councillors are feeding any information nor CPBC making comment as to Local Plan progress.

Councillors and officers have a responsibility to the Residents but show little regard as to keeping them informed.

We are likely to pay a heavy price for CPBC’s ineptitude!

We thank our friends at Basildon Residents Against Inappropriate Development for alerting us to the issuing of the Government letters to the Wirral and Thanet Councils, shame our local Echo isn’t more challenging where CPBC is concerned.

The Letters issued to the Wirral and Thanet can be found via this LINK.

Paddocks Community Centre Keys set to be Handed over to U3A, Charity Foundation to Cough Up for the rebuild, CPBC gain extra Housing and Everybody Happy?

The Paddocks community centre, Canvey Island. Soon to be destined to the History Books, alongside many Canvey Island Landmarks.

It would not be unreasonable to surmise on the future of Canvey Island’s, Paddocks Community Centre.

 “No Plan for the Paddocks“, claim Castle Point Council, well, here is a simple one for Free!
Hand Over the Paddocks Community Centre to the University of the 3rd Age (U3A)!

It may appear that U3A, for some reason are receiving preferential treatment.

Despite CPBC insisting that there is no plan for the Paddocks, nor for Development of the site, it appears that we Canvey Simple Folk, may well have been Played!

All of the Clues, are Written in Between the Lines, just not necessarily in the Right Order! The Canvey University of the 3rd Age group (U3A) have been “addressed” twice by the CPBC councillors over the future of the Paddocks Community Hall. Whereas other Paddocks user groups, such as the slimming group have only received invite to join in the Consultation process, as all Canvey Residents have been invited to do!

There are also such agencies and organisations, as the Trusthouse Charitable Foundation* and the Charity Commission**.

Canvey Residents should be asking themselves why would CPBC be getting so cosy with the U3A folk, if not to explore, if they would be willing to become the Trustees of the New Paddocks Hall!

Well, we should remember that the U3A is a Registered Charity!

The Trusthouse Charitable Foundation, is interested in applications for capital projects at community centres in the most deprived urban areas

Castle Point is recorded as “There are 57 Lower Super Output Areas (LSOAs) in Castle Point, with one of them being amongst the most deprived 10% in England and another four that are in the bottom 20%.***

Canvey Island is included as having specific areas amongst these lower levels. The Castle Point and Rochford Health Care Trust, prepared a cost saving document and referred to a preferred closure of the Long Road NHS facility housed in the old Canvey Island Urban District Council building. In which they stated “As detailed above it can be concluded that there are issues within the Canvey area which can be summarised as follows;
*Increasing elderly population living in their own homes *High levels of deprivation

These Canvey Island pockets of deprivation may well be adequate to qualify for charitable Financial Assistance towards the development of a New Paddocks Community Hall facility.  

CPBC have history, where selling off of assets are concerned, Richmond Hall, Tewkes Creek Pavilion, Small Gains Hall and Hadleigh Hall are examples.

With the Paddocks Net Operational Cost of £110,000 expected to rise in the short term to £165,000 per Annum you can see why CPBC are keen to get the Paddocks Community Hall off their Hands!

Handing this, not so old, Canvey Urban District Council Community Hall over to the U3A for just a Token Sum would offer CPBC a “Get Out” ticket!

With the costs of a New Community Centre estimated, by CPBC, at £4,300,000 it may be doubtful whether on-Site Housing Development would realise profits that would enable the developer to provide a New facility.

However if the Paddocks site was gifted to the U3A, they could sell off a large part of the site to a CPBC “approved” developer.                         Castle Point Borough Council, Local Plan Housing Supply, would then be boosted with however many dwellings could be squeezed onto the site, there would be some funding accrued towards “Affordable Housing”, and U3A could apply for Charitable funding for any shortfall towards development of THEIR New Community Hall.

Part of the Charity Commissions service to charities is that it is able to, “Help charities with the disposal of Land and permanent endowment”*

Does this extract below from the Charity Commission’s Report sound in anyway familiar?

“Trustees of a village hall charity contacted the Charity Commission for advice after the building became unsafe and needed to be demolished. The building had been well used in the past although there were limitations on the activities and services it could offer because of its age and state of repair. The trustees proposed to rebuild on an alternative site and use the proceeds of the sale of the original site to enable them to establish a hall with improved facilities to increase the range of activities it could hold, such as the provision of IT facilities. The trustees sent out a questionnaire to determine what kind of facilities the community wanted. We advised that the disposal and changes were in accordance with the charity’s governing document, allowing the trustees to proceed without any further intervention from the Charity Commission.”***

All conjecture by ourselves of course, and no doubt the agencies and organisations may differ. But it cannot be denied that some “below the table moves” are afoot!

* http://trusthousecharitablefoundation.org.uk/grants/community-centres-and-village-halls/

** https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/284719/rs9text.pdf

***Essex Local Authority Portraits A product of the Essex Joint Strategic Needs Assessment (JSNA) May 2016

Pantomime at Canvey Island! CPBC “under no obligation to provide a new Paddocks Community Hall” Consultation Castration!

The Simple Folk of Canvey Island could be forgiven for thinking that the Pantomime Season has arrived late. The Paddocks Consultation Road show‘s first session was conducted at Canvey Library, despite the CPBC cabinet suggesting that Canvey Councillors would be on hand to “inform” the residents of the future plans for the building, just 1 Canvey ward representative was present alongside 2 mainland ward reps. Nevertheless the information available to the Public merely prompted even more questions and concerns.

Paddocks Consultation Event. Photograph credit: “Tell the Councillors” Facebook page.

The CPBC website states

“Castle Point Council has recently decided to provide a brand new Community venue to replace the existing old and out-dated one on Canvey Island.” However the councillors present at the Library event were keen to point out that “we”( the Local Authority) were under no obligation to provide a new Community Hall nor even maintain the existing Hall.

This fact was confirmed by CPBC Cabinet within; Cabinet Agenda Oct 2018

“Community and leisure facilities, whilst important to residents are discretionary functions for a local authority.  Except in cases where a discretionary function makes a positive financial contribution most authorities are endeavouring to scale down or discontinue these services entirely.  

In order to safeguard any new facility at the Paddocks from threat of discontinuation at a later date, it is desirable that the facility is self-sufficient.  It would be illogical for the Council to take a decision now to provide a new facility which would result in an increased financial burden in years to come.”

Apparently the Simple Folk of Canvey should be grateful that CPBC, are even considering the possibility of re-building the Paddocks.

On face value this implies that the Paddocks site is for CPBC to do with whatever they wish! Once again they continued to insist that there were no plans for a new Hall, nor any Housing Development. We assume they mean Plans, as in Development Plans, rather than plans, in the strictest sense.

The attending councillors were even suggesting that a new build Hall may even have funding sourced from CPBC’s own funds. We heard cllr C.Maclean state that “we can deliver a Hall” during the October 2018 cabinet meeting

This is in direct contradiction to the CPBC Finance officer who considered that; “the financial forecast currently indicates an unbalanced budget from 2019/20 meaning that the Council would need to rely on the use of reserves in order to maintain services until the budget is balanced.  Any new / additional revenue commitments would further impact on the Council’s ability to set a balanced budget in future years.”

Given this financial context, it is essential that the Council ensure that every opportunity to reduce ongoing costs is explored.  The options explored within this report would have a positive impact on the Council’s financial plans.

“Community and leisure facilities, whilst important to residents are discretionary functions for a local authority.  Except in cases where a discretionary function makes a positive financial contribution most authorities are endeavouring to scale down or discontinue these services entirely.”

So, it would be reasonable to expect that funding for a new “Paddocks” Community Hall, would need to be sourced by releasing assets. The most likely is to release part of the Paddocks Site for Housing / Flatted development. Why CPBC are so reluctant to admit this we can only guess, maybe due to May fast approaching perhaps!

The contents of the Consultation Questionairre, appears to follow the form of a Residents wish list. This can be countered by CPBC by the apparent lack of the current Halls levels of usage, which are low! Given the financial constraints, the “wish list” will be weighted down, by there being no guarantees that a New Hall’s facilities would suddenly become supported by the public!

Despite the fact that “hire charges for the Paddocks are relatively inexpensive.” “the Main Hall (largest hall) has an occupancy level of 18% and generates 31% of overall income.”*

Whilst “4.4 The key driver for the business case was to identify a financially sustainable option which meets the needs of the community.”**

The 18% occupancy levels could be used to indicate that a New Community Hall of, say, 30% of the size of the current Paddocks Community Hall would be sufficient!

A Consultation attendee commented; “What was evident is that most people taking part in the consultation were unaware that the new build was CPBC approved option following the outcome of the business case study. When asked about the funding for the New Hall It was strongly emphasised that there were no plans to develop the site in order to finance the new build, however the statement that other option were that funding could come from Government Grants and Council reserves brought the consultation process down to a discreditable level”

And as a point of clarity to one particular Canvey ward councillor and member of the Development Committee , present at the Library – Paddocks Consultation event, we would point out that; “There is always potential, whilst unlikely, for the sea wall to be damaged in extreme storm weather and tidal conditions which could lead to coastal flooding.”

However relevant to a new Paddocks Community Hall, and as typically stated by the CPBC professional Planning Case Officers, the current requirements for development on Canvey Island require Safe Refuge in the case of Tidal Flooding; “The ground floor level of the property is therefore liable to flooding under such circumstances, however the first floor would remain dry and offer a place of refuge from flooding. “

The mainland ward representative / Development Comm member, must surely have been mistaken when he feigned surprise at being unaware that a New Canvey Paddocks Community Hall would NOT be granted Planning Permission without a First Floor Safe Refuge!  Adding to the build cost of course.

Caught between a rock and a Hard Place, Canvey Residents must consider what participation in the Paddocks Consultation could mean. A low response would be taken to indicate, little need for a new Community Hall. Equally, little enthusiasm would indicate a potentially little used facility meaning a much smaller Hall being required.

Either way, and depending on what Developers consider to be Viable, the % of Residents Responding and the enthusiasm of the responses, will have bearing on whether a new Community Hall is delivered at all, and of what size.

*,  ** October 2018 Cabinet Agenda

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!