Tag Archives: CPBC

Thorney Bay, change of Use Over-Heard on the Canvey Grapevine! CPBC Local Plan issues?

It started as a Whisper, became a Rumour and has now reached Conjecture level on the Canvey Grapevine!

Thorney Bay, the apparent answer to the Castle Point Council’s Local Plan dreams, has become the subject of unconfirmed speculation. With the humiliating Withdrawal of the cpbc Core Strategy in 2011, it was considered “timely” by cpbc officers that Thorney Bay, despite it being sited within the Hazard range of Calor Gas and within a 3A Flood Zone, should come forward to provide a Housing Development of some 600 dwellings plus sheltered accommodation.

Thorney Bay then became the Backbone, the largest single development site, of Castle Point council’s daft Local Plan and surviving the GB sites cull to remain as the spine of the Local Plan2016, 5 year Housing Supply!

The Thorney Bay proposal passed in Principle by the cpbc development committee, whilst in the following months / years a 1st Phase proposal has gained Health and Safety Executive’s permission and is apparently overcoming the Flooding Objections to the fundamental requirements of the Environment Agency and the ecc Lead Local Flood Authority.

Now then; Listen very carefully, I shall say this only once!

A little Bird has told me, and I must say there is little foundation, so to speak, for this to be considered information, but it could be that the development may not be going much further!

To me this would not be a surprise, I would have thought a more likely idea would be for the developer to follow the Kings Park, and remove the static caravans and replace with Park Homes.

The build cost would be far less, the speed of development would be probably twice as quick and success of the venture equally, if not more so, financially successful as Kings Park!

What’s to lose?

Park Homes and Luxury Lodges can easily reach an asking price of £300,000, the site is opposite Thorney Bay Road, and residents would likely be of an age not too concerned with, the daily commute.

Now that the Canvey Bay Watch team have created such an attractive area of the promenade and beach front, this forms another selling point for potential Park Home buyers. I would have thought that the Canvey Bay Watch team should soon be knocking on the site owner’s door for financial support, should this development rumour come to fruition!

Thorney Bay 1

Photograph courtesy: Dave Harvey

The question for cpbc is whether these Park Homes should count towards the official Housing Supply.

On one hand these Park Homes “are suitable for residential use throughout the year and are built to last at least 50 years”! (Omar park and leisure homes). Although whether 50 years lifespan is considered permanent is challengeable, however, their success is, and there are people desiring to own them.

The Planning Inspector examining the Glebelands, Thundersley, Appeal did not consider the numbers at Kings Park should qualify for inclusion in building numbers, but that may have been due to cpbc being unable to clarify how many caravans were replaced by Park Homes.

We do know that of the caravans at Thorney Bay the Inspector concluded;

“But that does not necessarily mean that the Households now occupying caravans would have chosen that type of accommodation, in preference to bricks and mortar.”

Well, “bricks and mortar” these Park Homes ain’t! But the appeal of Park Home life is generally popular across the UK, so if people are choosing to buy into this type of accommodation, then there is an argument for these dwellings to be included into the Canvey Island Housing Supply count.

With our “Broken Housing Market” leading to the apparent need to revisit Pre-Fabricated Housing, these Park Homes may well have some scope.

Whether or not any Affordable Home supply can be squeezed into the equation will be upto the negotiating abilities of cpbc, so we won’t hold our breath on that one!

What could be expected is for some Canvey Island “bricks and mortar” dwellings to become available, for local young families hoping to get on the property ladder, as older Canvey residents move into the Park Homes.

It may be doubtful , should the development come into fruition, whether the Housing Need in the mainland part of the Borough be part satisfied, as it will be difficult to argue that this type of dwelling satisfies the cross market “bricks and mortar” Housing Need. In fact it probably increases the pressure on mainland site supply.

I remind you this is only speculation.

As a reference, below, I include part of the text of the cpbc Report on Residential use of Caravan and Park Home Sites 2013.

“It is clear from both Census data and from Council Tax data that an increase in the availability of caravans for residential use resulted in an increased housing supply of the order of 800 homes in Castle Point in the period from 2001 to 2011. This increase was largely as a result of the change of use of Kings Park and Thorney Bay Caravan Parks from holiday use to residential use.”

“To date, the Council has only included those caravans registering for Council Tax at Kings Park within the housing figures for the period 2001 to 2011. However, given that caravans at Thorney Bay were included as homes within the Census 2011 outcomes, and this will be reflected in population and household data moving forward, it is appropriate that the housing supply figures for the period 2001 to 2011 are appropriately adjusted to include these homes also.”

“The change of use of static caravans from holiday accommodation to residential accommodation has made a significant contribution to housing provision over the last decade (2001 to 2011). Approximately, 800 additional caravans moved into permanent residential use over this time period, primarily on the Kings Park and Thorney Bay sites. This is supported by evidence from the Census and from Council Tax records.”

“However, whilst some of this provision has contributed positively towards the community, in particular at Kings Park, the nature of the provision at Thorney Bay has had negative socioeconomic consequences both for the surrounding community and for the vulnerable families who have found themselves living at the site.”

“Due to these issues there is support for proposals to redevelop a significant proportion of the site for traditional homes. However, it is the intention of the owner to retain a smaller caravan park of 300 caravans for residential use towards the west of the existing site.”

“Assuming that the proposals to redevelop this site as proposed for traditional housing are delivered in full over the next 10 years, then it is unlikely that the number of households living in caravans in Castle Point will increase further between 2011 and 2021. Indeed, as a result of the development of traditional housing over this period, it is expected that the proportion of households living in caravans will reduce.”

“However, should the Thorney Bay site not be redeveloped as proposed, then there is the potential for a further 800 caravans moving from transient use into permanent residential use. This will increase further the number of households living in caravans, and the associated socio-economic issues arising from this. It is therefore imperative that the Council work alongside the site owners to encourage and facilitate the redevelopment of this site in an appropriate timeframe.”

Video copyright BBC

Canvey Island Flood Risks – brought to Parliament!

“Planning conditions can be flouted, and they are sometimes not properly enforced.”

Parliament debated “FUTURE FLOOD PREVENTION” and further resources totalling £582,310,000 in the House of Commons on the 27th February.

envagencyanglia-1

EnvAgencyAnglia photo

Photograph courtesy; Environment Agency Anglia; Canvey Island February 2017

Neil Parish opened the debate and mentioned, “One problem is that, if we are not careful, people living in an area with a “one in 100 years” risk which is flooded are inclined to think that they will be safe from floods for another 99 years. Of course, that is not the case. An area with a high flood risk will continue to have that risk until better defences are created or resilience measures are introduced, and it will probably always be a pretty high-risk area.”

His reference to “1 in 100 years risk”, and peoples understanding of it, indicates how slowly changes are put in place. This was one of the recommendations following the Report and Review into the Canvey Island Flooding of 2014, that a more straight forward and easier description of flood risk was brought into use!

“The report states that firefighters provide a vital “first-line service” to flooded areas”

Strange then that they were discontinued as statutory consultees in the planning process locally, after continually stating they were only able to guarantee a response during a life or death situation due to a lack of resources. It is hard to imagine, following the fire and rescue service cut backs of late, that they are better placed now to become a fully effective “first-line service”!

Castle Point MP Rebecca Harris participated in the debate. However some of what she said appeared to expand the theory, long spun amongst residents, that our defences are impenetrable. Our sea defences do not compare with the Netherlands and are indeed liable to over-topping in parts under certain conditions (cpbc SFRA 2010).

Although Canvey Island is defended to a high standard of protection, it is at risk should there be a flood defence failure. This residual flood risk should be considered, as although the likelihood of it (flood defence failure) occurring is low, the consequences should it happen would be very high.

Referring to the evacuation of Jaywick, whilst Canvey Island residents were considered safe, suggests that an evacuation of Canvey Island was possible. The potential time required, upto 19+ hours, would make this unlikely, and in the event of a Breach, impossible.

One thing that requires clarity is, given the extraordinary amount of work already carried out across Canvey Island, whether the request to Government for £24,500,000 required to repair our broken drainage system still stands. All appears to have become silent following cpbc representatives being told to return with specific details of work necessary and estimates of costings to evidence the sums requested.

Nevertheless to have our MP stand in Parliament to put forward the issues of the Flood Risks to Canvey Island, and the level of work needed to simply maintain the drainage system, can be no bad thing.

Rebecca Harris, Castle Point

“The financing of flood defences is of absolutely paramount importance to my constituents, as my borough has been hit by flooding on a number of occasions, most notoriously the devastating North sea flood of 1953, which breached the old Canvey Island sea wall defences and caused the loss of life of 58 residents and the evacuation of the entire remaining population. To avert a similar catastrophe, the island is now protected by a concrete wall that runs along its entire 28 km to protect the population of 40,000 from tidal surges. This wall is still judged to be good for a one-in-1,000-years event. I note that the residents of Canvey Island were not encouraged to evacuate because of a threatened tidal surge when those of Jaywick were. The wall is judged to be sound right up until the end of this century provided that there is regular monitoring and maintenance. The concern of my residents is to ensure that the money is always there to make sure that we are upgrading the maintenance.

Notwithstanding how good the sea walls are, Canvey Island and other parts of my borough, including South Benfleet and Hadleigh, still remain subject to a serious risk of surface water flooding, as occurred dramatically in the summer of 2013 and again in 2014, when homes right across the borough were flooded, including 1,000 homes on the island alone. Despite the great sea defences, this is a serious problem for an island that remains 1 metre below sea level at high tide and is entirely flat. It presents a particular problem for effective surface water drainage. There was an absolute outcry in 2014 at the second significant flooding event in less than 11 months. That led to calls for an investigation into whether this could be dismissed as a mere act of God or whether much more serious defects in the water management system were at fault, and what measures were needed to be put in place to assure residents that it would not occur again. I was extremely grateful to the then Cabinet Office Ministers and Secretary of State for Environment, Food and Rural Affairs, who agreed to an investigation by the Government chief scientist, Sir Mark Walport, to establish the facts and make recommendations for the various agencies locally. His report found that the coincidence of extreme rainfall, problems with the performance of the drainage system, a power cut, and pumps overheating and tripping out were all foreseeable, although unusual, and many could be avoided in future. Sir Mark made a number of recommendations, the majority of which, I am pleased to say, have already been acted on.

Since those last floods, an extraordinary amount of work has taken place right across Castle Point, with considerable amounts of money spent on improvements and mitigation measures. The Environment Agency has invested large sums in improvements to its eight sluices and 13 pumping stations. In this financial year alone, it has invested over £500,000, including £89,000 on the Benfleet and East Haven barriers, which are key to protecting South Benfleet as well as the island. Webcams have been installed to monitor pumps and ditches. Some £620,000 has been spent on refurbishing 28 floodgates, and the remaining six will be completed by the end of this year.

The county council and Anglian Water have worked hard to map the drainage network underground and to make thousands of repairs and remove blockages in the system, as well as identifying the most serious faults. Anglian Water has invested millions since 2014 and has also been highly proactive in a public awareness campaign locally to raise the critical importance of maintaining free-flowing water courses. The county council is undertaking a huge rolling programme of property-level protection, with grants of up to £5,000 for homes affected by flooding previously.

The improved partnership working of Essex County Council, Anglian Water, the Environment Agency and the Essex fire and rescue service, as recommended by the chief scientist, is exemplary and has even resulted in a national award. Although the investigation focused on the island, improvements in multi-agency co-operation have had real benefits for the entire borough and it is now an exemplar for the rest of the UK.

The partnership has concluded a comprehensive urban drainage study of the problems underground and to model any future problems, to help make sure that this does not happen to my borough again. Proposals include the creation of additional storage ditches on roadsides and open areas, green roofs, water butts, porous paving and increased pipe sizes. It will shortly submit bids for some of those projects to the South East local enterprise partnership and central Government.

Previously, DEFRA Ministers have supported our bids. I hope that the Government will continue that support, acknowledge the economic importance of those bids and stress, not only to my LEP but to others, the importance of flood alleviation schemes in ensuring that communities remain economically viable. It is absolutely essential for the continued economic regeneration of my borough that it is recognised as protected from non-tidal surface water, as well as from tidal flood risk, especially given the increased likelihood of future events.

My borough is grateful for the introduction of the Flood Re scheme, which means that residents are not priced out of insuring their homes. It is not, however, available to businesses in my area. I hope that more work can be done in that regard, because a lot of them suffer great hardship. Nor does the scheme apply to new builds. I urge the Government to do more to ensure that there is better defence of our floodplains from developers and to press planning departments to incorporate more surface water mitigation for developments. Perhaps they could even reverse developers’ current right to connect surface water to the sewerage system, as it does not incentivise them to consider sustainable drainage systems.

I am conscious that time is short, so I will end by encouraging the Minister to visit Castle Point, if she can find the time in her diary, to see the incredible work that has been done in Benfleet and on Canvey Island, and to meet local agencies to discuss what more is needed and how we can further help the borough.”

Hansard’s record of the full debate can be reached HERE.

 

Duty to Cooperate sabotage? CPBC Local Plan2016 left up **** Creek without a Paddle?

With an admittance of having little knowledge of the Local Plan process, we fear that the Castle Point Local Plan2016 may have already come across some major difficulties.

One of the very first stages pre-examination is for the local authority to gather and submit evidence on how they have attempted to cooperate with neighbouring authorities.

“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.

Local planning authorities must demonstrate how they have complied with the duty at the independent examination of their Local Plans. If a local planning authority cannot demonstrate that it has complied with the duty then the Local Plan will not be able to proceed further in examination.”

It appeared apparent to us, during the Local Plan Task and Finish group meetings that little evidence of cross local authority cooperation work had been published.

Now we learn of the Planning Inspector’s letter to cpbc, expressing an opportunity for cpbc to offer an explanation on the missing gaps in the required work.

It appears to us that the letter underlines the chasm between the level of commitment to the Local Plan2016 between officers and members.

At the recent Council meeting the council leader made light of the issues, but unless a united effort is made by officers and lead group members, the Local Plan2016 may have hit stormy waters less than one calendar month after it being submitted to the Planning Inspectorate!

The Inspector wrote on 22nd September;

1. As an initial matter the PPG makes reference to the submission of robust evidence by authorities of the efforts they have made to co-operate on strategic cross boundary matters (ID 9-012-20140306).  This should include details about who the authority has co-operated with, the nature and timing of co-operation and how it has influenced the plan.  Whilst some information is given at Section 4 of the DtC Report precise details are scanty.  Future work through the South Essex Strategic Members Group and the completion of a written Strategic Planning Framework appear to be broadly in line with co-operation principles but clearly have no bearing on the preparation of the New Local Plan.  In responding subsequently I therefore request that the Council provides specific detail of actions taken to seek the co-operation of key partners in relation to the preparation of the New Local Plan.

2. Section 4 of the DtC Report indicates that officers have come together since mid-2014 to consider strategic planning issues affecting South Essex.  Prior to that was there any constructive, active and on-going joint working linked to the preparation of the New Local Plan?  If so, what form did it take?

3. Section 4 also includes a list of cross-boundary planning issues.  Compared to the topics identified in Appendix 1 communications infrastructure is omitted.  Having regard to paragraph 156 of the NPPF and the PPG (ID 9-013-20140306) could the Council confirm the full list of strategic matters that, in its view, fall within the definition in Section 33A?  Having done so it would be helpful to have a short resume of the steps taken to meet the DtC and to deal with questions 6, 7 and 8 in respect of each of these matters.

4. The PPG refers to the important role of Councillors in the DtC process (ID 9-0003 & 004-20140306).  To what extent have Councillors been directly involved in any specific DtC activities?

5. Has the Council considered any more formal arrangements in terms of joint working on plan preparation as set out in the PPG (ID 9-01620140306) and as required by Section 33A(6) of the 2004 Act?  If so, why have any such approaches including the use of formal agreements not come to fruition?

6. How have any DtC actions maximised the effectiveness of plan preparation?

7. How have any DtC actions influenced the preparation of the New Local Plan and what have been the outcomes?

8. What solutions have emerged to achieve effective strategic planning policies?

9. Regulation 34(6) requires details of action taken in co-operating with other bodies under Section 33A to be given in a monitoring report.  Have any such details been provided in monitoring reports throughout the plan preparation period?
Housing

10. Paragraph 13.22 of the New Local Plan recognises that the housing target of 2,000 new homes by 2031 does not represent objectively assessed need but reflects the capacity of the Borough to accommodate growth.  Paragraph 179 of the NPPF indicates that joint working should enable local planning authorities to work together to meet development requirements which cannot be wholly met within their own areas.  In the light of the strategy proposed for Castle Point what specific steps have been taken or mechanisms are in place to distribute unmet housing need elsewhere in the Housing Market Area (HMA) or beyond?

11. What is the rationale for reducing the housing requirement from 4,000 in the Draft Local Plan to 2,000 in Policy H1 as referred on p12 of the Consultation Statement (CP/05/013)?

12. When were neighbouring authorities within the HMA made aware of the Council’s intention not to meet its full objectively assessed needs and of the reduction referred to above?

13. Has the Council considered whether it should meet any unmet housing requirements from neighbouring authorities?

 

Sabotage? Green Belt under attack as Developers and Neighbouring Authorities criticise CPBC Local Plan!

Castle Point Council’s Local Plan2016, read by an outsider or even a Planning Inspector in conjunction with the daft New local Plan (2014 version), may be considered to have identified almost ALL of Castle Point’s Green Belt and green field land as being available for both Housing, and in the case of Canvey Island, Industrial Development as well!

local plan.jpg-pwrt3

It is not unusual to expect developers to attack the Castle Point Local Plan 2016, as they have attacked each previous version.

Developers Consultation submission comments / criticisms include:

The New Local Plan concludes that “The draft Local Plan is generally sustainable”, that “It is therefore appropriate to move forward with the plan-making process on the basis of this plan” and that draft Policy H1 (Housing Policy) “strikes an appropriate balance between the different sustainability objectives.”
However, the SA/SEA has not been amended since 2014 which in respect of the Draft New Local Plan (2014) that the then proposed Policy H1 that:
“The draft policy makes provision for 200 homes per annum, which is less than objectively assessed need, and based on the capacity of the borough to accommodate growth having undertaken a Green Belt Review.  Harm to the strategic purpose of the Green Belt is therefore avoided. The level of growth required by this approach will not entirely avoid harm to biodiversity and the risk of flooding; however there was sufficient capacity to accommodate mitigation at this level of growth. Harm to important areas of landscape value is however avoided through this approach.” (para 3.6.3).
The Sustainability Assessment of the current NLP (2016) now concludes that:
“When these changes to the draft policies are compared to those proposals originally prepared (the recommended policies) there has been a negative impact on the sustainability of the plan. The reduction of housing sites will result in insufficient capacity to address housing needs”.
And that:
“Overall, the draft New Local Plan 2016 has become less sustainable as a result of these changes, and it is recommended that the submission New Local Plan 2016 is amended to reflect these sustainability concerns.”

This is not consistent with the NPPF which seeks to significantly boost Housing supply and ensure that housing needs are met in full (para 47). Furthermore, the Members approach to protecting Green Belt is a false statement as the GBBR (Green Belt Review)(2013) Evidence Base sets out a robust and strong case for areas of Green Belt release that were supported by the Council in the DNLP consultation in 2014.

It is evident that the Council is not prepared to proactively meet its housing need and is artificially using the Green Belt as justification to resist meeting this need.

Notwithstanding this clear contradiction, Professional Planning Officers of the Council have stated on record that they do not endorse the current NLP (2016) document and will not act as advocates at Examination. This was confirmed in the Committee Report to Ordinary Council on 23 March 2016 (Appendix 2) which states that Officers consider that to support this plan would be a breach of the RTPI professional Code of Conduct and that ‘ Members must not make or subscribe to any statements or reports which are contrary to their own bona fide professional opinions, nor knowingly enter into any contract or agreement which requires them to do so’ .

This is clear evidence that the Plan is unsound as the Council’s own Planning Officers deem it so.
It is considered that Members, in pursuit of their political objective to protect Green Belt land, have unjustifiably elected to set aside its own evidence and lower its housing requirement.

Another developer points out that the Local Plan  must consider;

“…. Spatial implications of economic, social and environmental change.”

this is particularly interesting as all iterations of the Local Plan, the Core Strategy the daft New Local Plan and the latest version, Local Plan2016 seek to increase the population of Canvey Island through development, thereby increasing the numbers of People at Risk of Flooding and at Risk of a Hazardous Industrial Accident.

As has been mentioned above, it is not unusual to expect developers to attack the Castle Point Local Plan 2016  but for a neighbouring local authority to join in by “helpfully” pointing out;

“However, in doing so the New Local Plan ignores the recommendations of its own evidence base which advises that it is in fact possible for development to occur in some parts of the current extent of the Green Belt in Castle Point without diminishing its purpose.”

Another neighbouring local authority makes comments using terms such as “strongly objects to” and “needs to ensure” and they “remain very concerned about..” all far too emotive terminology than is required to be viewed as being helpful in the Castle Point Plan making process.

The local authority concerned also requested that all mentions of a link road between Canvey Island and Manor Way Thurrock is removed from the CPBC Local Plan!

Very Duty to Cooperate neighbourliness indeed!

Furthermore the author, a “professional” officer, has requested to participate in the oral examination of the Castle Point Local Plan.

I don’t recall this particular local authority’s representative requesting permission to attend the CPBC Core Strategy examination back in early 2010, a far more Unsound and Unsustainable planning document than the current version!

More recently clearer Government Guidance has been issued to accompany the NPPF to assist local authorities in the Local Plan making process with areas constrained by Green Belt land.

The CPBC Local Plan 2016 has evolved from less popular versions and follows activity by leading councillors and indeed the Castle Point MP, who has gone to efforts to arrange training sessions for councillors and officers with Ministers and advisory Planning Inspectors.

Government Guidance includes:

Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity;

The CPBC Local Plan2016 evidence base is undermined by containing many reports and assessments which are seemingly out of date, such as the Green Belt Boundary Review 2013 – published prior to the Government issuing clear Planning Guidance on Green Belt and yet contained within the current Evidence Base of the Local Plan.

For a Local Plan to be successful both the content and the presentation will need to be impeccable. From the comments of both developers and neighbouring authorities it appears that Castle Point officers are unprepared to give the Local Plan 2016 their full commitment. Officers participation at the Examination of the Plan will make interesting watching.

Photo courtesy of: Echo Newspapers

 

The Castle Point Borough Council planning Devil is in the Detail!

The devil is in the detail, is an idiom that Castle Point Council appear to rely on where development approvals on Canvey Island are concerned!

Far too often development proposal comments by consultees are taken at face value in the support of approval recommendations of the “professional” officers.

Rarely do development Committee members challenge the points of recommendation, simply because of a lack of alternative information.

Within proposal consideration for Calor and Oikos will often be the Health and Safety Executive comment; “Do not Advise Against”.

Within a recent appeal inquiry in Oxford a Do not advise against comment was made by the HSE in regard to a development near a Hazardous site.

However the local authority, UNLIKE Castle Point felt they should seek independent advice, rather than rely on untrained officers taking the HSE at their exact word. The advisor to the Oxford council considered that;

Do not advise against is not the same as saying planning permission must be granted. 

Overall the HSE methodology is designed to identify sites where the HSE feels obliged to advise against planning permission.

However, their only other advice category of do not advise against is not equivalent to supporting the application being granted.

As already established it is quite legitimate for a local planning authority to take a different view on the merits of granting planning permission, so long as the HSE’s advice has been taken into account.

That the HSE disputed some of the advisors comments, was not disputed, what is relevant is that the local authority had attempted to seek objective advice that may not be available amongst local authority officers.

The development in question, is in a less significant Flood Risk Area than that of Canvey Island.

The local authority in Oxford have a shortfall in housing land and under estimated their Objectively Assessed housing need, as is likely to be found in the case of Castle Point’s local plan 2016.

Despite this and the fact that the site in question was for a great deal fewer dwellings than in the case of Thorney Bay, the Oxford local authority turned down the application.

Castle Point of course have approved in principle outline permission for 600 dwellings, a residential institution plus the retention of static caravans and included these numbers within their daft New Local Plan and Local Plan 2016!

This despite the developer having relied on quoting the CPBC’s previous consideration: “The most recent Strategic Housing Land Availability Assessment (SHLAA) (2011)  indicates a potential range for dwelling units for the site between 378 and 595”

All based upon them achieving a “do not advise against” response from the HSE.

The Environment Agency acknowledge an agreement with Castle Point council in which Canvey is to be treated as a Special Case where Flood Risk and housing development needs for the whole Borough is concerned!

Canvey representatives really do need to start reading the SMALL PRINT where planning proposals are concerned!

  Footnote: Neither of the local Parish nor Town councils concerned in the Oxford case have given any indication that they intend to produce a Neighbourhood plan.  No evidence was submitted of any preliminary works in this regard. 

Canvey residents add to cause of their own Flooding! Scrutiny committee warn of Chip Fat ahead of final report.

Almost as one final insult to residents who had suffered during the major flooding of July 2014, the Castle Point Council flood scrutiny committee identified one further cause of the flooding,  Canvey Island residents themselves!

It appears that members consider residents pour too much cooking oil into the drainage system, thus adding to the reasons why so many houses were flooded during the heavy rainfall!

cooking-oil-power-660-jpg

Previously residents had heard the Essex Highways representative admit the gulley cleaning scheduling had fallen short of the necessary standards, that Anglian Water had found damage to the drainage pipework had been caused by developers and utility companies. The Environment Agency had found their pumps had failed for short spells due to design flaws and that dykes were in need of more regular maintenance and that some areas of dykes / watercourses had been filled in, adding to the restricted flow of surface water to the pumps.

Last evening’s Flood Scrutiny meeting was felt necessary as the Lead Flood Authority, Essex County Council, the Government Office for Science (GOfS), and DEFRA had each, in their Reports, identified serious shortcomings directly attributable to the local authority, Castle Point Borough Council.

The Canvey Green Belt Campaign group had assembled these identified shortcomings and suggested to the Scrutiny Committee that residents should hear the local authority’s response to them.

The Castle Point Council officer assigned to respond to the individual Peer criticisms denied any flaws in either current or historical policy and decision making.

yesminister

In the light of the level of criticisms of Castle Point Council, contained in both the Essex Lead Flood Authority, the GOfS and DEFRA Reports, and the officer’s refuting of all, the only explanation appears that the blame rests with local decision makers themselves, our local councillors!

There can be no denying that the flooding suffered by residents caused serious damage to property,  major inconvenience and distressing fears that the level of flooding may happen again once the immediate maintenance schedules revert back to normal.

This should have been an opportunity for committee members to have questioned the officer on the policy and implications of continuing to develop housing  in a Critical Drainage Area and Flood Zone 3A whilst new builds will not be covered by the Insurance industry and Government’s Flood Re scheme. This may well leave home owners with difficulty in obtaining House insurance against flooding.

During the New Local Plan Task and Finish group meetings this same officer plus, Brandon Lewis the housing Minister, ex head of the planning Inspectorate Lord Pitt and the Planning Inspector invited by our MP to address a councillors training session, Keith Holland have made clear that Flood Risk is a Policy Constraint on Housing.  There appears a relutance to apply this constraint.

Whilst the meeting was not publicised as well as the previous scrutiny meetings, no Press were in attendance and just 17 Residents were in the public gallery. Whilst no organisation enjoys criticism, the level of flood damage and distress deserved being openly and transparently, publically addressed.

The officer made clear that the currently and previously employed, civil servants had worked within Planning Policy and Guidance in their recommendations.

So we are left with a dilemna of whether the Government Office for Science, the lead Flood Authority Essex County Council and the Environment Agency were wrong to criticise Castle Point Council, whether these were not actual criticisms, whether councillors rather than officers were being criticised, or indeed these comments were not in fact actual criticisms!

The points “suggested” that CPBC may like to address during the scrutiny meeting are reproduced below. The speech marks identify some areas of concern of our local authority made by either the Lead Flood Authority Essex County Council, the Government Office for Science, the Environment Agency or DEFRA:

1. Drainage
Reliance on Inadequate Capacity of the Drainage System.

“Canvey Island is an area that has historical susceptibility to flooding and following the severe 1953 coastal surge, has considerable sea wall defences. As a very low lying area, over thick layers of clay surrounded by sea defence walls the importance of the drainage and associated systems is fundamental to managing the rainfall that the area receives.”
“The flat topography of the Island, combined with the densely developed urban areas and covering of open watercourses has created an exceptional reliance on the designed drainage system. In addition, a large amount of Canvey’s drainage system was designed prior to the introduction of national design standards and is therefore likely to be of lesser capacity than new infrastructure.”

2. Over-Development
Level of Past and Proposed future Development.

“Older drainage systems may have been sufficient at the time of construction, but increased development and subsequent pressure on the already strained drainage system has meant that in some locations the capacity is not sufficient to provide effective drainage and mitigate flood risk. As a result of this, some areas of the Island have suffered from a history of surface water flooding in more moderate events than those of 20th July 2014”
“Due to its location, topography and urban design, Canvey Island as a whole exhibits a significant level of underlying flood risk, with large areas of the island particularly vulnerable to flooding.”
“Poor historical recognition of flood risk in the planning process and increases in areas of impermeable surfaces have led to further difficulties in draining a very low lying area which has historically been very susceptible to all sources of flooding.”

3. Building Control
Lack of enforcement of Planning Conditions

“It is also possible that drainage systems have been misconnected, or not built or maintained as proposed, which are causing local issues. Compliance with planning conditions and enforcement is a matter for Local Councils rather than ourselves.”

4. Surface Water Management Plan
Flawed and irrelevant document.

“We (EA) do consider the outputs of the South Essex Surface Water Management Plan, produced by Essex County Council as the LLFA and within which Canvey Island falls, when commenting upon the adequacy of surface water management proposals.”
“The (Surface Water Management Plan) methodology is applicable for those areas of south Essex where there are significant variations in the land level to generate surface water flow paths during rain fall events, but therefore is not applicable to the flat topography and subsequent reliance upon piped infrastructure and pumping stations found on Canvey Island. As a result it does not provide an accurate reflection of known surface water flood risk on the Island,”

5. Following of Environment Agency Advice through the CPBC
Planning Process.

“We (EA) comment on the adequacy of surface water management proposals for any site greater than 1 hectare. This statutory power was set out in revisions to the General Development Procedure Order (GDPO) published on 1 October 2006. Since this date we have advised Local Councils on the adequacy of Flood Risk Assessments which includes ensuring that flood risk will not be increased as a result of the proposed development. This advice is primarily based on managing any surface water run-off leaving the site. It is however only possible to advise Castle Point Borough Council on flood risk and how it may affect a site based on the best available information at
the time. We are currently working in partnership with Anglian Water, Castle Point Borough Council and Essex County Council to model the urban drainage system on Canvey Island.
It is the responsibility for Local Councils to assess the drainage proposals for
developments less than 1 hectare. Since 1 October 2008 planning permission has been required for converting front gardens into impermeable driveways, prior to that date this could be done under permitted development rights.”

6. Sequential and Exception Test
CPBC Responsibilities

“Concerns about the Sequential Test should also be directed to Castle Point Borough Council. We (the EA) will highlight the need for Local Councils to apply this Test, and the Exception Test, in our planning responses but it is not within our remit to advise on its application as we do not have a detailed understanding of the availability, suitability and viability of alternative sites.”
“28. Further development is planned in a number of locations on Canvey Island.
This could cause increased surface run off and put further pressure on the drainage systems. It may also increase the number of properties at risk of events such as this in the future. Government planning policy requires that future development on Canvey … does not increase overall flood risk.”    “Our remit is to advise Local Councils whether Flood Risk Assessments supporting planning applications comply with flood risk policy set out in the National Planning Policy Framework (NPPF). If there is a local need to consider applications differently then this should be set out in the Local Plan for the area.”

7. Mis-Perception

“Consumer confidence in flooding infrastructure is low. A major concern for the public was the perceived ineffectiveness of the drains and pumps – not just for surface water flooding, but an underlying fear they might not work if Canvey ever suffers from a tidal surge.”

The officer suggested that flooding from surface water  and that from the sea should be addressed separately, despite the statement above having been attributed to his own Chief Executive!

8. Communications
Disconnection with Residents, leading to lack of meaningful communication of information.

“The local authority has a role as a category one responder to warn and inform their residents of risks and respond during such flood events. Castle Point Borough Council receive the same weather forecasts and advice as other category one responders”
“At least 250 from 20th July – 12th August. Potentially greater number as enquiries received through various sources (Elected Members, Officers etc.), although some repeat enquiries were possible.“

Criticism within the Report and Review documents of the July flood incident suggest that communication between the public and the Responsible Agencies has been limited or confusing.
It appeared that local residents suffering from being flooded first turned to the local authority. Castle Point Council use an outside agency, Southend Careline, to handle out of hours emergency calls. This outside agency were unable to handle the number of calls.
“16:12 Request from the Southend Careline for Sandbags to CPBC CCC. Careline was informed that CPBC does not hold stocks of emergency sandbags.”
Not only do Canvey Island residents appear unaware that Castle Point Council do not have a “sand- bag” policy, but also the appointed helpline agency were equally unaware.
There appears very limited awareness of the CPBC “Be aware, Be prepared and Be Resiliant” programme.
Castle Point Council issued a number of messages during the flood event via social media. CPBC should be in full knowledge that of their 2,054 Twitter followers, given the population distribution, just 883 are likely to be residing in Canvey Island.
Likewise the CPBC Facebook page has received just 106 “Likes.”
This indicates a lack of social media communication achieved !
The dis-engagement between the local authority and it’s residents was particularly apparent during the August 2013 and July 2014 times of crises.

 

 

“Flooding should be a priority – we must ensure that money is not wasted through poor development and lack of maintenance”

Paul Cobbing has Guest Blogged for the Association of British Insurers.

His opening paragraph could not have had more relevance to Canvey Island, than if he had posted specifically with Canvey in mind.

The Castle Point Council Scrutiny committee looking into the causes and issues following the surface water flooding during the summers of 2013 and 2014 are still to release their Report. The committee members will have local knowledge and will be expected to highlight the issues that have been allowed to undermine the Island’s drainage system.

floodfreehomes

Flooding to the scale endured by Canvey Island residents brought a realisation of how alone people become when dealing with the effects and after effects of such events. Strong words and promises that “lessons will be learned,” (again), along with funding to mitigate against future occurances.

Much is being organised to clear drainage channels and to inspect for intrusions into the drainage network but the thought that things will return to how they were, ahead of the flooding, is always the likely scenario.

Drainage maintenance was not conducted thoroughly prior to the recent funding cuts. Money has only been allocated for a thorough cleansing, we have only the Highways official’s word that the maintenance levels will not drop back to previous inadequate levels.

Human nature is that following a spell of reasonable weather in which the drainage system copes, gives a false sense of confidence that will again lead to neglect. The Canvey Flood website indicates that Anglian Water are currently continuing the CCTV sewer network surveys. Whilst Essex Highways have not updated information since mid December, one is left wondering whether the gulley cleansing programme has been completed (not in my area) or whether it i s simply a failure in keeping the residents informed.

Canvey residents are familiar with hearing messages explaining the confidence we should have in our pumping system and sea defences, unfortunately the ability of  a drainage system is only properly tested during an actual heavy sustained downpour or during a storm event.

No word of who is to be appointed the sole person responsible to command and control the prevention and response to flooding in Essex as recommended by the Government Office for Science’s  Sir Mark Walpole.

Sir Mark Walpole

Sir Mark Walpole

This would be the most important step in safeguarding homes and residents on Canvey Island for the future.

Canvey residents eagerly await the CPBC Scrutiny Report.

Paul Cobbing posted:

Flood water can drag the heart out of communities.  Once the water, the politicians and the cameras are gone, people have a long hard grind to get their lives back to normal and the trauma can live with people for the rest of their lives. This is why we must get better at managing flood risk to protect our communities. Flooding should be a priority for all of national and local government, both to fund and maintain defences, but also to ensure that this money is not wasted through poor development, lack of maintenance of gullies, culverts and bridges, and inadequate riparian management.

We still have a very long way to go.

Managing flood risk using the full range of tools from catchment management to flood defences, and reducing the impact on individual homes is essential to protect people against the effects on flooding. Though, as the recent report on Defra performancefrom the Environment, Food and Rural Affairs Select Committee highlighted, the low level of funding for flood risk management, particularly maintenance, is concerning  for the millions of homes at risk of flooding. A much longer-term, more coherent, better co-ordinated approach is desperately needed in this country, that includes all of the factors that affect flood risk.

This is why the National Flood Forum is supporting the Flood Free Homes campaign, for a sensible long term approach to land and water management. We must act now, as climate change and factors such as development and higher population density mean that the problem is getting worse. We need sustained and co-ordinated investment in building and maintaining flood defences, a sensible approach to building new sustainable housing and long-term thinking about flood prevention that does not get caught up in the politics.

We must act now, as climate change and factors such as development and higher population density mean that the problem is getting worse.

Flooding throughout the world is becoming more extreme as a result of changing weather patterns and increasing populations.  Here in the UK we’ve had more severe floods in the last ten years than in the generation before.  Flooding can hit anywhere now – not just near the major rivers.

The devastating nationwide floods in 2007 created the biggest peacetime civil emergency since the Second World War. According to the Pitt Review, 55,000 properties were flooded, with 7,000 people needing to be rescued from flood waters and 13 people died. Recently, the annual cost of flood damage has been £1.1 billion and is set to rise.

At the National Flood Forum, we work with communities at risk of flooding to offer advice and support them when preparing for flooding and starting the recovery process if the worst has happened. We see first-hand how communities can be devastated by flood water and how challenging the recovery can be. We hope in the future that this country will be more resilient and protected against floods, so that fewer of our communities experience this first hand.

Paul Cobbing is Chief Executive of the National Flood Forum.

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