Tag Archives: Dutch Village

CPBC Local Plan Members, Inspector sends a Timely reminder, development on Canvey’s Green Belt does not constitute Very Special Circumstances nor Pass the Sequential Test!

Canvey’s Dutch Village Green Belt fields have been saved from Persimmons latest attempt at development of Equestrian Stable block, hay storage, grazing and exercise facilities.

Having taken the proposal to Appeal, the Appeal has been Dismissed on Grounds of Flood Risk AND Green Belt!

This is all part of their long term aim of circumventing the planning process to develop 300+ dwellings through the Castle Point Local Plan.

In what MUST serve as a Timely Reminder to those Castle Point Councillors who meet on the 22nd October to pass the next version of a daft Local Plan, the reasons, and clear interpretation given by the Appeal Inspector should be used as Direction to Think Again, before releasing what little remains of Canvey Island’s Green Belt!

The Appeal Inspector, in considering a 2 horse Stable Block with paddock and grazing land, found:-

 “The construction of the stable block would result in a built development where there are not presently any buildings.  The development of a new building (and associated paraphernalia) would inevitably lead to the loss of openness.  This is particularly the case as the site has no other buildings or development on it.

“Furthermore, it would also lead to a loss of Green Belt openness and would impact on the Green Belt purpose of safeguarding the countryside from encroachment contrary to the Framework.”

“A flood risk sequential test should not take into account the need for such facilities as such but should concentrate on whether the suggested location is appropriate having regard to other available sites.”

“In this case, the Appellant has justified the limitation of the sequential test area to Canvey Island on the basis of the local need from Canvey Island and the desirability to have such facilities in proximity to the owner of the stabled horse(s). It has also been suggested that the ‘mainland’ is around 3 miles away. However, the Council consider there is a more direct route to Benfleet via the B1014. On my journey to/from the appeal site, I travelled along both routes and I agree with the Council that the route via the B1014 is a quicker and a more direct route. To my mind, this indicates that sites away from Canvey Island should be considered as part of any overall sequential test assessment. Given that the information provided to inform the sequential test does not consider other sites away from Canvey Island, this presents a significant omission.”

“….in the absence of a comprehensive sequential test it has not been demonstrated that the proposal would not present an unacceptable risk in relation to safety and flood risk. Consequently, the development would be contrary to the flood risk aims of the Framework.”

“the very special circumstances necessary to justify the development do not exist and the proposal would conflict with the Framework.”

Green Belt balance;

“I have concluded that the proposal would be inappropriate development and would have an adverse effect on openness.  The Framework indicates that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.  Therefore, substantial weight should be given to the harm to the Green Belt.  Very special circumstances to justify inappropriate development will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”

It was not so long ago that Brandon Lewis, issued a written ministerial statement saying that unmet housing need was not in itself likely to constitute a very special circumstance.

It was encouraging that the Planning Inspector took note of the submission of the Canvey Green Belt Campaign and referred to points made by us in reaching his decision. We live to fight another day.

However the CPBC councillors participating in the meeting to decide the fate of Canvey Island’s Green Belt should note, they will be held Totally Responsible, should they agree a Local Plan that includes development on the two valuable Green Belt areas on the Island.

To capitulate to the officers, leader of the council and Government Interventionists, is to Betray Castle Point Residents, according to the Inspector considering the Persimmons Appeal, un-necessarily!

The full Appeal decision can be found HERE.

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Green Belt, Brexit, General Election, Government Intervention. What could be delaying the next Castle Point Local Plan?

Decisions, Decisions, Decisions, facing Castle Point Council!                 

Whilst working tirelessly, no doubt, behind the scenes in producing a further Local Plan draft, the key decision in its production will be Timing. That is, when to put the Local Plan before the full Council for consideration, and when to release the Housing Sites selected.

Potential Reaction from Residents, can be considered a crucial Factor, what with the potential Fall Out should Residents be asked to attend the likely imminent General Election Polls. There is no doubt that Brexit and the turmoil, I was going to write, “inside parliament”, but as it remains closed at the time of writing, had better change to, turmoil on the political front, is undoubtedly affecting CPBC’s advancement of their Plan.
Despite being supposedly under pressure to speedily produce an adoptable document, otherwise Government Intervention will be implemented, and Green Belt Land being left “vulnerable to speculative developers(since 2009?), CPBC appear confident working at their own pace of production. Rumours suggested that late Summer would see a Plan emerge, but now Autumn nears and still no sign.

In the light of no information emerging it seems reasonable to speculate which Housing Sites may be included, given certain rumours currently going around the Borough.

Given that Canvey Island’s Green Belt has been selected for Development in every single one of CPBC’s draft Local Plans, that is with the exception of the 2016 version, which left the Rails at the Duty to Cooperate stage, it would be a waste of time and energy worrying about which of the Island’s sites will be included for development in the latest forthcoming Local Plan.

The mainland is a different matter, as what Housing Development is to be proposed for the south of the mainland part of our Borough will directly influence, to the detriment, the Traffic Flows and Congestion getting to and from Canvey Island!

Jotmans Farm and Land between A130 and Romsey Road, is identified for 940 new dwellings all due to be serviced by a roundabout with a Junction intersecting Canvey Way!

Canvey Way, Sadlers Farm and the Waterside Roundabout needs no explanation as to their chronic effects upon the everyday life of Canvey Islanders. Sadlers Farm, sold to us as being a potential relief to congestion issues, in fact turned out to be the exact opposite whilst also affecting for the worse, commuter traffic heading for the Tarpots junction and Benfleet.

Those wondering why the south of the Borough appears to be the favoured development and regeneration areas will be puzzled by the apparent overlooking of sites towards the more central parts of the Borough. CPBC identified sites with a potential to realise 1,100+ dwellings around Daws Heath and Rayleigh Road areas.

The previous draft Local Plan 2018 in its Green Belt Housing Site Selection, identified 455 dwellings at Land East of Rayleigh Road with other sites allocated medium to small numbers of dwellings, other than the Chase area off Kiln Road, already partly developed through the 1998 Adopted Local Plan.

This despite the Castle Point Council Briefing paper for the Members Conference of September 2011 identifying capacity for many more dwellings on sustainable dwellings in the Green Belt on sites in the middle part of the Borough.

It appears that even now, Local Factors are influencing Green Belt development site selection, as Canvey Island and the Jotmans Farm area are receiving no such protection.

Green Belt development remains a volatile topic at Local and National levels. Should illogically preferred sites continue to be protected through the influence of “Local factors”, then it would be fair to assume that a new draft Local Plan will also be the subject to opposition and criticism through to its Examination stage.

The A127 Nevendon Interchange is receiving Government monies to improve traffic flow, talk is of consideration of removing the Fortune of War roundabout to also improve flow. And yet still no word of reconsideration of the North West Thundersley site, Blinking Owl, with the potential for 1,200 dwellings with the opportunity to put in new infrastructure to best suit the needs of commuters with Government funding via ASELA, The Association of South Essex Local Authorities!

Whether it’s the Brexit and possibility of a General Election issue at National level, or Green Belt and the Local Plan with its allegedly imminent Intervention threat at Local level, No, I really can’t think why the next issue of CPBC’s Local Plan is so slow in Emerging.

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

No Place for Intimidation, Castle Point councillors were simply not convinced the Local Plan was acceptable or Fair. Time for an Inquiry into Behaviour!

It appears there have been reports, that following the Castle Point Council decision not to approve the draft 2018 Local Plan, certain councillor or councillors have been subjected to intimidation, basically for voting against a Local Plan they felt unacceptable.

Lead group councillors suggest they were allowed a free vote.

Firstly the chief executive made clear that in his view the Plan wasn’t for changing, and the vote must be in favour of adoption, solely to keep to a schedule set by Government.

The council leader repeated this warning as did his deputy, this was followed by many councillors stating they were between a “rock and a hard  place”, followed by the usual platitudes.

It may have been an easier passage for the Plan if rather than the sit and listen briefings, councillors from all sides had been invited to engage with the Government chief planner’s team and had some input into drawing up the Plan.

Some of the councillor’s input into the debate was nonsensical. Cllr Cole for instance explained his sympathy for the homeless people of Castle Point, families waiting to be housed. Then he went onto suggest that with Cllr smith’s inclusion of master planning developments identified for development ward councillors and residents would have influence on the density of the housing, less flats, more open spaces etc etc.

Master planning will come at a serious cost, most particularly at the likely expense of affordable and social housing!

Another councillor suggested in his 6 months of being in position he had studied and got to grips with the Local Plan process of Castle Point, all 12 years+ of it!

We have heard talk at National level of No Plan being better than a Bad Plan.

Luckily in a democracy we are allowed to say and vote accordingly, especially if we feel this is the case.

Perhaps some councillors felt that “Local Factors” still affect the cpbc Plan making process, it has before!

What the leadership and officers must remember is that they have solely been responsible for the debacle of a situation they have found  themselves in, they have voted in Favour of every single Plan put before the members and it was they that Failed the Duty to Cooperate test with the 2016 Plan, before that even reached examination stage.

For it to be claimed that the Lead group allowed a free vote on the Plan makes it all the worse that it appeared that one councillor was taken ill, possibly due to the pressure of the occasion, and another was left upset by remarks following the vote.

In a democracy it is peoples right to make up their own minds, and it is important they are allowed to do so without fear of recriminations.

Now it is important that those who have Failed us should not take the Lead should intervention occur.

The Gov. Chief Planner is fully capable of putting together an unbiased and neutral team of planners and examiners.

Perhaps this is what those so forcefully behind an approval vote fear the most.

Now following the recent posts leading up to Wednesdays meeting, we have encouraged participation through the comments column.

This time for many reasons there will be none allowed, as the saying goes, they will have to “suck it up!”

This Post is purely in appreciation of the councillors who took a brave decision in spite of the consequences and took the more difficult decision to vote, right or wrong, according to their consciences for what they felt was Right.

Those brave mainland and Island councillors are what makes this country what it is.

The rest of us must learn to live with it, or come up with a more convincing argument other than intimidation!

There is a very real case for an Inquiry into the Matter!

 

How NOT to Build Cross Community Consensus, the Castle Point Way! A Joint meeting with Canvey and Mainland Residents apparently “Not Effective”!

Embracing the spirit of localism, a small contingency of Canvey Island and Benfleet community representatives, collectively requested an opportunity to discuss their Development concerns, with Castle Point Council leader, Cllr Smith.

smiff

Residents having recognised that the loss of Castle Point Green Belt sites, that are in close proximity, will have a cumulative impact on the local environment.

Unfortunately, seemingly wishing to avoid a combined group meeting, made up of the Dutch Village and Jotmans Farm Green Belt sites campaigners, the leader of CPBC, succeeds in promoting the perception, that communities from Canvey Island and Benfleet are being kept separate for an ulterior motive!

Local communities in this part of the Borough are clearly best placed to recognise that local and main roads are struggling to cope with the demands of today’s traffic, let alone the additional traffic brought about by the proposed large scale indiscriminate development.

The same communities are also best placed to understand how their health and wellbeing issues are directly linked to road traffic pollution and how their day to day functional requirements are already overstretched.
It was not unreasonable of us, to seek an open forum with cllr Smith, so as not to allow local campaigners to meet the leader in more “private” circumstances.

It may appear advantageous for residents with localised green belt site interests, seemingly at risk of development through the new Local Plan, to engage with cllr Smith via individual one to one meetings, however this may encourage the return to the problematic Local Factoring, that has blighted and festered mistrust, through previous versions of the CPBC Local Plan!

Having rejected the opportunity of bringing the community of Castle Point together, Cllr Smith has disingenuously failed to meet his communities public consultation expectations.

CPBC recognises that one of the key risks to the successful production of its Local Plan and its Policies is the possibility it would attract significant public opposition. This particular threat level has been scaled as “HIGH”, and mitigation measures were needed, in the face of Residents opposition to the Local Plan, to prevent slippage in the programmed time scale, raising the perceived Fear of Government Intervention.

CPBCs documented that:-
“The Local Plan will tackle contentious issues that could give rise to significant public opposition. Whilst every effort will be made to build cross community consensus, there remains risk of significant public opposition to the Local Plan proposals”

Cllr Smiths determination to meet with individual Green Belt groups in isolation contradicts this commitment.

Canvey Island’s Dutch Village Green Belt Development, Persimmons approach the 2nd Hurdle, with just one faller at the 1st!

Persimmon have big Housing Development plans for Canvey Island Green Belt.

However they appear happy to play the Long Game, as they again propose a Stable Block for Horses on the Dutch Village Green Belt on the Cornfields, as their first stage approach to their aims.

Note the new Application number should you care to object.

Green Belt. Land East of Canvey Road Application No. 18/0980/FUL | Erection of stable block with adjoining hay storage/tack room and associated landscaping, formation of access track together with the change of use of land for the keeping of horses, installation of a width restriction barrier to discourage unauthorised motorcycle access and main entrance gate alterations | Land East Of Canvey Road And South Of Great Russell Head Farm Canvey Island Essex

This will include the “Change of Use of Land” as it is Green Belt.
Their Application stresses the stables will be “Built Development”.

Those wishing to object to the application, can do so on the CPBC website.

The relevant page can be found HERE.

For those concerned or wishing to make comment we thought it might be helpful to make public our Grounds for Objection as registered with Castle Point Council, these follow below for you to see, feel free to cherry pick to add to your objections:-

This Proposal for Stables, also more importantly, includes the change of Use of Land.
Therefore, as a whole, it should be considered that the proposal represents inappropriate development in the Green Belt. The NPPF identifies that such development may only be permitted under Very Special Circumstances.

NPPF Paragraph 83 instructs “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.” It can be argued that the “Change of Use of Land” should also only be considered, through the preparation or review of the Local Plan rather than by individual applications.
“All permanent stables and field shelters will require planning permission and, if the land is not in use for the keeping of horses, an application is unlikely to be acceptable.”

The Land has not been used, and is not used, for the keeping of horses. No permanent stables have been erected in the past.
The current security of the site actively discourages and prevents horses from having easy access to the fields.
As CPBC have recognised that a similar Application, 16/0433/FUL, required Very Special Circumstances, despite a Change of Use of Land NOT being necessary to be applied for.

The term Very Special Circumstances implies that a desperate “Need” for this facility must be Obvious and Proven, or that there are very few similar facilities in the area.

It should be noted that there are many similar facilities in the local area.
Most notable of which are the Approved Application for livery, stabling and 2 ménages at Sluice Farm, Haven Road, Canvey Island.
Approval for this considerable facility, Proposal 16/0433/FUL, for stables for 40 horses, was granted by Castle Point Borough Council as recently as 10th January 2017.

Also the long established nearby facilities at Northwick Poultry Farm x 2 yards, Northwick Road Canvey Island.
The Applicant states that “facilities are small scale” indeed accommodating a maximum of 2 horses only. This will have no tangible impact on any suggested unmet need for such facilities, even if such need were proven to exist.

In the light of these points raised, the Very Special Circumstances necessary cannot be considered to have been fulfilled.

Green Belt
Purposes

Whilst CPBC will be reminded that they are expected to consider only the Application for stables etc, it must be noted that the Applicant themselves goes to repeated lengths to emphasise “of course, as a matter of fact, the construction of such buildings in the Green Belt will give rise to built development upon it” as though some precursor to other types of more extensive development, they being Housing Developers.

The applicant points out “To the south is an extensive area of unmaintained scrubland which separates the site from the residential area to the south (Holland Avenue). This extensive area of scrub would preclude views of the stables from the residential area to the south. It is considered that the development would have no perceivable impact on Green Belt openness when viewed from the residential area to the south.”

This is presuming that this currently unmaintained area will remain so. This should not be assumed, as the area in its present unmaintained condition can be considered a very potential fire hazard to the houses along Holland Avenue. The area of scrubland has been allowed to grow high and against the rear garden fences of Holland Avenue and it would be reasonable to expect that these bushes and brambles should be cleared, thus removing the fire hazard.
Therefore this area of scrub cannot be considered a permanent feature and that the stable block and yard, a permanent Built feature, would then be compromising and impacting upon the Openess of the Green Belt.

The applicant refers to the Purposes of the Green Belt and notes ‘to check the unrestricted sprawl of large built-up areas’;5 By the applicant pointing out that their intention is to construct “buildings in the Green Belt will give rise to built development” they are in effect conceding that they would be harming the Green Belt by means of commencing Sprawl And beginning Encroachment into the countryside adjoining this largely built up area.

Archaeological Features

The Design document indicates that there would be no hard fencing restricting the movement of Horses outside of the Stable Yard.
The field abutting the proposed Stable Yard contains the Roman Saltern, a scheduled Ancient Monument, 260m south east of Great Russell Head Farm. This monument is scheduled under the Ancient Monuments and Archaeological Areas Act 1979 as amended as it appears to the Secretary of State to be of national importance.

Applicants Design and Access Statement
This field, being the least low-lying, is the driest of the 4 fields making up the site during the wet winter months, whilst much of the other 3 fields remain heavily water-logged during this period.
The temptation to use the field containing the Roman Saltern during wet periods to allow “turning out” or exercise may well lead to potential damage of the archaeological feature and any historical artefacts below ground.
“The use of mobile, temporary horse fencing would allow ‘paddock’ areas to be formed for the grazing / exercising of the horses.”

The potential therefore exists for these fences to be knocked down whether by deliberate or accidental means, allowing horses to escape their confines, and / or riders to be unaware or careless and ride across and around the scheduled Ancient Monument Site.
Therefore the development will most likely lead to an adverse impact on the archaeological features close by.

Proposed Access
The Applicant is wrong, and it is misleading to suggest that; “The site currently benefits from a lawful access from Canvey Way.”

The current access is on a busy dual carriageway, Canvey Road. This is towards the end of a 50 mph stretch leading from Waterside Roundabout on which speeds of up to 70mph are not unusual! The access gate is directly ahead of the road as it curves into the approach to the Canvey Road / Roscommon Way roundabout.

The design plans indicate the intention to “set back” the gated entrance 6 metres from the footpath. Whilst this “pull in” may make the actual entry to the field somewhat safer, other Canvey Road field entrances, with similar “pull in”design, have been the subject of serious “Fly Tipping” problems. This has been notably recorded at the entrances to the Canvey West Marsh RSPB site, directly opposite.
The only solution to this Fly Tipping problem the RSPB have found, is to re-position the gates directly close to Canvey Road, the exact opposite of the Applicants Planning Proposal’s intentions.

The use of Canvey Road is planned to become busier, given the planned extension to Charfleets Industrial Estate and the approved Business / Retail Parks, increasing the private vehicle and heavy commercial vehicle use, adding to the potential hazards.
The assessed 6 vehicle movements per day for the proposed site, whilst few, will likely be during the most busy periods of the day, during the early morning commute and the start of the evening Rush Hour.

Adopted Local Plan Policy RE11: STABLES WILL NOT BE PERMITTED WHERE THE EXTENT OF ACTIVITY WOULD GIVE RISE TO AN UNACCEPTABLE LEVEL OF TRAFFIC GENERATION OR WOULD BE LIKELY TO CAUSE DANGER TO OTHER ROAD USERS. (my emphasis).

7 Design and Access Statement 6.12 and 6.13 with accompanying photograph 8 “ “ 6.2, 6.7, 8.8, 9.5
In the event of a Fire in the Stable Block, the Applicants submitted Stable Entrance Plan drawing, appears to indicate an inadequate entrance width for the Fire Service Pumps. The minimum requirement indicated in the London Fire Service document “Fire Service Guidance Note” GN29, between Gateways, is 3.1 metres. Whilst the Applicants Drawing gives no measurement figures, the width restriction appears to be no more than 3.0 metres wide.

The access would prove a very tight “turn-in” for a Fire Service pump, and mean blocking Canvey Road should the gate be locked, whilst access is gained.
Currently the field gate is locked and historically when fires have “broken out” or been started in the field proposed for the Stable Block or an adjacent field, the fire Service pump has had serious issues gaining access, due to the narrow locked gate and the general ground conditions.
The proposed entrance, given its position and layout, must be considered a critical feature and unsuitable for purpose.

Vandalism

The proposed site for the Stable block is very close to Canvey Road pedestrian pavement, adjacent to the “old” original Canvey Road, thereby hidden from view of vehicles passing by.
The RSPB site and West Canvey Marsh opposite have suffered from vandalism.

The Stable Block would likely act as a “magnet” for vandals being, unlit, housing unattended animals over night, out of sight of passers-by view thereby “secret”, and of wooden construction, containing feed and bedding, all potential fire hazards.
Historically young children “play” in the field, making dens etc, directly behind the gardens of Holland Avenue. Occasionally attempts are made to light fires but in the main residents are aware of the activity and are able to take preventative measures.
Older generation of youngsters are responsible for the sporadic more serious fire starting on other parts of the land, that takes place usually over the course of the summer months, and causes the Fire Service to attend.
The potential for harm to animals, damage to the facility and creating a more serious fire, with more serious consequences, close to the scrub field directly behind the Stable Block, to the south, should not be dismissed.

At 6.9 of the Design and Access Statement, and to conform to cpbc officer requests, a width restriction gate is proposed to discourage unauthorised Motor cyclists. Whilst this would not be unwelcome, it must be acknowledged that this form of nuisance does not amount to the problem that it once was.

In the event of the Fire Service and Ambulance service vehicles requiring to attend the site in an Emergency, during the wet winter months, the poorly drained and waterlogged fields may well present a serious problem for the vehicles traction.
Impact on the Neighbourhood.

The intention is to use the created horse manure as agricultural fertiliser. This is usually created by allowing the horse manure to rot down on site.
The rear gardens of Holland Avenue, being just 70 metres away will most likely be affected by the smells emitting, especially during the warmer months when residents will expect to be able to leave windows and doors open to enjoy the fresh air, but would likely be prevented from doing so.

1998 Adopted Local Plan
RE11 (iii) BE DETRIMENTAL TO THE RESIDENTIAL AMENITIES OF NEARBY PROPERTIES BY VIRTUE OF NOISE, SMELL OR GENERAL DISTURBANCE. (my emphasis) And further; “would be likely to cause danger to other road users” by means of unsuitable entry access.

IMG_0156 (2)

Canvey’s Dutch Village GB site back under Threat? Castle Point bc, not only can we produce a sound Local Plan, but we can do so at High Speed! “Watch this Space” indeed!

Short-termism appears to be the “Get Out” approach for Castle Point Borough Council to appease the Government’s intervention team.

Despite no Local Plan emerging over the past 20 years, the latest approach appears to be to crash out an interim 10 Year Plan including Green Belt development sites allocation, and hope for the best that normal service will be resumed with the assistance of our neighbouring Boroughs!
shutterstock_boot_crushing_man

The questions are, which Green Belt sites will be sacrificed in the rush to develop, and which Green Belt sites will developers actually agree with cpbc to build on?

Certainly potentially in the region of 900 dwellings are being installed at Canvey Island’s Sandy Bay, but the distinct threat remains that Canvey Island’s Dutch Village is also cpbc’s preferred Green Belt site in danger of development!

The opinion of outsiders is always useful to keep our feet on the ground, and to help us with that Planning Resource publication have produced their view of the position Castle Point council currently find themselves in, ahead of the secretary of State’s decision on whether cpbc are now trusted to be allowed to produce their own Local Plan under the watchful eye of Government.

As we know a greatly truncated approach has been adopted as the preferred approach of our Borough council, as a means of warding off Intervention in the Plan making process.

CPBC’s interpretation of the situation is directly below, whilst further below is how the “trade” press’ view.

“the Government has confirmed that it will intervene in plan-making in areas where councils without a post 2004 local plan have not submitted a plan for consideration by the Planning Inspectorate. This will reduce the control the local planning authority has over such matters. In March 2018, the Council received a letter from the Secretary of State for Housing, Communities and Local Government confirming the intention to commence Intervention in the Castle Point Local Plan. As of June 2018, the form of this Intervention had not been confirmed, but dialogue with the Ministry has confirmed the need for a Local Plan to be prepared to an accelerated timetable, and this Plan must focus on bringing forward new homes in the early part of the Plan period.”

“The Local Plan will tackle contentious issues that could give rise to significant public opposition. Whilst every effort will be made to build cross community consensus, there remains risk of significant public opposition to the Local Plan proposals.”

“Logistically this could cause a higher volume of work in the processing and analysis of representations than accounted for in the LDS timetable, which could set it back.”

“To help reduce this risk, responses from the 2014 and 2016 draft Local Plan consultations will be used to assess public opinion. The 2014 and 2016 draft Local Plans will form the majority of the new Local Plan so previous consultation responses as well as updated evidence will help inform the Plan.”

“In February 2017, the Government introduced the proposition that all Local Planning Authorities (LPAs) be required to prepare a ‘Statement of Common Ground’ (SCG) to help manage strategic planning matters across local authority areas and strengthen the Duty to Cooperate”

“3.5 Castle Point
Castle Point is a relatively small local authority area just 4,500 hectares in size, with a population of 88,000 people. It sits at the heart of the South Essex sub-region on the northern bank of the Thames Estuary between the larger settlements of Basildon and Southend. It is these larger settlements, along with London, on which Castle Point relies for its employment, services and leisure opportunities.
The key planning issues comprise:
• the challenge of meeting housing need in a borough of significant Green Belt and other environmental constraints and where land availability is confined to small scale infill sites in the built-up area;
• the need to improve infrastructure to address congestion, historic underinvestment and provide capacity for growth;”

“9.1
Castle Point currently has no up to date local plan in place and has therefore been subject to potential government intervention. The Council will therefore prepare an interim local plan covering the next ten years and focusing on planning for housing, with the ambition of meeting local housing needs in this period. In the longer term, local housing needs will be considered through the strategic assessment and allocations prepared for the JSP.”

“The current estimated need for housing across South Essex is 90,000 dwellings over the next 20 years, but with the right conditions to support growth, more could be achieved. As part of the consideration of long term spatial options, the authorities are therefore exploring whether the development of new ‘Garden’ communities could offer a strategic solution to growth.”

“The South Essex Authorities estimate that up to 4,500 new homes will be needed each year to meet housing needs.” *

Planning Resource publisher’s opinion of the situation Castle Point find our / themselves in are reproduced here;

A group of seven Essex councils this month published a draft statement of common ground (SCG) designed to make sure they meet the challenging duty to cooperate. The statement commits them to preparation of a formal joint strategic plan for a green belt-constrained area where local plan processes have been hobbled by an inability to resolve local opposition to much-needed new homes.

The statutory joint plan is being pursued by six districts and boroughs – Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea and Thurrock – and Essex County Council. At the start of the year, they formed the Association of South Essex Local Authorities (ASELA) to formalise joint working arrangements. According to the SCG, the joint plan will provide an “overarching framework within which more focused local development plans will be prepared”.

Requiring unanimous approval from all seven councils to go forward, the joint plan will set out housing targets and distribution as well as key employment sites and infrastructure priorities. Its prime purpose, commentators say, will be to decide where to find space for the required 90,000 new homes in south Essex over the next 20 years, given significant green belt constraints.

Consultant Catriona Riddell, who is advising ASELA, said: “With the area’s large proportion of green belt, all the authorities have challenges in terms of meeting housing needs, so they have decided that looking at strategic growth areas across south Essex would be the most deliverable and sustainable option.”

Nick Davey, partner at Brentwood-based planning consultant JTS, said determining housing allocations has been a big problem. “I feel sorry for the planners,” he said. “They have to try to meet objectively assessed need and that means releasing green belt, but they just can’t get members’ buy-in. All that’s happened since the 2012 National Planning Policy Framework is procrastination.”

The draft SCG doesn’t grasp this nettle.

Instead, it identifies five “strategic areas of opportunity” where housing may be located, all of which straddle local authority boundaries and thus leave exact allocations undetermined.

Riddell said the body has now commissioned a strategic growth study to further develop these proposals. “Some authorities will ultimately have to take a disproportionate share of the homes – those are the issues we haven’t got to yet. They need to stick together like glue,” she said.

The joint plan comes in the context of delays in local plan preparation led to three of the districts – Basildon, Brentwood and Castle Point – being threatened with intervention by former housing secretary Sajid Javid last year for their slow progress. In March, Javid pressed ahead with sending a government team in to scrutinise Castle Point’s local plan preparation arrangements. He told Brentwood and Basildon they’d face no further action, but warned he’d keep a close eye on them.

Castle Point’s last attempt at a local plan, which left 300 of its 400 homes-a-year housing need unmet, was withdrawn last year after failing the duty to cooperate. It is now seeking approval from the government to develop an interim local plan covering just five to ten years, allowing it to avoid large green belt allocations and leaving responsibility for further allocations to the joint planning process.

Riddell said: “The vital thing is that any intervention doesn’t compromise the joint planning effort by forcing Castle Point to release green belt that, from a wider south Essex point of view, might not be in the right place.”

Some fear, however, that the joint plan process will be used to justify continued delay. Tony Collins, owner of consultancy Collins & Coward, said: “Joint plans take a long time to draw up and even longer to deliver. The government wants delivery but joint planning is only going to slow things down.”

Riddell recognised government fears that the joint plan promises “jam tomorrow”, but pointed out that the SCG, once approved, will commit the ASELA authorities to an “accelerated timetable” that will see a draft plan consulted upon early next year, with submission for examination a year later. “It’s really fast,” she said. “These concerns are totally unfounded.”

* 6 Jun 2018 – Special Meeting of Castle Point Borough Council agenda appendices.