Tag Archives: Environment Agency

Dates, Canvey Islanders won’t even Notice! Thorney Bay’s, on its way!

Canvey Islanders, it is said, haven’t the nous to have a cynical thought cross their little minds.

Firstly, following the Election announcement on the very last day prior to the period of Purdah commencing, the Jotmans Farm Appeal Inquiry was Rejected by the then Secretary of State, thereby saving important mainland Green Belt from development.

Secondly, tomorrow, 6.6.2017, just 2 Days prior to the General Election, castle point council development committee will decide the Recommended Approval “first phase” of the Thorney Bay vast green field development, on Canvey Island.

Thorney Bay Beach Camp, Canvey Island, Essex

copyright Jason Hawkes

This so called first phase at Thorney Bay amounts to 113 new dwellings.

The development committee Agenda paperwork indicates officers advise :

It is not considered necessary for Members to visit the site prior to determination of the application.

This despite :

To the north of the site is the Local Wildlife Site (LoWS) Thorneyfleet Creek, which comprises a water body with Common Reed and rough grassland; beyond this is residential development. To the east is Public Open Space, in the form of a grassed area and children’s play space. To the south and west is the wider expanse of the Campsite. A water treatment works lies to the west of the wider site and beyond this is the Calor gas terminal. To the south is the Canvey Island Sea Defence, beyond which is the River Thames.

Of the Health and Safety Executive’s comment;

..more than 10% of the housing development area lies within the (Calor Gas Hazardous) middle zone….and HSE Advised Against Granting Planning Permission.

The HSE then go onto excuse the proposed development layout, stipulating that castle point council must not in future use the self regulating facility, instead be referring any future development directly to the HSE!

The Case Officer comment, which will no doubt be pointed out to the planning committee members in the Agenda Paper states; 

Health and Safety Executive  No objection.

As far as potential flooding is concerned, especially as the site is directly reliant on the Canvey Sea wall Defences;

Environment Agency  No objection: following the receipt of a revised FRA, subject to conditions and the satisfaction of the LPA that the proposal will be safe for its lifetime

It should also be noted, should the are become flooded yet again that responsibility has been relieved of the Leal Local Flood Authority (Essex CC.);

It is the applicant’s responsibility to check that they are complying with common law if the drainage scheme proposes to discharge into an off-site ditch/pipe. The applicant should seek consent where appropriate from other downstream riparian landowners. 
The Ministerial Statement made on 18th December 2014 (ref. HCWS161) states that the final decision regarding the viability and reasonableness of maintenance requirements lies with the LPA. It is not within the scope of the LLFA to comment on the overall viability of a scheme.

But of course the Rumours emanating from CPBC is that Thorney Bay will become a Park Home site, So None of these Rules Will Apply!

1,600 static caravans could quite easily become 1,000+ Park Homes, and there is the next Local Plan’s 5 Year Housing Supply.

Let existing Canvey Island residents and future property owners be warned!

We make no apology for over-simplifying these issues but for anybody interested the webcast and recording should be available via;  https://castlepoint.gov.uk/webcasting

The meeting Agenda papers are available via; https://www.castlepoint.gov.uk/agendas-minutes-library

 

Thorney Question of Over-developing a Small Island in Castle Point!

Given that there is a possibility Canvey Island may suffer another Tidal Flood, given that we may again suffer from Surface Water Flooding as in 2013 and 2014, given that there may be another leak of LPG from Calor Gas, given that OIKOS have been granted permission by CPBC to increase activities in the importation, storage and blending of butane, and however small the risks, should not the Distribution of Housing Growth as imposed by Castle Point Borough Council (cpbc) be called into serious Question? *

Already there are over 38,500 residents on Canvey Island. If there were to be a major incident from just one of these four sources, an Evacuation of the Island, given the population level, the lack of access / egress routes and there being No Means of Warning, would be an impossibility. Is it time to cap the population level? We believe it is!

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Rather than accepting these “dangers” the powers that be at cpbc, appear to have their eyes and ears covered to blot out the concerns of the population on Canvey Island exposed to possible incidents in the desire to offset Housing and Business development away from the controlling mainland part of the Borough. Little wonder there is an active group hoping to convince the Boundary Commission to leave the Borough’s borders alone!

The denial of Climate Change, the absolute faith in our sea defence, the faith in the “hard work” undertaken to “maintain” the Island’s drainage system and the assurances from the two Top Tier COMAH sites, amount to little more than roll off the tongue Platitudes!

We stand accused of scare-mongering, then so be it!

We call it living in the Real World and “facing” realities. Fore-warned is Fore-armed.

Canvey’s highway infrastructure is restrictive, all routes converging at Waterside Roundabout, meaning evacuation is impossible and our limited Fire and Rescue cover means response times for assistance are likely to be prolonged.*

Green Belt is protected in planning terms by the Very Special Circumstances needed before the consideration of any development proposal.

Consider that, against a development proposal within a Flood Risk Zone and within the Consultation Distance of a Major Hazard site!

This is what requires not only for planning considerations, but also leading council members and officers to consider their consciences, with the proposal to develop 113 dwellings at Thorney Bay, Canvey Island.

This is only the first phase of a major development consisting of “approximately 600 dwellings” plus “Park Homes.”

The cpbc planning portal indicates that the developer may have overcome, to cpbc’s satisfaction, the requirements of the HSE, the Environment Agency and Essex County Council, the surface water drainage experts.

However these agencies lifting of Objections should not be seen as them giving their Approval!

In fact their concerns indicate that they Do Not Rule Out the Possibility of one or other Incidents occurring in the Future!

Within their comments they give very distinct warnings and concerns and indicate quite clearly the final decision and the Responsibility is Castle Point council’s ALONE!

Below are a few of the consultee agencies points of concern over the Thorney Bay proposal and further below are links to some previous incidents etc of some interest.

The Environment Agency state;

Our role is to provide you with our assessment of the risk for matters within our remit so that you can make an informed decision

“The FRA (flood risk assessment) proposes no detriment in off-site flood hazard for the design and extreme floods and manages this via a proposed embankment, subject to condition.”  Approval of the design of the proposed embankment is therefore necessary as a pre commencement condition, as the embankment is essential to safeguard against the offsite impacts. Without the construction of the embankment off site impacts would be seen

Provided you consider the development meets the requirements set out in the NPPF, including that it is safe for its lifetime and does not increase the risk of flood risk off site, we request that the following conditions are appended to any permission granted. Without these conditions our objection will be maintained.

Flood Risk Responsibilities for your Council    

We have not considered the following issues as part of this planning application as they are not within our direct remit; nevertheless these are all very important considerations for managing flood risk for this development, and determining the safety and acceptability of the proposal. Prior to deciding this application you should give due consideration to the issues below. It may be that you need to consult relevant experts outside your planning team.     

Safety of the building 

 Safety of People (including the provision and adequacy of an emergency plan, temporary refuge and  rescue or evacuation arrangements) 

Flood recovery measures (including flood proofing and other building level resistance and resilience measures) 

Whether insurance can be gained or not

Sustainability of the development – we advise you consider the sustainability of the development over its lifetime.

Your attention is brought to the proposed Roscommon Way Extension that is likely to pass immediately to the south of this proposed development site. Consideration is required of residual tidal flood risk at a master planning level to evaluate if further proposed phases of the Thorney Bay caravan park development could become less deliverable, unless suitable mitigation measures are identified and designed, with regards to breach characteristics – mainly depth, time to inundation and hazard ratings. Future proposed Flood Risk Vulnerability Classification will need to be considered alongside the residual tidal flood risks to ensure a sequential approach to future site layout is maintained.

 

ECC Lead Local Flood Authority position;

Having reviewed the Flood Risk Assessment and the associated documents which accompanied the planning application, do not object to the granting of planning permission.

Condition 1

 No works shall take place until a detailed surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development, has been submitted to and approved in writing by the local planning authority. The scheme should include but not be limited to:

  • Final modelling and calculations for all areas of the drainage system.
  • A final drainage plan which details exceedance and conveyance routes, FFL and ground levels, and location and sizing of any drainage features.

Reason:

  • To prevent flooding by ensuring the satisfactory storage of/disposal of surface water from the site.
  • To ensure the effective operation of SuDS features over the lifetime of the development.                 
  • To provide mitigation of any environmental harm which may be caused to the local water environment                                                                                                                                                            
  • Failure to provide the above required information before commencement of works may result in a system being installed that is not sufficient to deal with surface water occurring during rainfall events and may lead to increased flood risk and pollution hazard from the site.

Condition 2

 No works shall take place until a scheme to minimise the risk of offsite flooding caused by surface water run-off and groundwater during construction works and prevent pollution has been submitted to, and approved in writing by, the local planning authority.

Reason

 The National Planning Policy Framework paragraph 103 and paragraph 109 state that local planning authorities should ensure development does not increase flood risk elsewhere and does not contribute to water pollution.

 Construction may lead to excess water being discharged from the site. If dewatering takes place to allow for construction to take place below groundwater level, this will cause additional water to be discharged. Furthermore the removal of topsoils during construction may limit the ability of the site to intercept rainfall and may lead to increased runoff rates

Health and Safety Executive state;

More than 10%of the housing development lies within the middle zone, – through the HSE Planning Advice Web App advised Against the granting of Planning Permission.

However, having given more detailed consideration, HSE has concluded that it is appropriate for HSE to provide case-specific advice on this proposal outside of the codified planning methodology provided.

The layout indicates that a total of 30 dwellings at a housing density of 38 dwellings per hectare within the middle zone.

HSE’s advice is that significant housing should be prevented from being built in the inner zone and only a limited number of houses at a low density.

The overall objective is to maintain the separation of incompatible development from the Major Hazard.

HSE would advise Against any planning application which seeks to locate any additional dwellings within the middle zone of Calor Gas Ltd.

Instead of using the HSE Planning Advice Web App, Castle Point Borough Council should therefore consult HSE directly for advice on any future planning applications which propose further residential development at Thorney Bay Park within the middle zone of Calor Gas Ltd.

*Below are links to;

*Reduction in Essex Fire and Rescue Service cover view HERE

*Calor Gas Leak court decision view HERE

*OIKOS permission granted view HERE

Editor. It should be pointed out that any emphasis included in the text is the author’s.

 

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.

 

Time to brief our MP? Canvey Island at the forefront of Flooding Issues, whilst CPBC covers up?

The National Flood Forum tweeted

“A great opportunity to get communities’ flooding issues debated. Time to brief your MP and ask them to participate.”

This was the Forum’s reaction to an announcement by The House of Commons Environment, Food and Rural Affairs Committee:-

We’ve secured a debate in the Chamber on 27 Feb, pending the House’s agreement tonight, with on our flooding Reports

Regarding the now regular Flooding Events that occur in the UK, much has been spoken, reported and recorded. Monies have been promised and Budgets have been set.

Nothing matches the Flooding Prevention approach and outlay committed in the Netherlands.

However locally in Castle Point, the situation appears worse still.

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There exists what may be a false sense of security concerning the perceived infallibility of the Sea Defences. The seeds of apathy have manifested from residents being comforted by the Defences being the very “best in the Country”!

The Environment Agency’s view regarding the Canvey Sea Defences is;

” 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 occurring is low, the consequences should it happen would be very high.”

Climate Change and Rising Sea Levels mean that the Sea Defences will require improvements to the current standards before the year 2100.

In February 2015 a Commons Select Committee conceded;

“The Environment, Food and Rural Affairs Committee queries Government plans to attract £600 million from external funders to bolster flood defences. In its report on Defra Performance in 2013-14, the cross-party Committee cites low levels of private funding attracted to date as a cause for concern about ambitious future plans.”

This matter was tentatively raised, and disputed by the applicant, during the Thorney Bay Application in Principle to redevelop the Caravan Park. A sum of around £100,000 was suggested as being appropriate contribution towards the necessary future Sea Defence Improvements by the applicant.

Since then, enquiries by the Canvey Green Belt Campaign group have revealed that Castle Point Council officers concede they have no mechanism in place for the collection of such Funds. Consequently no request towards the necessary external funding has been made by cpbc during the consideration of the application for the First Phase of the Thorney Bay development!

This further undermines the attempts by Defra and the Government to implement the Aspirations of the TE2100 (Thames Estuary) Plans for Canvey Island.

The Surface Water Flooding of Canvey Island during 2013 and 2014 were severe enough to warrant the Government Office for Science to undertake a Peer review of Essex County Council’s report on the Canvey Island flooding in July 2014.

The Government Office for Science Peer Review can be found HERE.

The Essex County Council Report into Canvey Island Flooding 2014 can be found HERE.

The Environment Agency consider the Canvey Island Drainage System as being “complicated”.

It is reliant on Gravity, as the Island is so flat, for water to reach the Pumps that are installed to transfer surface water to the Thames Estuary.

These pumps will not cope with the levels of water should there be Tidal Flooding, and failed during the 2014 Flooding event, requiring improvements to the mechanisms.

Maintenance is a continual requirement to Drains and Ditches. The Environment Agency and Essex County Highways division are affected by ongoing budget constraints, meaning Maintenance may be insufficient at any particular time.

These issue were all revealed during the report and enquiry following the 2014 flooding.

Alongside the Essex County Council Report and the Government Office for Science Peer Review, Castle Point Council’s Scrutiny Committee held a series of meetings during 2014 and earl 2015, to investigate the effects, the impact, the response and the causes of the Canvey Island Surface Water Flooding event.

The Castle Point Council Scrutiny Committee’s Report into the Canvey Island Flooding of 2014 remains Unpublished!

The Castle Point Council Webcasts of the Scrutiny Committee meetings are now unavailable!

Neither the Essex County Council Report into the Canvey Island Flooding of 2014, nor the Government Office for Science Peer Review are included within the cpbc Local Plan2016 Evidence Base! 

The Canvey Island Integrated Urban Drainage Study, is included in the cpbc Local Plan2016 Evidence Base in the form of a desk top published aspirational leaflet!

No Fund gathering mechanism is in place to collect the required External Funding for the future improvements of the Canvey Sea Defences.

In response to the National Flood Forum’s suggestion “Time to brief your MP and ask them to participate,” there appears plenty of concerns for our Local representatives to be lobbying our MP Rebecca Harris to participate over!

Canvey Island Population set to grow despite, ASPIRATIONAL Sea Defence improvements and Flood Re Insurance being unavailable!

A “proposed” new development of Flats for Canvey Island that WILL receive Approval from Castle Point Council reveals 3 serious issues.

Firstly it is correct to point out that the proposed Flats are in the Canvey Island town centre, and if anywhere is to be developed here is more appropriate so as to assist the regeneration of the town centre Retail outlets, under threat from out of town local authority preferences.

The first issue is the continued increase in population in the Flood Risk Zone of Canvey Island. Castle Point councillors and officers appear to be relaxed and show little moral concern in locating more and more people into an area at some risk of both surface water and tidal flooding.

Secondly a point given no relevance by the same Castle Point members and officers is that Canvey Island, being a FLOOD Plain is reliant on its sea defences.

 

sea wall damage

Previous damage acts as reminder of the Tidal power.

 

These sea defences will need to be raised and improved prior to the year 2100, as clearly explained by the area’s Strategic Flood Risk Assessment, to prevent potential over-topping! The potential for a breach in the defences remains.

Whilst the Environment Agency, recognising Canvey Island is a “special case”, emit the music to Castle Point’s ears “have no objection to the proposals”, however in this case feel it of the most importance to make very clear to our Local Authority the uncertainty that faces Canvey Island’s sea defence!

The EA warns;

“The TE2100 Plan is an aspirational document, rather than a definitive policy, so whether the defences are raised in the future will be dependent on a cost benefit analysis and the required funding becoming available.”

“When determining the safety of the proposed development, you should take this uncertainty over the future flood defences and level of flood protection into account.

This may require consideration of whether obtaining the funds necessary to enable the defences to be raised in line with climate change is achievable.”

Thirdly, much has been said about the benefits and protection that the Flood Re insurance scheme delivers. However this scheme will NOT benefit residential properties built post January 2009!

As a director of the Flood Re scheme pointed out to the Canvey Green Belt Campaign group, the idea of the insurance scheme is NOT to encourage development in Flood Zones!

Going by previous development committee meetings you will not hear these 3 matters discussed. Officers will make a strong point of informing members that the Environment Agency “have no objection to the proposals”.

Consequently, the level of population of Canvey Island at Risk from Flooding, continues to Grow!

Neither Tidal nor Surface Water Flood Risk a Constraint on Development, where Castle Point Council are concerned!

The issue of potential Flooding remains a Hot Topic. That is as it should be, however as we have seen within Castle Point Council it only acts as a Development Constraint verbally, rather than effectively.

The responsibility on Flood Risk should fall squarely on the shoulders of council members, but other interests and “fear” of scaremongering, in effect mean that Flood Risk as a Constraint on Development is disregarded.

Floods 2014 pic via Police Helicopter

View of Canvey Island flooding from Police Helicopter July 2014

The Environment Agency adopt a position where residents safety over the lifetime of a new development is left to council members, Canvey Island and mainland residents Representatives.

The EA consider;

“The site is currently protected by flood defences so is not at risk of flooding in the present-day 0.0% (1 in 1000) annual probability flood event. The defences will continue to offer protection over the lifetime of the development, provided that the TE2100 policy is followed and the defences are raised in line with climate change, which is dependent on future funding.” 

The Island’s Flood Risk Assessment confirms over topping will be a concern prior to the year 2100!

There are no guarantees of this future funding and residents may be surprised to know that much of this funding must be raised locally. Councillors should be in a position to inform us of the sources of this funding and of the avenues in place for the collection of these monies, if they are confident that the sea defences will receive the necessary improvements so as to have confidence any new builds that they approve, will be safe over its Lifetime!

The EA give further warning;

“Although Canvey Island is defended to a high standard of protection, it is at risk should there be a flood defence failure” 

Of course the official position of cpbc appears to be that as long as there is space provided for safe refuge areas above the ground floor, development is acceptable.

A somewhat contradictory position in respect that if Canvey Island could not Flood, the safe refuge requirement would be un-necessary.

Government and Defra continue to fumble about giving residents no security whilst planners and developers take advantage of the lack of a clear position.

The BBC Report;

The Commons environment committee said ministers were not addressing what it called the fragmented, inefficient and ineffective flood management.

Areas of concern include flood impact home insurance, building rules and local authority planning decisions.

The government rejected the criticism, saying it had accepted many previous suggestions on flooding from the MPs.

The committee’s comments are the latest in a running tussle between MPs and the environment department Defra.

 The MPs admit that flooding has risen up the government’s priority list, and say “considerable work” on flooding is being done across Whitehall. But they complain that ministers are still ignoring reasonable demands.

Jim Fitzpatrick MP, acting chair of the Environment, Food and Rural Affairs Committee (Efra), said: “People living in areas of flood risk need to be reassured that the government is acting to improve our disjointed flood management system.

“Defra has failed to give sufficient justification for its rejection of our recommendations for important new measures.”

Continued development also increases pressure on Canvey Island’s drainage system, already capable of failure through misuse and lack of maintenance. Housing and Business development means Roads, Parking areas and hard impermeable surfaces intensify this issue as development approvals continue unabated.

This move to develop more and more areas of grass land on Canvey must be considered in the light of it inevitably increasing the likelihood of Surface Water Flooding, a warning of this issue is contained in a Research paper by Dr David Kelly. Its relevance to Canvey Island should be considered Striking!

It should be remembered that, whilst the sea defences have some ability to stop the Tide from over topping, they have absolutely no effect in stopping the Tidal Water from penetrating the ground from beneath, and causing flooding and a High Water Table by that means!

Impact of paved front gardens on current and future urban flooding” Research Paper by Dr D.A.Kelly

The proliferation of paved gardens is putting the UK’s towns and cities at greater risk of flooding and, by 2080, the UK’s urban drainage system could be overwhelmed by ‘runoff’ equivalent to the volume of up to 100 Olympic-sized swimming pools.  

The potential impact that paved gardens could have on urban flooding in Edinburgh, Exeter, Manchester and London by 2050 and 2080 was examined by Dr David Kelly, associate professor in Heriot-Watt’s Water Academy. 

Many gardens in the UK have been paved by homeowners who want low maintenance gardens or off-street parking. Covering traditional gardens with hard paving, and the subsequent loss of green vegetation, reduces the amount of rainfall that can be dealt with naturally and significantly increases the rate and volume of runoff flowing to surface water drainage systems. 

Dr Kelly applied projected rainfall intensities for each of the four UK cities to simulated front gardens that reflect the trends for paving. 

Calculating the runoff contribution from new and existing paved gardens will help planners and policy makers identify areas of risk in their town and city – and decide whether to call for homeowners to depave. Additionally, data of runoff from individual paved gardens could highlight the need for behaviour change, and help encourage homeowners to take action themselves by depaving their gardens and enhancing green vegetation.

Dr Kelly, assistant professor in Heriot-Watt University’s Water Institute said: “Domestic front gardens cover almost 30% of our urban space and play a vital role in managing surface water runoff in towns and cities. 

“Existing urban drainage systems will be inadequate to cope with the level of increased runoff from paved front gardens. With runoff from all impermeable surfaces, including paved front gardens, likely to increase in future due to urban densification, the risk of urban flooding will increase unless substantial efforts are made to minimise runoff.”

Homeowners and policymakers need to focus on depaving gardens across the UK.

Dr Kelly’s research showed that the collective runoff by the 2080s from front gardens alone is expected to increase by substantial amounts during extreme storm events due to climate change. 

“In Edinburgh, considering only gardens that are currently at least three-quarters paved, during just one storm, runoff could increase to 29,000m3 across the city, equivalent to 12 Olympic swimming pools, by 2080.”  

“In London, the volume of runoff could increase up to as much as 278,000m3 (equivalent to 100 Olympic swimming pools). ” 

“But, if all of these gardens were depaved and had zero impermeable cover, then the runoff could almost be eliminated, particularly if combined with enhanced green vegetation solutions.”

 D.A.Kelly’s research paper; “Impact of paved front gardens on current and future urban flooding” can be found HERE

The full BBC Environment Parliamentary Report can be found HERE.

 

 

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.