Tag Archives: Exception Test

China Crisis = Answer to Canvey Island issues? Or – Castle Point’s Broken Local Plan Process “the continued development of Canvey Island is necessary”???

“The continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement.”

So say, Castle Point borough council planning officers in their programmed approach to avoiding objections to each and every proposal for development on Canvey Island.

This programmed response, supporting perpetual development, is in respect of evading opposition and objection to the “Special Case” position the officers are ordered to adopt in consideration of Canvey’s Flood Risk Exception test.

Whilst Constraints on development in other areas of the borough are sited and strictly adhered to, as a matter of policy, similar approach to Canvey Island proposals appear less rigorously imposed.

Given that Canvey development should be constrained by the fact that the Island is a tidal Flood Risk Zone 3a area, is now deemed a Critical Drainage Area following the surface water flooding during 2014 and previously, as well as being the location of 2 Top Tier Comah hazardous industrial sites.

That there is only one access / egress point, that the Island’s dedicated Rapid Response (paramedic) Vehicle is being withdrawn and that, like other areas the Police and the Fire and Rescue service presence has diminished.

These factors, one would think given Canvey Island’s geographical position, may cause outsiders to wonder why castle point borough council planning department should be so manipulative, when they recite such Unsound Drivel as “the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement”!

Higher up the local government ladder the planning department superiors have indentified in contrast, that on tidal Flood Risk alone, they consider that the population of Canvey Island should be limited to the level prior to 2011, OR LESS!

However cpbc Cabinet, Councillors, Officers and Planners ALL choose to ignore this apparently sensible and cautious approach to Housing Numbers, one can only assume, so as to limit the levels of apparently necessary, but unpopular, Housing Need elsewhere in the Borough!

Now whilst our local “public servants” propose and impose yet more development, both Housing and Industrial, onto Canvey Island under the pretext that, “the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement” they would do well to appreciate what is going on far from here.

Local decision makers, in their desperation to support the Borough’s income stream and limit the perceived Housing Need on the mainland, are willing to overlook potential Hazards and Constraints that should, by Rights, limit the ever-increasing Canvey Island Population Growth, through the means of our broken Local Plan process!

This Blindfolded and Wreckless approach to Development Planning on Canvey Island, has directly led to the flooding of many properties during 2013 / 2014, and is continued unabated, despite the clear warning towards adoption of a more cautious approach following the Calor escape of 163 tonnes of liquified gas forming a  vapour cloud over the Island!

Whilst the efforts of the Essex Fire and Rescue Service to convince cpbc members that their vastly reduced level of cover for Canvey Island would be adequate in the event of a major accident at either of the 2 Hazardous sites, their claim should not serve as supporting evidence for continually increasing the Population of Canvey.

Castle Point, we believe, would be totally justified in adopting a Limited Population Approach to its Housing Supply through its Local Plan Process, especially where Canvey Island is concerned.

This approach would be fully justified and would protect local builders and developers alike.

An ever-increasing population has little or no justification in any of the reasons recited by cpbc in its flimsy evidence to direct the levels of development growth towards Canvey Island, indicated in their various versions of failed Local Plans .

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It is Amazing then to discover that a Far Eastern Country should have adopted a Plan that puts concerns for its Population and Environment first, by recognising the Need to Limit Population Levels.

Whilst we do not compare the population levels of Shanghai and Canvey Island, it does indicate that limiting population, rather than the contrived reasoning behind the proposal for the ever-increasing population numbers policy, as applied by Castle Point Council Strategic and Local Planners!

 “China’s financial hub of Shanghai will limit its population to 25 million people by 2035 as part of a quest to manage “big city disease”, authorities have said.

The State Council said on its website late on Monday the goal to control the size of the city was part of Shanghai’s masterplan for 2017-2035, which the government body had approved.
“By 2035, the resident population in Shanghai will be controlled at around 25 million and the total amount of land made available for construction will not exceed 3,200 square kilometres,” it said.
State media has defined “big city disease” as arising when a megacity becomes plagued with environmental pollution, traffic congestion and a shortage of public services, including education and medical care.

But some experts doubt the feasibility of the plans, with one researcher at a Chinese government thinktank describing the scheme as “unpractical and against the social development trend”.
Migrant workers and the city’s poor would suffer the most, predicted Liang Zhongtang last year in an interview with state media, when Shanghai’s target was being drafted.

The government set a similar limit for Beijing in September, declaring the city’s population should not exceed 23 million by 2020. Beijing had a population of 21.5 million in 2014. Officials also want to reduce the population of six core districts by 15% compared with 2014 levels.
To help achieve this goal authorities said in April some government agencies, state-owned companies and other “non-core” functions of the Chinese capital would be moved to a newly created city about 100 kilometres south of Beijing.
An exact date for when those offices will have to move has not been set, but Beijing officials have already begun reshaping the city’s population.

Tens of thousands of migrant workers were evicted from their homes beginning in November, after authorities launches a 40-day crackdown on unsafe buildings in the wake of a fire.
Many of China’s biggest cities also face surging house prices, stirring fears of a property bubble. Beijing and Shanghai have enacted strict rules on who can purchase property and the two cities are the most vulnerable if prices begin to tumble.
Shanghai had a permanent population of 24.15 million at the end of 2015, the official Xinhua news agency said last year.
The city has also said it would intensify efforts to protect the environment and historic sites as part of its masterplan.” *

As a further reminder, we make no apologies for reminding readers of the devastating effects on households Hazardous Accidents have the potential to cause, as seen in this Video recording.

Grateful thanks go to Ian Silverstein for use of his video.

*Report filed for the Guardian by; Benjamin Haas in Hong Kong and agencies
@haasbenjamin
Tue 26 Dec ‘17
Reuters contributed to this report

And for those who have read this far, here is a link to some music – China Crisis’ recording of “Wishful Thinking”.

We thought the title appropriate!

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RECOMMENDATION, – CAUTION! No, the Continued Development of Canvey is Necessary!

In March, this year, Castle Point Borough council cabinet addressed what at the time was one of the hottest topics facing the UK. Termed by our own government as our “broken housing market” invitations went out to consultation on the white paper.

Little can be found, via a general internet search, of castle point council’s response.

Following the “successful” approval of 113 dwellings on Canvey Island, 30% of which fall within what is known as the Calor Gas Hazardous middle zone by the development committee, we were soon all feeling appalled at the scenes of disaster at Grenfell House in Kensington.

Whether it is correct to connect any possible similarity between poorly located housing and a disaster through whatever reasons that come to fruition in a tower block, may be arguable.

However an early suggestion as to the tragedy at Grenfell House suggests “the organisations responsible for maintaining standards in the building industry have been advising contractors not to take the regulations too literally.”  *

Whilst this claim requires some substantiation, the application of the Environment Agency and the Health and Safety Executive’s advice where Canvey Island development is concerned, as applied by Castle point council, equally is in need of some serious scrutiny!

We, ourselves are used to being called scaremongers, but quite possibly so were some concerned residents near Buncefield, and those users reliant of the rail line through Dawlish, where the section of sea wall collapsed under the rail track in 2014, may have also been grateful of a more cautious approach to safety.

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Damage to the railway at Dawlish in Devon

The lack of brownfield land in Castle Point is obvious. It is also reasonable to expect Green Belt to be protected.

However Canvey Island is subject to perverse considerations by Planning Officers, no doubt instructed from above, or to put another way, from back offices and corridors!

Housing on Canvey Island must pass the Sequential and Exception Test (Look it Up yourself!)

This allows development in areas that NOBODY can guarantee safe for the development’s lifetime. You would have to be Psychic!

The excuse, sorry, reason, given is:

“In a very broad sense the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement.”

Strange, I have never heard or seen any concern of social and economic blight used to support a Reason to Support development where the mainland is concerned! Remember Deanes School??

But Canvey, don’t forget, is a “Special Case!”

Soon a Brownfield site list of local authority owned land will be compiled, just imagine it; the Paddocks, Canvey police Station, the old council building now Health Centre Long Road etc etc.

It is clear why Canvey is so often selected for development over mainland.

The Island is unsustainable as it is, so to it will be argued is the mainland, but Canvey is the council’s preferred choice.

On 7th February 2017, the Government published a White Paper concerning housing related matters, entitled “Fixing our broken housing market”.

Cabinet Agenda Item7a March 2017:

CPBC intention to respond to “Fixing our broken housing market” Government Consultation on Housing White Paper

The report identifies the problem as threefold – first, not enough local authorities plan for the homes needed, secondly house building is too slow, and thirdly the house building industry is too reliant on a small number of large concerns.

4.4 The report then analyses these issues and brings forward proposals to address them in four chapters;

  1. Planning for the right homes in the right places
  2. Building homes faster
  3. Diversifying the market
  4. Helping people now

Chapter 1 – Planning for the right homes in the right places – brings forward eight proposals;

“Maintaining existing strong protections for the Green Belt, and clarifying that Green Belt boundaries should be amended only in exceptional circumstances when local authorities can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirements;”

“Giving communities a stronger voice in the design of new housing to drive up the quality and character of new development, building on the success of neighbourhood planning”

“Making more land available for homes in the right places, by maximising the contribution from brownfield and surplus public land, regenerating estates, releasing more small and mediumsized sites, allowing rural communities to grow and making it easier to build new settlements;”

In addition to those general comments the Cabinet is recommended to allow more detailed responses to the 38 questions posed by the White Paper to be issued by the Chief Executive in consultation with the Leader of the Council by the deadline of Tuesday 2nd May 2017.                        (abridged version)

Given cpbc’s previous History where development is concerned, we are left to wonder how seriously the government will take our local authority’s consultation responses. As I have said previously, a quick search for cpbc’s official response fails to be found.

*BBC Newsnight Policy Editor Chris Cook.

Photo: Network Rail Media Centre

Canvey Island, Dutch Village, Green Belt development Refused, but don’t mention the “F” word

A Unanimous decision to Refuse the Dutch Village, Holland Avenue Green Belt planning proposal was decided upon by the Castle Point planning committee last evening.

Objections from both the Environment Agency and the Lead Local Flood Authority, made the decision fairly obvious, although with CPBC you can never be certain.

At last the area was given the Green Belt recognition and respect that has been overdue. Previously the area had been the first in line for release for development. The Local Plan2016 shifts focus onto previously developed Green Belt, land that already contains a level of development, as that which is preferred for housing supply.

The fact that the Holland Avenue site is Green Belt within a Flood Zone should have offered more protection from development than most in the Borough, however logic doesn’t always prevail.

The reliance upon our “impregnable” sea defences, which by the way can do little to halt water seeping under them, and our “broken” drainage system, should result in a Sequential Approach to development. If similar development areas outside of the flood zone are available, then development in the flood zone would be Refused.

However using the overly simplistic logic, that Canvey is a “Special Case,” due to Canvey Island being a developed area it must follow that it must be continued to be developed!

The officers report offered no other reasoning nor explanation, than that!

A case was offered by us that the development in a flood zone, Sequential Test decision was challengeable, as was the Exception Test, which was actually mentioned as being failed in the officers report. We asked that both Tests should be recorded as Reasons for Refusal, most disappointingly councillors allowed this to slip the net!

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Members agreed that the access to the proposed site was inadequate, hardly surprising considering the condition and specification of the approach road, which we must add past planning administrations had allowed approval.

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Thankfully the “F” word wasn’t uttered by development committee members although in this instance we mean the “Flood RE” word.

Consideration should be given by as to whether the development committee can be assured that housing development in a Flood Zone will be able to obtain flood insurance over the life time of new dwellings.

The Flood RE scheme, which guarantees affordable insurance to such new dwellings, excludes all development built since 2008!

Therefore, as in the case of Canvey homes flooded in 2013 and 2014, insurance premiums and excesses are open to the market forces, meaning insurance premiums and excesses if offered, are extortionately high.

Whilst the Canvey Green Belt Campaign group made this point in representation, the issue received no consideration.

This is quite incredible as we hear that funding is neither identified nor allotted for improvements for the sea defence nor improvements for the drainage system.

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Non-discussion will not exempt Castle Point Council from blame. A head in the sand attitude towards this evidenced Risk is a gamble. A gamble with residents and future residents, financial assets and well being. A gamble with the socio-economic stability of Canvey Island.

We welcome and endorse the committee’s decision, but  will continue to press for a realistic approach to local planning matters.

A link to the committee meeting can be reached HERE.

Green Belt housing development, Flood Risk and fairly applying constraint considerations!

The Green Belt Test!

Bear with me.

Canvey Island, as current Borough residents should know by now, is in a Flood risk Zone. Canvey is at or below sea level and reliant on sea defences to prevent flooding.

However there are lengths of the sea wall where over topping is possible, there are also areas where the sea “wall” is in fact a clay embankment, and there is also a possibility that at some stage the defences could be breached leading to a “catastrophic” inundation!

Canvey Island is at Actual Risk of Flooding.

View of Canvey Island flooding from Police Helicopter July 2014

View of Canvey Island flooding from Police Helicopter July 2014

Canvey is also served by a “complex drainage system” that failed to prevent severe household flooding during the rain storms of August 2013 and July 2014.

Despite these issues there are people who promote development on Canvey, simply so as to add numbers to the BOROUGH’s overall housing total.

The more houses built the less demand on Green Belt development is the motivation.

Fair enough you may say, until you consider the requirements to pass the Sequential and Exception Tests for development in Flood Zones.

CPBC Officers consider:

For residential housing to serve the community of Canvey Island it is considered that it would need to be located within that settlement. Since the settlement of Canvey Island is located entirely within Flood Zone 3 it is not considered that there are reasonably available sites within the area with a lower probability of flooding. Under the circumstances it is considered the proposal passes the Sequential test.

The proposal must then pass the Exception Test.

The proposal must demonstrate that the development provides wider sustainability benefits to the community that outweigh flood risk. In response to this in a very broad sense, the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement.

 “The continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement,” statement is never applied to mainland development proposals. This seems contradictory and not a tad, unfair.

Questionable reasoning that makes it almost impossible to oppose development on Flood risk grounds, yet has led to the density of urbanisation that itself adds to the intensification of flood cause and damage.

Wouldn’t the possible loss of the Deanes School, due to falling residents of a school age, have led to social blight in the Deanes area?

Isn’t housing development also strongly opposed  in that part of the Borough due to the potential loss of Green Belt? Wouldn’t some new housing accommodation for young families have supplied the necessary pupils, so as to stop Essex County Council from considering keeping the Deanes school open unsustainable?

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Just imagine there was a Green Belt Sequential and Exception Test, how might that read as an officer’s response to a housing development proposal?

CPBC Officers consider:

For residential housing to serve the community of the Deanes School area, it is considered that it would need to be located within that settlement. Since the settlement of the Deanes School area is located entirely within the Green Belt it is not considered that there are reasonably available alternative sites within the area. Under the circumstances it is considered the proposal passes the Sequential test.

The proposal must then pass the Green Belt Exception Test.

The proposal must demonstrate that the development provides wider sustainability benefits to the community that outweigh Green Belt loss. In response to this in a very broad sense, the continued development in the Deanes School area is necessary to sustain the local community and prevent the social and economic blight of the settlement.

If this “reasoning” was used there would, quite understandably, be a reaction at the Polling Station.

However there appears little inclination amongst many of the Lead Group members to apply the same reasoning where flood risk is concerned.

Flood Risk is a CONSTRAINT!

The constraint should be applied, exactly in the same way as Green Belt is sought to be used as a constraint. This does not mean there is a need to direct housing on to the mainland if, as it should be, the flood risk Sequential Test is applied correctly and Canvey were to receive less housing development!

What you would definitely not expect is for a Canvey Councillor to “call in” a proposed development, in a previously flooded area, for planning committee members to consider, AGAINST officers recommendation!