Canvey Island residents lay claim that they are treated unfairly by Castle Point Council. In turn CPBC claim they are being treated unfairly by the Government, by being threatened with Intervention due to their Tardiness with producing a Local Plan!
Apparent outrage from the CPBC leader and chief executive, at those Councillors brave enough to Reject the draft Local Plan, did not disguise the fact that the emerging Plan deserved closer Scrutiny and Challenge from Councillors, than those Reasons given for their votes of Rejection during the December Council Meeting.
Whether the Failure of the Local Plan 2018 is due to CPBC Incompetence, or whether some perceived levels of Immorality, or political corruption, is involved in the selection of the Canvey Island Green Belt sites for Housing Development, especially in the approach to the application of the Sustainability Tests involved, we leave the Reader to decide.
As you are probably aware, the whole of Canvey Island is regarded as being in Flood Zone 3a. Housing in this Zone is considered as being Vulnerable development.
The whole of Canvey Island is also considered to be a Critical Drainage Area.
For ease and to avoid confusion wording highlighted in Blue are those of CPBC whilst wording in Red is official Government Guidance.
The Castle Point Local Plan 2018 version at Paragraph 17.4 states “planning policies should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes and policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts”
Typically though, of CPBC, and despite their Officers and some members, insisting that the NPPF should be “Read as a Whole”, the Local Plan 2018 version Craftily fails to include the final, and most Important part of the NPPF text of the above Paragraph 17.4.
That is; “ , such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure. ”
CPBC Sequential Test Page 2
This Local Plan Evidence document almost immediately sets out to justify, carte blanche, large scale Housing development on Canvey Island.
Bear in mind that Housing and Residential care Homes are considered to be a “More Vulnerable” uses of Land in Canvey Island a Flood Zone 3a area.
“The NPPF recognises that following the application of the sequential test, it is not always possible, consistent with wider objectives, for certain development proposals/requirements to be located in lower ‘flood risk zones’. It therefore also sets out a test that needs to be passed if certain types of development are to be exceptionally allocated in a local plan”
All of the Canvey Island Housing Sites are considered by CPBC to Pass the Exception Test, “This site has significant positive impacts related to the sustainability objective concerning the provision of housing, including affordable housing.”
Affordable Housing being considered practically Unviable on all Housing Development Sites, even those not requiring the Surface Water Management measures, and Sustainable Urban Drainage schemes, and Raised Floor Levels that are now required on Canvey Island.
Additionally the CPBC Sequential Test found that, NONE of the 9 Housing Development Sites allocated for Canvey Island is considered to be “Within a Potential Surface Water Flooding Hotspot”, whilst 4 of the Mainland Housing Sites were within a potential flooding Hotspot !
Clearly the evidence found in the Reports, on the Canvey Island Summer Flooding 2014 and 2013, has been discounted, ignored and will be hidden from the Government Chief Planner and Planning Inspector examining the Next CPBC Local Plan!
“All the deliverable and developable sites assessed in terms of their risk of groundwater flooding were found to be appropriate for development, at least in this respect.”
We would ask CPBC “what Tests and Reports were their Assessments based on?”
Once again only certain Mainland Sites were considered to be “Within an Area Susceptible to Groundwater Flooding”, NONE of the Canvey Island Sites allocated for Housing Development were considered to be affected!
This goes Against common local knowledge AND written evidenced Reports to be found on CPBC’s own website!
“Subject to other considerations, it is recommended that when selecting sites for development in the New Local Plan, preference is given to those sites within the highest preference ranking groups over those in lower groups. This will reduce the exposure of new development to flood risk.
It is recommended that housing sites on Canvey are only allocated as a means of providing flexibility to the housing land supply. If sites on Canvey are included within the New Local Plan, a sequential phasing requirement should be applied within their allocation policy to ensure other sequentially preferable allocated sites are brought forward first. Additionally, requirements in the allocations policies should include the provision of flood resistant and resilient design.”
Quite clearly the Housing Development Site Allocation process, of Castle Point Borough Council, applies considerably more Weight on Green Belt protection over that of Flood Risk. The local authority Actively Chooses to adopt this approach despite some sites on Canvey Island being both Green Belt, within a 3a Flood Risk Zone and a Critical Drainage Area!
Government Guidance in the NPPF continues to point out;
“11. Plans and decisions should apply a presumption in favour of sustainable development.
For plan-making this means that:
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area, see Footnote 6
Footnote 6 The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.”
“Incompetence”, perceived “Political Immorality”, or a “Corruption of Facts”, you decide, if not the Examining Planning Inspector most certainly will!