Tag Archives: Flood Re

Canvey Island, Flooding, Over-Development, Local Plan, draft NPPF Consultation and the National Flood Forum. Unrest Grows!

Canvey Island, is synonymous with Flooding.

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Despite the tragedy of 1953, the major Surface water Flooding of 2014 and other similar events, Canvey is cynically treated as a “Special Case”. This is so that Housing Development, Park Home expansions can continue unabated.

These new homes are sold to unsuspecting buyers, with little reference as to the likely problems in obtaining House Insurance against Flooding on New Builds, since January 2009.

All so that the expectations of a New Local Plan are fulfilled.

The Castle Point Council Strategic Flood Risk Assessment, undertaken by Scot Wilson to comply with the demands of the failed Core Strategy in 2010, identified Canvey Island being “At Risk” from Flooding!

Consequently a Reason had to be “invented” so as to permit all, from Small to Large site Housing Development on Canvey. CPBC’s officers, at the behest of certain councillors, cosied up to the Environment Agency and the Strategic Flood Risk assessment was Distorted to permit continued over development!

Since then no developments are Rejected in principle by cpbc on Flood Risk grounds. CPBC claim that for development to serve, and the continued growth of Canvey Island, the development MUST be ON Canvey Island. As though Castle Point is a massive Borough divided by language barriers and with miles of sea between us and the mainland!

The draft National Planning Policy Framework (NPPF) has recently been consulted upon. We, the Canvey Green Belt Campaign Group, have monitored the submissions, especially where Flood Risk is concerned.

We found that the group known as the National Flood Forum have submitted comments that identified issues most relevant to Canvey Island.

And that if our local authority “Ruling Party” and our new leader, are unwilling to truly represent Canvey Island Residents, at least the National Flood Forum have quite capably stated OUR Position

We make no apologies for this being a long read, but we ask you to at the very least skim through it and allow the relevant issues trigger something in your mind, if you were affected in 1953, 2013, 2014 or have been concerned or affected by Flooding at any stage.

The NPPF Consultation has closed, however we have failed to discover a published response to the consultation from Castle Point Borough Council, perhaps one of our councillors may be able to direct us to the document, if it exists.

The National Flood Forum’s submission the draft NPPF consultation, with highlighted passages of some significance to Canvey residents, reads:

The National Flood Forum is a national charity dedicated to supporting and representing communities and individuals at risk of flooding. We do this by:
1. Supporting people to prepare for flooding
2. Helping people to recover their lives if they have been flooded
3. Working with government and agencies to ensure that they develop a community perspective when addressing flooding issues

As part of the flooded community, the National Flood Forum is a charity that supports communities to tackle the things that matter to them; creating hope and reducing the fear of flooding; helping people to work together to reduce flood exposure and its impacts, both physical and emotional. Over 300 flood groups are affiliated to the National Flood Forum and this response has been developed from their many comments.

The National Flood Forum regularly deals with a range of scenarios:
1. New developments that have flooded or which are likely to flood because, for example, SuDS measures are at capacity under normal weather conditions, or sites have been built on areas that are waterlogged
2. Developments which have apparently caused flooding elsewhere, or are likely to
3. Planning applications and decisions that do not make use of local knowledge of flood risk issues
4. Development planning that does not make use of local knowledge

The result is that people become extremely fearful of the future, distrustful of those in authority. This can appear as either apathy or combative behaviour.
“We had a housing estate built up in Eyam and they concreted over a large natural drainage point. And that’s in the Peak Park which is supposedly highly regulated. It’s a shambles. If you have a lot of money you can do what you want.”

Caterham Flood Action Group are also angry:
Hey “To briefly explain, our community has been blighted by surface water flooding for over twenty years, development has continued, responsibilities have been fractured, affecting maintenance (tantamount to neglect) of the delicate drainage infrastructure leaving residents in fear of precipitation.

On the 7th June 2016, after campaigning and complaining for almost two decades, the great storm wreaked havoc, destroying homes, devastating families, trapping our vulnerable and elderly neighbours for hours without power, as rivers of raw sewage flowed into our homes, through the streets of Surrey across the administrative border into a London Borough (contrary to the draft London plan, Policy Si12 B, which states ‘Boroughs should co-operate and jointly address cross-boundary flood risk issues including with authorities outside London’).

The CFAG must question if measures really are in place to guarantee that councils on the edge of the London Basin are considering the quality and capacity of the infrastructure ‘downstream’.

Paragraphs 154 – 163 of the Draft NPPF are an improvement on previous versions. But Caterham Flood Action Group, and others, do not believe that the Draft NPPF addresses their concerns that people will be put at risk of flooding.

In particular, policies and guidelines need to be much more ambitious if we are to create places that people will want to live in, that are adaptive to the future (such as being able to absorb more development) and where people feel safe.

Policies need to be translated in to action and many of the concerns from Flood Action Groups are that even the existing policies are being ridden over roughshod, with no recourse for affected communities.

The National Flood Forum strongly refutes the notion that flood risk can be outweighed by the economic benefits to the community and does not reflect the absolute misery flooding problems can cause to those involved.

The current wording in the draft NPPF virtually establishes that flooding is acceptable and provides opportunities for those who wish to find loopholes to do so. If development impacts even on a handful of households/properties, then it’s not a benefit to the community. For example, words such as “safe” in paragraph 154 are ambiguous. Whilst no one can ever be without flood risk, the wording here and in wider guidance needs to reflect community perspectives on safety, risk and what it means to feel resilient.

Data from the Association of British Insurers shows that 50% of insurance claims for properties flooded during the winter of 2015/16 were from areas that had not been identified by the public or private sectors as being at risk of flooding. In previous years the figure was sometimes higher (80% in 2007) and never lower, indicating that our understanding of flood risk and the flood risk maps available only cover a proportion of the risk. Surface water, groundwater and combined risks in particular are poorly understood.

For these two reasons greater stress should be placed in the NPPF on the rigour that is required to assess flood risk through all forms of Food Risk Assessments.

The biggest complaint from Flood Action Groups across England is that people’s local knowledge about their area is ignored, resulting in poor decisions about their future. People frequently have knowledge about their local area that professionals do not; details about previous flooding incidents, underground drainage, old drainage systems, etc. Modellers will frequently say that their modelling work simply produces useful tools and does not represent the real world exactly.

It will often lack local information to put in to the model and the parameters through which the model works will have limitations on the accuracy of what results. However, in the planning system models are often regarded as the absolute truth in the decision-making process and other evidence ignored. Communities regularly complain that this is the case. This can include information about local drainage patterns and historic flooding incidents through to the routes of major flow channels, groundwater levels and sea level rise. Therefore, development plans and planning applications should demonstrate how they have listened to local voices and how those views have been taken in to account in developing proposals. In particular they should demonstrate how triangulation has occurred between modelling, local knowledge and other forms of evidence to arrive at the most reasonable answers.

Paragraph 156) demonstrates an improved level of ambition, but not significant enough if we are to tackle flood risk seriously. The example from Shipston in Warwickshre below illustrates the point:
“The NPPF requires new developments to achieve ‘flood neutrality’ as a minimum i.e. that water run off post development should be no worse than the pre-developed site.
We work with our Town Council and the developers in negotiating better than flood neutrality at or before the planning stage and have had some success in getting their drainage strategies to achieve betterment – in most cases within the range of 25/40%.
With modern SUDS systems, their creative application and a willingness to meet improved objectives this is perfectly achievable at relatively low, if any, ‘on cost’ and of course the whole concept of betterment is essential with the increasing pressures brought about by adverse climate change trends and as a community support programme by developers.

We are concerned that the present policy is simply not ambitious enough and consider that a policy of betterment should replace the current ’neutrality’ policy.
Further, whatever the policy, specific local ground and geological conditions should be taken account of when determining the adequacy of drainage strategies by the LPA’s.
In our area Warwickshire clay is the predominant soil type and is almost completely impermeable so a literal ‘greenfield’ site in this area will already have a pre-existing high level of surface water runoff.

Further, should such ‘greenfield’ site have been used for grazing it will be highly compacted making the situation even worse.
Even further, should the site be sloping down to other developed areas great care needs to be taken to design a drainage strategy that absolutely reduces run off compared with the pre-existing situation.

Finally, the requirement that developments of less than 10 dwellings do not need LLFA oversight in giving guidance to the LPA (if different) should be reduced as it seems clear that developments of 9 or less are deliberately introduced perhaps to circumvent properly qualified scrutiny.
At present, it appears that the LPA’s simply have to check that a drainage strategy meets the NPPF guidelines which, in the circumstances described above, would likely be completely inadequate.

Once new developments are built to inadequate drainage standards in their specific local context there is no going back so this consultation is a once off opportunity to address the issue and build better resilience for the future into such developments.”

Para 158 a) contains an assertion that where there is no other option it is acceptable for a development to take precedence over people’s lives, however traumatic the outcomes might be. This is simply not acceptable and should be deleted. Developments that put people or their neighbours at a significant risk of them being flooded should not be built, whatever the pressure for new housing. Areas in Flood Zone 3, where there is significant groundwater (such as permanently within 150 cm of the surface) or significant drainage limitations should not be built on.

Where there are wider societal benefits identified, the risks of any new development should be transparent, so that businesses, infrastructure providers can make judgements about the level of risk that they are prepared to accept.

Para 160 – footnote 41. The site-specific flood risk assessment should triangulate modelling, local knowledge and other evidence. The assessment should proactively seek out local knowledge and demonstrate how this is used to develop an overall assessment. Guidance should be updated.

A common failing of current developments is that drainage plans are developed after the site layout has been determined. Retrofitting a drainage plan to a site can be difficult and lead to inferior results. Drainage plans should be submitted for all outline planning applications and should detail measures to manage water during the construction phase. The example from Charlton Flood Action Group, Worcestershire below illustrates the point.

“The Plan [South Worcestershire Development Plan] does not make any reference to the Environment Agency designated “Rapid Response Catchments” of which the Merry Brook is a very High risk one.
To minimise future flood risk in these particular vulnerable catchments we believe the plan should make reference to these Catchments and further that when any development/planning application is being agreed in these catchments that the conditions of planning should require that:
• Any flood prevention schemes should be put in place prior to the development of houses and other infrastructure being commenced. (During the last few years the development of the housing estate at Hampton, Evesham was commenced with top soil being stripped off the land. Those living in Charlton noticed that the water levels in the Merry brook increased far more quickly due to water running draining off the site. It was only when we started complaining that thought was given to installing the retention ponds and there was then a further delay until weather conditions were suitable).
• That in these catchment areas the water run off levels should be half the normal levels allowed. This should be achieved either by reducing water run-off levels or where this is not possible by the developers installing recommended schemes suggested by the Environment Agency – such as ponding on water courses.
• That all suggestions recommended by the Environment Agency should be installed. (At the Hampton development the Environment Agency had suggested that some ponding take place on the Merry Brook to help reduce water flows. This suggestion was totally ignored).
• That on small / single developments where planning consent is being sought that water run-off be considered and reduced to a minimum. Should there be a small water course running through the site then ponding/other means to reduce the flow should be installed.
• That any work on Highways in Rapid response catchment areas should also involve the installation of measures to reduce the flow of water into water courses.”

161 a) It is difficult to imagine situations where “overriding interest” applies. This clause should be removed, otherwise it will be used to push through inappropriate developments. The overriding concern must be for the wellbeing of people.

161 e) There is some confusion amongst Risk Management Authorities as to which organisation should comment on this aspect of planning applications. This needs clarification
Note 42 does not adequately cover the risks posed by surface water, ground water and combined sources. With at least 50% of flooding incidents involving surface water, this aspect needs particular attention to ensure that people are kept safe, whereas the focus of attention in the guidance is on fluvial flooding because that is where the better evidence base is. Surface and groundwater risks are often highly localised, but the trauma that is caused can be significant because often there is no scheme available that meets benefit cost criteria for investment. Rapid response catchments pose a particular risk. The result is that people continue to suffer without the prospect of ever escaping from the threat. In addition, the National Flood Forum’s experience is that people are increasingly finding it difficult to sell their home, restricting their ability to change employment, move closer to family, etc. Therefore Note 42 should explicitly refer to areas of high surface water and ground water risk, combined sources of flooding and rapid response catchments. The quote from the Food Action Group in South Woodford Ferrer, Essex, illustrates the point:
“We are currently doing our best as a voluntary group to try to alleviate a recurring fluvial/sewage flood in our local area. We are now in 2018 and still do not appear to be able to assist the residents of our town to have a better quality of life. Funding issues and OFWAT regulations leave local residents baffled as to what they can do to resolve this horrendous flood and sewage discharge situation. These flooding events appear to be occurring every 2 years (2012-2014-2016) ….surely this can’t be right? We do understand that funding is a problem but by working together we should be able to come up with a solution for these poor people living with the prospect of a significant flood every time there is a heavy rain fall.”

An area may be in Flood Risk zone 1 but at very high risk from surface water. However, reference to Flood Zone 1 will frequently allow developers to push through schemes in very high surface water risk. The point is well made by Caterham Flood Action Group:
“The Draft NPPF supports small sites being identified, essentially promoting ‘garden grabbing’, to reiterate we’re aware of the need for homes BUT in a surface water flood risk areas, we can confirm this has had devastating results over the decades, hence the need for SuDs in ALL development and retrofitting (refer to 1.2). YET 71) resists ‘inappropriate development in residential gardens, where development would cause harm’… But as we’re technically in a ‘flood zone 1’, on paper there’s NO risk, therefore development is be permitted (refer to 3.3), hence the desperate need to ensure policy guidance is ‘joined up’”

163 Minimal operational standards for Sustainable Urban Drainage systems should go beyond normal and projected normal rainfall events, with or without taking account of climate change projections. Whilst systems are unlikely to cater for every eventuality, they should be designed to cater for abnormal events, occasions where soil moisture levels are full and a series of events over a short period of time.
In some areas SuDS schemes will be inappropriate due to high water tables or permanently waterlogged soils. It may be possible to pump dry sites, but this has carbon emission issues and pumps failure does happen. In these cases, it is especially important to have a full and detailed drainage plan.
Developments currently have a right to connect to sewerage and drainage infrastructure. The National Flood Forum experience is that this may place other people at higher risk of flooding and we deal with people whose homes may not have flooded for 40-50 years, but who suddenly find that they flood every couple of years or more frequently with sewage once a development takes place. Sewerage and drainage undertakings must have the ability to refuse to connect to new developments where appropriate infrastructure is not currently in place.

Many of the issues and concerns that people in communities have relate to the skillsets and resources in drainage and flood risk management in local authorities, particularly planning authorities. These are hugely variable. It is important that Lead Local Flood Authority and Planning authorities have a qualified flood risk managers and drainage engineers to support the planning development and control process. In many cases the lack of the skills to critically examine proposals and applications has led to a failure to spot problems or allowed poor design. Whilst not a consideration for the NPPF, it is a major component of the many failures to see it applied appropriately.

Enforcement is a concern for many communities. Where there is unauthorised development or where there are planning conditions, it is a common experience that these are not enforced effectively, leading to increased flood risk for occupants and/or neighbours. The quote below from a flood group in Essex illustrates the problem:
“As regards, unauthorised development, the local authority (XXX District Council) does not seem to have adequate staff to deal with this by planning enforcement.”
Communities have sometimes worked with developers to bring forward better designs, using their local knowledge. The willingness of developers to engage meaningfully with communities has been very variable, with markedly different approaches even within the same settlement. There should be an expectation in the NPPF for developers to work with communities meaningfully to develop better designs delivering multiple benefits, rather than just running a consultation.

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Castle Point Council face Testicular Examination Ahead! Whilst Nuneaton Council act as Local Plan Pathfinders?

Having promised to stand firm over Infrastructure before more Housing, the new Castle Point Borough Council regime will now have their resolve fully tested by the Government’s team sent into the Borough to oversee progress on the Local Plan.

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Residents, having shown confidence in the Lead group of councillors by giving them an increased majority at the May 2018 local elections, will be expecting them to be able to revive the latest withdrawn Local Plan following 12 months of intensive and “tireless” Duty to Cooperate work following the Examination inspector’s criticisms.

The protection of Green Belt was paramount to Residents concerns, and any backing away from the local authorities position will be open to criticism!

This may be particularly so in the light of promises to overturn the Borough Plan made in another area, Nuneaton, where the successful Conservative group promised to:

“Protect existing communities and deliver the roads, health and school services we need.
 Reduce the housing numbers based on new government guideline figures.
 Withdraw from Labour’s secret agreement to take Coventry’s overspill.” 

“Distribute housing more fairly around the Borough to enhance not destroy existing communities.”
 “Ensure our communities finally receive the much needed road improvements, schools, GPs, shops and essential facilities they deserve, 
 Prioritise Brownfield sites first, protecting our existing communities by removing unsuitable and unsustainable sites from Labour’s broken Borough plan.”

Andrew Lainton, of Decisions Decisions, Decisions blog suggests:

“However the Borough Plan is mid examination with initial findings due to be published this month.

As the inspectors findings are binding the only alternative to fulfill the manifesto would be to withdraw the local plan.

This would put the Council in special measures.” 

The Nuneaton Tory Group’s reference to Unsuitable and Unsustainable sites is interesting and should, but doubtfully will, provoke examination at Castle Point.

The wholesale blanket application of the Sequential Test across Canvey Island would, elsewhere, be expected to be deemed Unsustainable.

In effect despite being a flood Zone 3a, any Housing Development proposed for Canvey Island is deemed appropriate!

This is evidenced in each and every Application paperwork by officers, following councillors instruction, having “persuaded” the Environment Agency that Canvey Island is a Special Case!

An illustration of this, taken from the cpbc Annual Monitoring Report 2016-17 states; “It should be noted that there is no specific policy on flood risk included within the Local Plan (1998 adopted version) and therefore the Council relies on national policy set out in the National Planning Policy Framework and its technical guidance in respect of such matters.

Of course since then the Strategic Flood Risk Assessment has recognised that Canvey Island is at Actual Risk of Tidal Flooding and the Integrated Urban Drainage Study was researched and published following the 2014 Summer Flooding of Canvey Island!

Castle Point councillors, those involved on the development committee at least, appear willing to accept responsibility for future Flooding of housing and danger to residents, whether from Surface Water or Tidal.

So far that has paid handsomely. Over time and following Flood events, that may prove less so, as Housing built since the 1st January 2009 is not eligible for the Flood Re Insurance Protection that makes available affordable insurance.

Should this problem emerge mortgages on “new” builds may well be denied due to insurance issues. New Canvey Island House Buyers may well be walking into this trap unaware.

The development of Canvey Island both Industrial and Housing continues unabated, this will intensify the pressures on the already broken drainage system, and road and health service infrastructures.

The cpbc Annual Monitoring Report also states, “the proportion of new homes provided on previously developed land to remain lower than in earlier years.”

and that, even more worryingly; 

“16 affordable housing units were delivered in Castle Point in 2016/17, representing 14% of total housing provision (114 dwellings). This level of provision is an improvement on the annual average provision for the period 2001 to 2016 of 11.5%,”

An example of the inadequacy of our local authority is illustrated within the cpbc Sequential test documentation to support the first of the local plans, the Core Strategy, in which it was admitted “The Environment Agency met with the Council in 2007 to identify criteria under which they would allow development to proceed on Canvey Island. The final criterion was the need to ensure that the Emergency Planners and Emergency Services were satisfied with the measures in place to ensure safety in the event of a flood.

These services had not been consulted in the preparation of PPS25, and as such this requirement was a surprise to them, for which they were not prepared.

A typical approach by developers to overcome the Constraint on Housing by Flood Risk on Canvey Island and acceptable to CPBC is demonstrated here;

  • “The application site is located on Canvey Island, which is situated entirely within Flood Risk Zone 3a,
  • The Council has undertaken an annual review of Strategic Housing Land Availability (SHLAA) since 2011. This process has consistently indicated the need for a greater supply of housing land to meet the objectively assessed housing needs of the borough.
  • When applying a sequential test it is important to have regard to the local context. Canvey Island is a distinctive community, accommodating 43% of the borough’s population. It has specific identified needs in terms of social, economic and physical regeneration, as well as housing.
  • In order for residential development to serve the community of Canvey Island it is considered that it needs to be located within that settlement.”

The Level of delivery of Affordable Housing and the continued influx of new Residents from outside of the Area onto Canvey Island suggest that “residential development to serve the community of Canvey Island” is simply too broad a sweeping statement intended to be a means of simply granting Planning Permission to bolster the BOROUGH’s Housing Supply in an Unsuitable Location!

It would appear unusual, if not unreasonable, for a local authority to seek to increase the Urban Density by developing Green field land and intensifying Brownfield development,  supposedly under the guise of satisfying the Need of the Canvey Island Community, when in effect it simply intensifies Inward Migration, in an area specifically under the threat of both Tidal and Surface Water Flood Risk!

We eagerly look forward to learn what Resolve, Metal, Determination and hopefully Fairness, the new administration at Castle Point council are able to apply to the ongoing Local Plan process in the shadow of Government Intervention!

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Like a bad Smell, this just will not Go Away!

The full Decisions Decisions, Decisions post may be read HERE.

Canvey Island’s “flood” of Good News stories!

Never let it be said that the Canvey Green Belt Campaign group dwell on “poor us” missives as we acknowledge, the flood of Canvey Island  “Good News Stories,” being brought to our attention across social media of late. We are more than happy to contribute and post the following Hoorahs!

Those residents troubled should we see a Rain Storm in future similar to those of 2013 and 2014 can rest assured.

They will know that their Homes now have access to the FLOOD Re insurance scheme. This scheme insures they will be able to get competitive House Insurance from practically the whole insurance market.

Provided their homes were built prior to 2009!

In 2015 Castle Point Council assembled a high profile delegation and attended Parliament seeking £24,500,000 so as to upgrade the Canvey Island drainage system and to prevent any further flooding of Canvey Homes.

We have no further update on the request by Parliament to provide breakdown figures of exactly what the money is required for.

We also must pay tribute to the tireless and determined efforts that MAP, the Multi Agency Partnership, of the Environment Agency, Anglian Water, Essex County Council, Castle Point Council and Essex Highways are making to keep our Island Homes dry and Residents safe in the event of a future storm capable of bringing Surface Water Flooding.

It can ONLY, therefore be a short matter of time before scheduled routine maintenance of the Hole Haven Sluice is carried out.

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Sluice 1

 

Canvey Island and the Scrutiny of The RISING TIDE of FLOOD RISK!

We were present to witness Essex County Council Highways representative, holding his hands up in apology for his agency’s failure to carry out adequate drainage clearance, leading up to the Canvey Island flooding during the summer of 2014.

He made a promise, in public during the Castle Point Council Scrutiny meeting into the causes of the 2014 floods, that this would not happen again and that regular maintenance would be carried out so as to prevent a repetition of the Surface Water Flooding that so many residents suffered.

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Canvey residents are now seeing that words are cheap, and the results of the continued lack of ECC Regular Drainage Maintenance allowing drains and road gullies to become silted up. The previous regime of maintenance, in which operatives will attend if residents make repeated calls for action, appears to remain the norm!

This is asking for trouble on a basically flat Island with a “complicated” drainage system reliant on gravity to feed water to the pumping system.

Climate Change deniers amongst those in positions within local authorities, are blind to the changing weather patterns and rising sea levels. They abstain from making difficult decisions on the Distribution of Housing Growth, and delay from investing adequate resources in Flood Defences, compare Dutch standards with our own.

Human nature directs them to rely on the chances of a Flooding Event occurring is less likely than, more likely. A Carry on Building Regardless policy, with increasing population being put at Risk!

And yet these local decision-makers should know full well that the insurance umbrella by the name of FLOOD Re, will NOT cover dwellings built since January 2009!

FLOOD Re representatives explained that their product was not intended to encourage development within Flood Risk areas, quite the opposite, it was intended to encourage more sensible and safer development site selection.

“Historical data shows that the proportion of residential properties located in an area previously subject to a flood event was on average 5% per local authority in England and Wales.

The question is: why, when most experts agree that the number of severe weather incidents is only likely to increase as a result of climate change?”

Unfortunately Local Plan Policies drawn up by Castle Point Council prefer much, much higher percentages than 5% when selecting sites for their Housing Growth Distribution!

Emanuela Barbiroglio writes in her article “The Rising Tide of Flood Risk” for Property Week;

Councils also receive advice from the Environment Agency, which comments on all proposals for major development in areas at medium or high risk of flooding. It says that with the majority of such planning applications its advice is taken on board.

And yet we should all be aware that Castle Point Borough Council have come to an arrangement with the Environment Agency where Canvey Island is considered a “Special Case” where development in a Flood Zone 3 is concerned!

The Environment Agency leave CPBC to take the final decision on concerns over Tidal and Surface Water Flood Risk, and Residents Safety and well being, and the development’s safety are concerned!

Emanuela Barbiroglio’s enlightening article, “The Rising Tide of Flood Risk” can be found via this LINK.

The Canvey Multi Agency dedicated Flood web site can be found via this LINK, although much appears stuck in 2015! 

 

 

 

 

 

 

Canvey Island, the Development “Special Case” and Castle Point Council Failings!

Of late there have been reasons enough to query the sense in planning to over populate Canvey Island!

Following the “disputed” moratorium of housing development on Canvey, blamed upon the Environment Agency, a successful bid for Canvey Island to be viewed as a “Special Case” was launched.

Below follows the Castle Point committee meeting minutes whereby this cautious approach was over-turned and afterwards comes comment on the possibility of people investing in new properties with the danger of experiencing extremely high flood risk premiums or even finding themselves unable to secure flood risk cover at all.

We conclude with some Planning guidance that may suggest that development on Flood Zones and indeed in the Green Belt could, indeed should, be avoided.

We hope you find this locally enlightening.

Castle Point Borough Council decision to remove restriction of developing the Zone 3 flood plain of Canvey Island.

PLANNING COMMITTEE MINUTES
6TH FEBRUARY 2007
PRESENT:
Councillors Smith (Vice-Chairman who chaired the meeting), Anderson, Cole, Cross, Dixie, E. Egan, Mrs Goodwin, R.C. Howard, Riley and B.S. Wood
Councillors Mrs Challis Mrs B. Egan, Ladzrie and Mrs Liddiard
Apologies for absence were received from Councillors Blackwell, Mrs Iles, Sharp and Mrs J.Govier.
73. PLANNING POLICY STATEMENT 25: DEVELOPMENT & FLOOD RISK
The Committee was informed and discussed the new amended national policy on development and flood risk set out in Planning Policy Statement 25, published in December 2006 which contained new and amended planning policies to mitigate and avoid the impact of flooding through good planning and flood risk management.
The Committee had previously commented on the consultation on the draft PPS 25 at the meeting on 7.2.2006.
The report before the Committee described the structure of PPS 25 which contained five sections covering background; key planning objectives; decision making principles; risk based approach and responsibilities; supported by a further eight annexes.
Members considered the implications for Castle Point arising from PPS25. The new PPS would have a particular bearing on the work for the Local Development Frame work and on the consideration of planning applications.
In terms of planning policy work, a strategic flood risk assessment had been prepared for Thames Gateway South Essex authorities and was to be published by Spring 2007. This would help inform the preparation of the Core Strategy by identifying broad locations within Castle Point and other authorities that would be appropriate locations for development.
In development control and for the purposes of PPS25, Canvey Island was located in Flood Zone 3 (High Probability), because the PPS ignored the presence of existing defences (acknowledged to be some of the most comprehensive in the country). Accordingly the requirement for flood risk assessments to accompany planning applications had also been in place for some time and in particular the application of both the sequential test and the exceptions test.
Planning Committee – 6th February 2007
This initially caused difficulties, particularly for smaller scale development, because of the uncertainty over requirements for these assessments and their relevance and applicability to such schemes. However experience had suggested that through discussion with the Environment Agency, developers, agents and landowners were now clearer about, first the requirements of the these tests, but more importantly, secondly, how to carry out development whilst at the same time mitigating the risk associated with flooding through careful design at the application stage.
Resolved –
1. That the Committee notes the policy guidance and advice of PPS 25.
2. That the Committee have regard to the guidance and advice in the preparation of the Local Development Documents and in the consideration of relevant planning applications, in order to achieve the Council’s community priorities and deliver sustainable development.
Chairman.

However the Insurance Industry does not share the Councils optimism
The short term solution Flood Re is a scheme funded by a levy on insurers that reinsures their customers’ flood risk, allowing them to offer flood insurance to those homes at risk at a more affordable price.
One of the most important aspects of Flood Re is that it provides time for insurers, the government and homeowners to address deficiencies in planning policy, invest in flood defences and improve the resilience of housing stock. The scheme is intended to be operational for 25 years, during which time there will be a role for central and local government, the insurance industry, environmental organisations, housing providers and homeowners in tackling flood risk. After this 25 year period, the Flood Re scheme assumes that improvements in flood resilience, as well as more sophisticated and readily available flood data will leave the insurance industry in a position to offer more affordable cover in a risk-reflective free market.
Properties built since 2009 are not eligible for Flood Re, which in theory should introduce pressure on planners to fully consider flood risk before new homes are built. However there remains a challenge in ensuring that a new property’s flood risk is properly communicated both to the buyer and the insurance industry, so that both parties can avoid any shocks further down the line.
As well as providing a period of breathing space for industry and policymakers, Flood Re also intends to provide a point of focus for the next 25 years, to continue the debate about addressing the root of the environmental and planning issues. But the inescapable realities of climate change, coupled with a seeming lack of a long-term approach to investment in flood defence measures means that the success of these ambitious plans is far from guaranteed.

Planning Guidance tells us that when :

Applying the Sequential Test in the preparation of a Local Plan;
“As some areas at lower flood risk may not be suitable for development for various reasons and therefore out of consideration, the Sequential Test should be applied to the whole local planning authority area to increase the possibilities of accommodating development which is not exposed to flood risk.
More than one local planning authority may jointly review development options over a wider area where this could potentially broaden the scope for opportunities to reduce flood risk and put the most vulnerable development in lower flood risk areas”.
The latest Castle Point Local Plan failed the Duty to Cooperate requirement. The Examining Planning Inspector noted in his failure Report:

Indeed, the officer report of July 2014 which set out the full document representations on the draft New Local Plan (CP/05/008) includes the following as an action point:

Given that the Council has not been able to identify a sufficient supply of housing to meet its objectively assessed needs, it is also necessary to engage with neighbouring authorities under the auspices of the Duty to Cooperate in order to determine how the objectively assessed need for housing, and other strategic matters, will be addressed within the housing market area.

However, notwithstanding the lengthy and detailed engagement across south Essex there is no formal mechanism in place to distribute unmet housing need.

The problem is that this is once again only guidance and we have often been reminded by CPBC planning officers of this fact when they deliberate on planning proposal for Canvey Island.
It would seem that any guidance that has not been fulfilled can be ignored, as far as Canvey Island is concerned, as it is only for consideration purposes.

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!

Canvey Flooding, safe escape route too Congested?

Canvey residents are often questioned whether they are scaremongering when they express concerns over flooding and emergency issues. Now we learn through the Echo that CPBC’s own emergency planner has expressed concern that both the Environment Agency and the Lead Local Flood Authority remain concerned over potential flooding issues at Persimmon’s proposed development at the Dutch Village Canvey.

Floods 2014 pic via Police Helicopter

View of Canvey Island flooding from Police Helicopter July 2014

This apparent “good news” must be treated with some caution as the developer appears confident that the concerns can all be addressed.

The cpbc emergency planner has requested a copy of the evacuation plan, although a copy can be found on the cpbc planning portal.

Extracts from the developer Persimmon’s emergency Evacuation Plan may be of interest;

“The developer’s reasonability (Freudian slip, perhaps?) will end upon completion of the construction of the site.”

“Residents should remain in their dwellings until the emergency services or statutory bodies have advised that it is safe to leave. This could be for a pre-longed period of time (days rather than hours).”

“Whilst occupants can potentially remain at the site services such as water supply, sewerage, electricity and gas will be affected in the area and occupants are unlikely to be able to use these facilities”

The “Safe Escape Route” is indicated as being via Canvey Road to Waterside Roundabout and onto Canvey Way.

It has already been assessed, although not included within the Local Plan Evidence base, that an Evacuation of Canvey Island might take 19 hours.

The continued development in areas prone to flooding is an abuse, by developers and local authorities of the Flood RE insurance scheme.

Surely the continued intention of castle point council to increase the numbers of people at Risk of Flooding must be considered unacceptable.

rebecca_harris_mp_flood_free_homes

Echo newspapers coverage can be viewed via this LINK.