Tag Archives: Flood Risk

CPBC decision makers in need of Reminding of Accountability, via Local Government Ombudsman?

Canvey Residents may have witnessed the “flexibility” towards Planning Guidance as demonstrated by Castle Point Council’s Development Committee, where matters such as Flood Risk, Danger to Residents Safety, Drainage, undersized Parking facilities, Lack of Parking Spaces, lack of Space between Dwellings and the possibility of being Over-looked, to our cost!

Indeed mainland residents have also voiced frustrations on these matters, to no avail.

There is an apparent expectation that by fulfilling the minimum notification to residents of forthcoming proposed Development, opposition through the consultation process will be equally, minimal! And a Hope that nobody will notice proposals for development until Trees are being pulled down or Groundwork, or in the case of Canvey Land Raising, being carried out, which by then is of course, too Late!

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There is no doubt that on Canvey Island following the 2013 and 2014 Surface Water Flooding and the much Edited and Delayed 2010 cpbc Strategic Flood Risk Assessment (SFRA), in which Canvey Island is classed as being at Actual Risk of Tidal Flooding, that the approach to development on the Island is Long Out of Date, and in Need of Review!

As can be witnessed by our previous Blog Post the basis for reviewing development where Flood Risk on Canvey Island is concerned was decided in early 2007, long before the SFRA and the 2013 and 2014 flooding exposed the Castle Point council’s Development Committee decision as badly Flawed and long Out of Date!

The Responsibility for the impact of granting planning permission rests solely with the local authority and the development committee. The recent fire at Grenfell Tower has resulted in serious investigation of decision making, as is quite correct.

In Canvey Island there are obvious issues that would expect a limit on the population level, simply due to the issues of coping with the number of people should any evacuation be necessary or Safe refuges found. Recent events have shown Lessons are still being Learned, as Responses from all so called Agencies have been found inadequate!

Which brings us to the Accountability of our local Decision Makers.

 

Council which ignored Planning Duties reminded of Ombudsman Accountability Role

Local authorities across England are being reminded that the Local Government Ombudsman has the same powers as the High Court to require evidence, after Plymouth City Council failed to comply with its recommendations.

The LGO was called on to investigate complaints from two separate homeowners about a series of errors by city planners when approving a second application on an uncultivated field.

During the planning process, officers failed to publicise the new application properly in the neighbourhood, failed to ask for a flood risk assessment from the Environment Agency, included the wrong plans in the report to the planning committee, and significantly misrepresented how the new proposals would affect neighbours in the report.

Consequently, one resident says she no longer has any late afternoon sunshine in her kitchen, sitting room and dining room and has a Juliet balcony overlooking her garden and decking in the new garden affords an uninterrupted view into her bedroom

The other couple feel overlooked and their outlook is dominated by a two-storey house.

Both homeowners say their properties now flood because of inadequate consideration of drainage of surface water from the site

The Ombudsman’s report of the case says that the council was obstructive and challenged the Ombudsman’s findings of fault. It has had a number of opportunities to acknowledge the errors made but has refused to do so or to follow recommendations made.

Dr Jane Martin, Local Government Ombudsman, said:

“The role of the Local Government Ombudsman to hold councils to account when they get things wrong is well established and has a statutory basis.

“Authorities can and do have the chance to comment on my decisions before they are finalised, including providing evidence if they wish to challenge the findings, but they should cooperate with the investigation process. Compliance with LGO recommendations is extremely high, based on a relationship with local authorities of mutual trust and respect. This is essential for achieving redress for citizens.

“I would now urge Plymouth council to learn from my report and accept the recommendations for remedy I have made.”

To remedy the injustice caused Plymouth City Council has been asked to apologise to both families.  It should ask the District Valuer to assess the current value of the complainants’ properties and the value each would have had if the developers had built according to the original plans and pay the difference between the two valuations.

It should pursue the proposals in the drainage report completed in the course of the investigation and ensure adequate drainage is in place before the onset of winter. It should arrange for all members of its planning committee to have at least one day’s training from professionally qualified planning officers who are not employed by the council to ensure they can robustly challenge planning officers  views prior to making decisions

The council should also pay both families £500 each in recognition of the time and trouble to which they have been put.

Article date: 15 September 2016

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.

May Avenue, Canvey Island – Flooding Lessons Never Learned by CPBC- or were they never meant to be?

The controversial proposal to develop on a narrow green space in May Avenue, Canvey Island, returned for cpbc development Control committee consideration.

The previous application had been Rejected and on Appeal was upheld by the Planning Inspector.

The problem with cpbc being taken to Appeal over development is the crazy system of officers demanding Reasons for a development’s Rejection immediately the vote has been taken. There should be a process whereby the officers Report including Reasons for Objection is given further consideration before the officers are allowed to sign off their reports.

It is these Reports that stand as the Borough’s case during a written Appeal considered by the Planning Inspectorate and they appear to be practically made up on the hoof!

This time around some members voiced continued concerns, whilst the officer warned against the consequences of again Rejecting the proposal.

In the end a Motion to Defer the decision was Agreed.

One of the main issues MUST be that of the principle of Flood Risk.

No Objection from the Environment Agency, and the Developer indicated that the famed Canvey Integrated Urban Drainage study showed flooding, similar to that of the summer of 2014 would leave the proposed development dry.

Shame the same thing cannot be guaranteed for the Neighbouring Existing May Avenue Properties!

There is an agreed guidance between the Environment Agency and castle point council for small development sites.

Part of this guidance states;

“The National Planning Policy Framework (NPPF) and its supporting Technical Guidance Document set out the Government’s national policy on development in areas at risk of flooding. It seeks, wherever possible, to avoid inappropriate development in areas at risk of flooding. Where it can be demonstrated that development is required in these areas, the NPPF seeks to ensure it will be safe over the lifetime of the development and will not increase flood risk elsewhere and where possible, reduce flood risk”

Developing what is a narrow greensward area between two properties can only add to the pressures on the Canvey Island drainage system.

Replacing a greensward with a bricks and mortar dwelling and driveway will likely increase the Flood Risk to Neighbouring properties, against NPPF requirement.

The cpbc planning officer was dismissive of these concerns stating that the local authority’s position regarding Sequential Testing (where development should take place in less Flood Liable Zones) falls within the usual mantra;

“With regard to the sequential test, the proposal seeks to provide dwellings on Canvey Island. For residential development to serve the community of Canvey Island it is considered that it would need to be located within, or immediately adjacent to, that settlement.
Since the settlement of Canvey Island is located entirely within Flood Zone 3 it is not considered that there are reasonably available alternative sites within the area with a lower probability of flooding that could accommodate the proposed development. Under the circumstances it is considered that the proposal passes the sequential test.”

This is ambiguous! The first paragraph implies that the community of Canvey Island should remain where it is, no migration allowed! Castle Point is one of the smallest Boroughs in England however, no similar concerns are applied to Benfleet, Hadleigh nor Thundersley.

These mainland towns have populations that are barely increasing, and yet they face no similar Flood Risks.

The cpbc New Local Plan Sequential Test for Housing Site Options states;

In order to deliver 200 homes per annum for the period 2011 to 2031 (4,000 homes in total), it is necessary to identify developable sites with a further capacity to accommodate 2,400 homes. Approximately, 500 of these homes will be secured at Thorney Bay Caravan Park, and 99 at the 101 Point Road, Canvey Island. It is expected that redevelopment within the existing residential areas of the borough will secure approximately 380 additional homes in this period also. Therefore, the sequential test will be seeking to identify developable sites with a capacity of 1,421 homes.

Quite clearly, development on Canvey Island is in support of the Borough’s Housing Needs! Therefore this isolationist application of the Sequential Test by castle point council, to Canvey Island alone, has No Justification!

It should be remembered that the National Planning Policy Framework gives Equal Protection to Green Belt land and Land at risk of Flooding;

specific policies in this Framework indicate development should be restricted.9

9 For example, those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion.”

Committee members concerns whether surface water flooding could be prevented by Attenuation Tanks were wide of the mark. Canvey Island has a notoriously High Water Table, create space for a tank below ground simply pushes flood waters higher and wider!

See if these extracts ring any bells, you should all, Canvey Islanders anyway, recognise where these words come from and relate to;

“pumps are the final element of a long, incredibly complex and interlinked surface water drainage system comprising of drains, culverts, sewers, open watercourses, main rivers, pumps and storage areas all with varying capacity, which need to be operating efficiently in order to drain the island. Rainfall on the island may flow a substantial distance before reaching the pumps, through infrastructure owned or managed by a large number of different organisations and individuals and in some cases without a clear understanding of ownership. Any constriction on flow either due to blockage or insufficient capacity for the rainfall event can affect the effective operation of the entire drainage system”

“The pressure on the drainage system on Canvey Island has intensified over the last 50 years due to further development, and it is evident that in some locations some drainage infrastructure is no longer at the necessary capacity to provide sufficient drainage”

” Given the unique nature of the drainage system and the scale of investment needed, to achieve significant results in Canvey Island will require that special support be provided by DEFRA. With this understanding, multiagency cooperation and additional Central Government funding it may be possible to make necessary and feasible improvements to the drainage system and effectively reduce flood risk in some areas.

The population of Canvey Island consisted of 38,459 people back in 2011, and yet cpbc position is that unless the population continues to grow, the Island will become unsustainable.

What utter Tosh!

There are 38,500 people at Risk of Flooding, local agencies have proven they cannot cope should we suffer from Surface Water Flooding, and yet the Local Plan proposal is to put more and more people at Risk!

If that is not what unsustainable development means then I don’t know what does!

The Sequential Test, as adopted by CPBC, is out of date!

The Strategic Flood Risk Assessment is out of date!

The agreement between the Environment Agency allowing Castle Point Council to decide (take responsibility for) the safety of new development over its Lifetime is out of date!

That Canvey is a “Special Case” where development is concerned, is out of date!

The £24,500,000 required to mend the Canvey Island “Broken” Drainage System has never materialised!

The Canvey Green Belt Campaign group maintain the position that the Island’s population should be maintained at the current levels or lower. All planned development on Canvey should be the subject of the Local Plan alone!

The infrastructure cannot cope with more, whilst the Island’s economy is reasonable given the UK’s circumstances. Whilst the Town Centre may be showing some signs of struggling in the more expensive locations, this is not helped by out of town commercial development in the pipeline.

Lessons clearly are not being learned despite assurances from senior officers!

Fair Play for Canvey Island in the light of the Jotmans Decision or are we still a “Special Case”?

And the Necessity for Castle Point Borough Council to produce a Local Plan is?

“National planning policy places Local Plans at the heart of the planning system,”

Even so, the National Planning Policy Framework states as early as Paragraph 14;

“Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

– any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole;

or– specific policies in this Framework indicate development should be restricted. 9

Paragraph 14, Footnote 9 Reads; “For example, those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion.”

“so it is essential that they are in place and kept up to date. Local Plans set out a vision and a framework for the future development of the area, addressing needs and opportunities in relation to housing, the economy, community facilities and infrastructure – as well as a basis for safeguarding the environment, adapting to climate change and securing good design.”

The Secretary of State’s decision to dismiss the Jotmans Farm Appeal in the light of the Inspector’s recommendation, raises some questions.

Is the Planning Inspectorate’s reading of the NPPF and Guidance similar to that of the Government’s?

There was agreement between the SoS and the Inspector that, Castle Point Council are only able to identify 0.4 years worth of the required 5 Year deliverable Housing Supply, this is an even worse supply than in 2013 when the SoS considered cpbc had a realistic housing supply of just 0.7 years!

In the case of the Glebelands 2013 Inquiry the SoS used a “totting-up” method of measuring harm to the Green Belt;

“the Secretary of State has identified moderate harm in respect of urban sprawl, moderate harm in respect of the merging of neighbouring settlements, and moderate harm to the visual appearance of this part of the GB.  The Secretary of State considers that together this represents a considerable level of harm. ”

” He also wishes to emphasise that national policy is very clear that GB reviews should be undertaken as part of the Local Plan process.”

So we appear to be in a situation where, as long as Castle Point council are in an apparent perpetual process of Local Plan making, the whole of the local Green Belt can be considered safe from development!

Residents should now be looking for a new, up to date cpbc Green Belt Review, based on the SoS’ guidance and embracing the protection afforded by Footnote 9 of the NPPF.

As was pointed out earlier in this post;

“Local Plans should meet objectively assessed needs, … unless: – ….  specific policies in this Framework indicate development should be restricted – For example, those policies relating to …. land designated as Green Belt, Local Green Space, … and locations at risk of flooding.”

This appears to be the clear desire of the Secretary of State’s interpretation of planning direction. The archived cpbc Green Belt Review was dated 2013 and produced in-house in support of the rejected daft New Local Plan, and clearly out of line with the Secretary of State’s consideration of  levels of “harm.” A new GB Review should be commissioned urgently, indicating the protection available through NPPF Policies and Guidance!

It would appear that the Castle Point council’s Local Plan2016, despite their failure to comply with the Duty to Cooperate with neighbouring local authorities, may have been more in tune with the Secretary of State’s interpretation of what is possible with Local Plan-making and stood a chance of being considered adoptable. Whilst an Inspector may feel the Local Plan2016 was worthy of withdrawal, seeking intervention via the Secretary of State, may supply a different decision, once the Duty to Cooperate has been complied.

More importantly, with Canvey Island in mind, is that NPPF Footnote 9 offers no  difference in the weight and importance that should be applied when considering whether a site is appropriate for development between that of Green Belt or Flood Risk!

Only in the minds of those in Control of Decision-making within Castle Point council, is Canvey Island deemed a “special case”!

If not now, then I do not know when, given the position of the cpbc Local Plan, and the direction given by the SoS, it would be more Timely and more Appropriate for Canvey Island Town Council to undertake a Neighbourhood Plan!

The Secretary of State is clear Footnote 9 should be applied to protect Green Belt from Harm.

It is obvious that an area within a Flood Risk Zone and with unresolved Surface Water Flooding issues, can expect that same level of protection using Neighbourhood Plan Policies under-pinned by that same Footnote 9!

Quite simply Canvey Island is thought to be unlikely to Flood. This is supported by no factual Evidence, simply that it is “unlikely”. The continual loss of Green Space to development on Canvey that serves as potential displacement for flood water, fails to register any concern to the planning decision makers!

The FloodRe insurance scheme is limited, limited so that it specifically discourages development in Flood Risk areas.

The list of properties excluded from the remit of Flood Re has been subject to significant debate however it has been agreed that the following properties will not be covered:

  • All commercial property
  • All residential property constructed since 1 January 2009
  • All purpose-built apartment blocks

Who will weigh this against Financial Sustainability? It appears nobody at Castle Point council!

It is time for the reservations contained within the NPPF Footnote 9 to be considered appropriately and evenly across the whole of Castle Point!

” ” All quotations lifted from the NPPF, Planning Guidance, Glebelands Inquiry and the Jotmans Farm Inquiry.

Can’t Plan, Won’t Plan – Canvey Island getting into Deep Water over Climate Change?

Despite Canvey Island, being surrounded by water and with a “Complex Drainage System,” the subject of Climate Change is buried as deep as Page 165 in the Castle Point unadopted Draft Local Plan2016!

So far, the list reads; No Local Plan, No Neighbourhood Plan, No Town Centre Regeneration Plan, however, what we do have is a TE2100 Plan (Thames Estuary Plan)!

But a Plan is of Little Use if it has a limited chance of  being implemented!

The Environment Agency consider; “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.”

There is No Vehicle in place for the collection of Developer Contributions, put in place by Castle Point Council, towards futures Funding for Sea Defence improvements. In the meantime development continues across Castle Point, including that which increases the level of population at Risk of Flooding!

Given that it appears the Earth’s oceans are warming 13% faster than previously calculated, and many of those in local power appear to be Climate Change sceptics, there is Real cause for Concern.

The effects of Sea Level Rise on the Thames will be dramatic, the protection of London will be the priority. The Thames barrier increases Sea Levels in the Estuary and increases the need for space for water.

Quite probably the future sea defence improvements around Canvey Island will be considered between the value of considerable financial expenditure and a practical experiment into the effectiveness of new space for water schemes along the banks of the Thames Estuary.

This should cause considerable debate as to the sensibility of new large Housing Development being distributed towards Canvey Island, however the Local Plan2016’s indicates the local authority Castle Point’s approach to this Flood risk as “there remains a very small probability that they could be overtopped or breached.”

Those residents who suffered their Homes and Property being flooded by the severe floods of 2013 and 2014 will take little comfort with the draft Local Plan2016’s approach to Surface Water flooding;  “Fluvial flooding is also possible from the watercourses and dykes that form the drainage system on Canvey Island.”

Green House Gas Emissions add to Sea Level Rise, Castle Point contribute to the increase. Within the Local Plan2016 it states;

“The Sustainability Appraisal Scoping Report sets out details of the borough’s ecological footprint. In terms of Castle Point’s impact on Climate Change, it is clear that the borough’s ecological footprint is high and likely to be contributing to more extreme weather events.

Paragraph 93 of the NPPF is clear that planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change,”

“The strategy in Castle Point therefore needs to be on how the individual can reduce their ecological footprint, and how developments can be planned to encourage this.

The Transport Evidence for the New Local Plan shows that Castle Point suffers congestion at peak times causing queueing at junctions and extended journey times. Congestion results in increased emissions from vehicles, including emissions of green house gases that contribute towards climate change.

Congestion is therefore contributing to both climate change and poor health outcomes for local people.”

Surface Water Flooding on Canvey Island and the Borough;

“The South Essex Surface Water Management Plan 2012 (SWMP) identifies the causes and locations of surface water flooding in the borough and a strategy for the future management of surface water flood risk, taking into account the impacts of climate change. This indicates that when the impacts of climate change are taken into account the likelihood and potential impacts of surface water flooding will be worse in the future than they are now. Extreme rainfall events will be more common and the depth of flood water will increase posing a risk to more properties.”

This is incorrect and out of date information in regards to Canvey Island. This flawed document was eagerly grasped by Castle Point cabinet as being indication that Surface Water Flood Risk affects Borough wide equally. Events in 2013 and 2014 proved cabinet members and officers so wrong!

The SWMP was based on incorrect Historic evidence that had been un-documented, suggesting there had been NO previously recorded flooding events by cpbc officers, particularly where Canvey Island was concerned.

The SWMP remains amongst the local Plan2016 Evidence base despite being incorrect and having been replaced by the more accurate Canvey Island Integrated Urban Drainage study document, albeit incomplete.

Interestingly the Canvey Island Integrated Urban Drainage study, is NOT included within the Local Plan2016 Evidence Base documents!

This may indicate the level of concern for any future Flooding of Canvey Island by cpbc cabinet in general, something current and future residents may wish to make themselves aware of.

The issue of Flood Risk in the Castle Point Local Plan, whichever version, needs to become more prominent and focussed within the Policies.

Residents Safety, Well-Being and Financial Security deserves far more consideration than is currently apparent.

Castle Point Council deserve more investigation and challenge on their approach to Risk.

More information on the latest Sea Level Rise and Climate Change may wish to follow this link to a MSN News article HERE.

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© CSIRO An Argo float is deployed into the ocean

 

Flood Risk! Canvey Island – The “Special Case,” the Sequential Test and the time to Reconsider!

The Approval of Flats in Canvey Town Centre caused Canvey councillors to mention fears of flooding.

Usually levels of development in areas liable to Flood would be restricted through planning, by consideration of the Sequential Test. This Test proposes that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk.

The effect of the policy approach of Castle Point council is to continue to increase the numbers of population at Risk of Flooding on Canvey Island.

CPBC justifies this by suggesting that “Canvey Island is a Distinctive Community. It has specific identified needs in terms of social, economic and physical regeneration, as well as housing.”

The result is that due to the 40% increase in population, since Canvey fell under the control of castle point council, there is a perpetual need for a never ending supply of Housing Development on the Island!

This is regardless that the Need for Housing is calculated as a Borough-wide figure.

The fact that it is admitted that there is “a need to maintain the population living in the flood risk zone at current levels or lower” on Canvey Island, has not deterred a reckless approach to the distribution of Housing Growth by the local authority!

This policy of increasing the numbers of population at Risk of Flooding and the deliberate manipulation of the Sequential Test stems from the efforts to label Canvey Island a “Special Case”!

Echo June 2008

DEVELOPERS seeking to build new homes on Canvey are being forced to think again because of growing fears about flooding.

The Environment Agency is resolutely pursuing its policy of recommending refusal of plans to build new homes on the island because Canvey is below sea level and therefore on a flood plain.

Castle Point Council is taking those recommendations to heart and rejecting applications for new homes, leaving some developers in limbo.

The council has pledged to continue upholding the Environment Agency’s recommendations until the results of a Government-initiated inquiry into flood plains publishes its findings.

The Government appointed Sir Michael Pitt to carry out the study, following catastrophic floods in Hull after heavy rainfall in June and July last year. It is likely the final report expected, this summer, will recommend tighter restrictions.

Ray Howard, Castle Point and Essex county councillor, said local authorities were reluctant to ignore the Environment Agency’s advice, while they are waiting for the results of the Pitt Report.

Mr Howard has received many letters from people struggling to build on Canvey.

He said: “It’s a big problem that needs to be looked at. We can’t have a blanket ban for building here.

“I believe Canvey is unique, as it has the best flood walls and flood water drainage system in the country.

“The flood plain rules should be relaxed for us.”

Last week localised flooding on the island, caused by heavy rainfall, affected hundreds of residents on the island.

But Mr Howard is convinced it is well protected against severe flooding from the Thames Estuary.

A total of £34 million was spent rebuilding Canvey’s sea walls in the 1970s and 1980s.

A further £6 million was spent last year on 14 giant pumps, spread around the island to force water back into the sea if the walls are ever breached.

Mr Howard said: “The reason Canvey is always considered high-risk is because of the 1953 flood.

“But back then the only sea defences were soil walls, built by the original Dutch settlers.”

Despite Mr Howard’s insistence that Canvey is well protected, the Environment Agency refused to budge from its policy of objecting to all new homes on flood plains.

Spokeswoman Rita Penman insisted the Environment Agency could not relax its planning guidelines for Canvey, even for special cases.

She said: “Although Canvey is well defended, the current understanding across the country is that if there are other areas not on the flood plains, they should be developed first.

“This is in the interests of everyone’s safety. We are therefore unable to recommend approval for any new developments on Canvey at the present time.”

Even if the Government report clears the way for new homes on flood plains, insurers are warning hundreds of thousands of homes built in high-risk areas may not qualify for insurance.

Nick Starling, the Association of British Insurers’ director of general insurance and health, said: “Poor planning decisions will lead to more homes becoming unsaleable, uninsurable and uninhabitable”

Consequently in 2007 a Planning committee meeting considered, and were asked to “Note” the freedoms of decision making that were pleaded for, and “seemingly” allowed by the Environment Agency, in considering Canvey a “Special Case” that has led to the abuse of the levels of development we continue to see proposed.

How things have changed, in such a short space of time!

Since then we have received a concerning Strategic Flood Risk Assessment for Canvey Island in 2010, and suffered two Surface Water Flooding Events during 2013 and 2014!

Whether a Planning committee should have the power to approve such a policy with the potential to impact Canvey Island, or whether members were all actually made aware of the policy’s implications, is dubious to say the least.

Whether the 2007 planning committee meeting decision to allow increasing levels of population at Risk should now be re-considered in the light of the ominous Flood Risk Assessment and the Flooding incidents, appears obvious!

Floods 2014

The Full text of the Echo article can be read HERE.

Canvey Flats, Foksville Road, Flood Risk responsibility and Lack of Parking Spaces!