Tag Archives: Flood Risk

Briar Cottage, Leige Avenue Development indicative of What Poor Planning Canvey Island continues to be Subject to!

Decision: Application refused.

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

On Tuesday, 2nd October, the Flats proposal for Briar Cottage, Leige Avenue, Canvey Island will be considered by the Castle Point Council Development Committee. Whilst the officer Recommendation is for Rejection of the Plans, we should bear in mind that at the previous meeting the officer recommendation of Refusal for plans for the Residential Institution in the Canvey Island Green Belt, was ignored by a majority of the Committee.

Below are some points taken from the meeting’s Agenda which lead us to the conclusion that CPBC development committee, their Planners and local developers, Have and Are creating a truly Miserable, Cluttered and Poorly Planned place to Live on Canvey Island!

We invite you to make your own conclusions from these Extracts:

“The proposed development of the site with flats is acceptable in principle, however the proposal is considered to represent overdevelopment of the site, by reason of its scale, and form, which results in a visually cluttered and unduly prominent feature on the street, of mean and cramped appearance and likely to have an adverse impact on the amenity of adjoining residents, by reason of undue overshadowing and dominance.
It is served by an unadopted private road some 4m in width.

Policy H13 of the Adopted Local Plan specifically states that proposals for flats should be located on main roads. Whilst it is recognised that the proposed development would also share a frontage with Leige Avenue, which is a residential street and not a major route the existence of flats in such context is not unusual, indeed flats fronting Central Wall Road exist to the west of the application site which are served from minor residential roads and adjacent to two storey development at the rear. As such it is not considered that an objection based on the relationship between flats and development on adjoining frontages can be sustain”

(So, because breaches of the Adopted Policy have been allowed by CPBC in the Past, Future breaches of the Policy will be acceptable!)

“The proposed development seeks to provide a three storey building a minimum of some 2.2m from the highway boundary. Such disposition is considered likely to result in the creation of an obtrusive and unduly prominent feature in the street scene.
The visual impression gained is one of a cramped and contrived design, overly fussy on the eastern and western wings and bland and austere on the northern elevation.
The unmatched and misaligned dormers within the northern projection adds further to the unsatisfactory and cluttered appearance.

The proposed development provides 17 spaces and is therefore deficient in parking provision and ordinarily would attract a recommendation of refusal.
However, the County Council has confirmed that the site is in a sustainable location, being close to shops, educational establishments and a public transport network, and that within such locations parking standards may be applied flexibly. The Highway Authority has raised no objection to the proposal on the basis of parking

Drainage and Flood Risk

Canvey Island lies within an area identified as falling within Flood Zone 3a. Within such areas there is an identifiable risk of flooding. For Canvey this risk takes the form of both fluvial and pluvial inundation.

Proposals are also required to pass the sequential and exception tests as set out in the NPPF and the Planning Practice Guidance (PPG), in order to determine whether sites of lower flood risk probability exist which may be more suitable for the type of development proposed.

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. Under the circumstances it is considered that the proposal passes the sequential test.

(Regarding the Exception Test.) In a very broad sense the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement. However, in assessing whether these benefits outweigh flood risk, the flood risks surrounding the development must be considered in more detail.

The second criterion requires that the applicant demonstrate that the development is safe and where possible will reduce flood risk overall.
should the (Flood) defences breach during a 1 in 200 year plus climate change storm event the depth of flood water on site would be between 0.3m and 0.45m deep. For a 1 in 1000 year plus climate change storm event this would increase to about 0.6m.

In order to mitigate the impact of such inundation the applicant’s consultants have recommended that floor levels be raised from 2.03maOD to 2.91maOD. This increase in height would have implications for the development resulting in an even more dominant and prominent feature in the street scene.

Not raising the ground floor level, as indicated in the submitted drawings, will result in flood damage and risk to occupiers in the event of a relevant breach event, however, the two storey nature of the properties is such that refuge can be achieved at first floor level

Redevelopment of the site will result in a reduction in the permeable area of the site and will therefore increase the risk of surface water runoff onto adjoining sites.

In recognition of this the applicant has submitted a surface water drainage strategy which seeks to retain excess surface water within an attention tank provided beneath the proposed car park. Water will be retained within the tank during periods of excessive rainfall and then pumped into the existing surface water drainage system at a controlled rate, in order to prevent surcharging within the system.”

In the event of a Flood of Canvey Island, the Response Plan is for Residents to Stay Put and take Refuge in safe areas of a Building. Yet again, the Floor Plan designs indicate No Specific Flood Refuge Areas. One must assume Residents will take Refuge in upper level Stairways for the duration of the Flood, reliant on Neighbours for the use of Toilet Facilities!

Density and Mix of Housing

The NPPF now exhorts Local Planning Authorities to achieve higher densities, in appropriate circumstances and consistent with the character of the area, in order to achieve the effective use of land and contribute towards satisfying the need for housing.

Policy H9 of the current Local Plan, requiring the optimum density of development to be achieved on any site, is considered to be broadly consistent with this requirement.

Amenity
The proposal seeks to redevelop the site of a single dwelling with a complex of 11 residential units. Local residents have expressed concern that such an intensification of occupation will lead to a significant increase traffic on Leige Avenue,

In terms of the operational phase of the development, it is clear that the proposal is likely to result in additional traffic on Leige Avenue.
Leige Avenue is a single lane road with extremely limited opportunities for vehicles to pass each other.

Social Infrastructure

There is an existing deficit of GP provision across the borough that is a result of the recruitment and retention of GPs as opposed to the amount of facilities available. Growth will exacerbate this deficit. NHS England and the Castle Point and Rochford Clinical Commissioning Group are seeking to address this deficit in two ways.

Firstly, they are seeking to recruit more GPs into the local area through the promotion and development of ‘Training Practices’. They are also putting together a Primary Care Strategy which will seek special clinics developed for older people with complex care needs. This will relieve pressure on GPs to treat the remainder of the population.

Under the circumstances it is not considered that an objection to the proposal on the basis of inadequate GP availability would be sustained on appeal.
Other Matters

The site, is within the zone of influence associated with the Ramsar site (Benfleet and Southend Marshes), Special Protection Area and Ramsar site. As a consequence the ecological implications of the proposal for the designated site must be considered.

Consideration of the development of the site has identified that it would have no direct impact on priority habitat and is not required to be retained in its current state in the interests of maintaining the integrity or facilitating the management of the designated site. No objection is therefore raised to the proposal on that basis.”

Despite the fact that concerns over the increase in the local population, as this development will contribute, is known to impact upon the integrity of the designated Ramsar site.

Conclusion
The proposed development of the site with flats is acceptable in principle, however the proposal is considered to represent overdevelopment of the site, by reason of its scale, and form, which results in a visually cluttered and unduly prominent feature on the street, of mean and cramped appearance and likely to have an adverse impact on the amenity of adjoining residents, by reason of undue overshadowing and dominance.”

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Canvey Island Flood Event “Cover Up”? CPBC willing to withhold information, so as to develop Canvey Island!

A recent addition to the Castle Point Borough council’s Local Plan Evidence Base is the Strategic Flood Risk Assessment 2018 Update covering South Essex.

The document, apparently is too large to be downloaded from the cpbc Local Plan website, so we downloaded from the Rochford council website instead!

Of note, and the Canvey Green Belt Campaign did make it known to councillors, Canvey Island had no Historic Flood Events, up until 2011, recorded by Castle Point council except the 1953 Tidal Flood. This despite local knowledge confirmed that there is a Surface Water Drainage issue across Canvey Island!

This information we made available whilst the cpbc cabinet discussed and adopted the Surface Water Management Plan during 2012. Little wonder then that cpbc and their partners, were totally unprepared for the Canvey Island Floods of 2013 and, worse still, 2014!

Those living on Canvey Island at the time would have been well aware of a serious Surface Water Flooding Event during 1968. Previous localised Flooding causing more regular problems had also taken place on the Island on more frequent occasions.

None of this was recorded, nor recollections sought, when cpbc gave information to URS Scott Wilson as they compiled the 2011 Surface Water Management Plan for South Essex.

Now it is evident that cpbc have allowed, one can only think for convenience sake, the South Essex Strategic Flood Risk Assessment to be published and adopted for inclusion in the cpbc 2018 Local Plan evidence base, with the same Flooding Event omitted!

The South Essex SWMP (2012) states that there are 26 recorded flood events from Castle Point Borough Council, the Essex Fire and Rescue Service, Parish Councils and the Highways Agency. The source of flooding is unknown and these records are shown in Appendix A Figure 5.3. Where available, updated flood incident records held by the project stakeholders, including Castle Point Borough Council, ECC, the Environment Agency and AWS, have been provided to support this Level 1 SFRA update.

Records of Flooding included within the document indicate:

1968 “Fluvial flooding from the Benfleet Sewer” Following this event, structural flood mitigation measures were undertaken along the watercourse to improve the standard of protection against flooding including the construction of the bunded washlands area.

Again in 1987 Flood recorded in Hadleigh

For Canvey Island, during these decades, Nothing Recorded!

So despite the Canvey Green Belt Campaign making it known to cpbc that Canvey Island had suffered Flooding incidents and that the 2011 Surface Water Management Plan incorrectly omitted a record of these events, Castle Point Borough council have allowed a new Assessment to be undertaken without correcting these errors!

Not only that, but the Canvey Island Integrated Urban Drainage Study, undertaken following Government departmental advice, was not used as an informative for the South Essex Strategic Flood Risk Assessment, despite being signed off in April 2018!

5.4.2 Canvey Island Integrated Urban Drainage Study
The Canvey Island Integrated Urban Drainage Study (IUD) has been undertaken setting out how surface water drainage should be managed and maintained on the island. The study was not available for inclusion in the Level 1 SFRA; however, the study should be used to inform the Level 2 SFRA and site specific FRAs.

We can only conclude that these omissions and flaws can only be explained by them being deliberate to support the desires of  Castle Point Borough Council to distribute a large level of Housing Development onto the Flood Risk Zone and Critical Drainage Area of Canvey Island within their latest 2018 Local Plan process!

The 1968 Canvey Island flooding was not an insignificant event as much as cpbc may wish it was. These photographs act as proof:

Sandra Davis Photo

copyright: Sandra Davis

Jacksons Photos

Copyright: Jacksons Photos

More information on the 1968 Flooding has been collected, along with many interesting photographs that can be found on the Canvey Island Community Archive. Their website can be found via this LINK.

 

 

Residents almost Total Disengagement with Castle Point Borough Council! Local Plan Consultation a Major Turn Off!

The CPBC Local Plan Consultation formally closed to submissions on the 15th August.

Alarmingly indications are that less than 0.7% of Castle Point residents took part in the process that will shape the future of the Borough!

“The Council invited comments on the contents of a new Local Plan…. Responses are yet to be analysed but initial indications show that more than 1100 comments were received  from over 630 individuals and organisations.”

We say that less than 0.7% of the 89,000+ Castle Point residents made their views known, as the total number of responses included those of neighbouring Councils and Developers!

There can be no doubt, that there is a disengagement with our local authority by residents!

That residents views are ignored, is a view challenged by councillors, but a view that, going by the number of responders, must be recognised!

This disengagement contrasts starkly from the Canvey Green Belt Campaign Referendum that managed to visit and ask residents their thoughts on Green Belt development on Canvey Island, and engaged with over 6,500 residents.

Also the Canvey Ladies who compiled a Petition against development on the Island and achieved over 10,000 signatures.

Not a week goes by without complaints on traffic congestion, and over stacked GP surgery lists. Flats and Houses being developed to more denser and higher designs. Industrial premises taking over important Green Spaces. Flooding becoming more frequent.

With latent feelings running high, why would residents NOT take part in the Local Plan consultation?

0.7% Response is a admittedly a paltry figure considering the number of campaign groups within the Borough.

However, what IS important is the content of the answers given and the documentation in support of what the Local Plan should and should not contain.

Despite this, going by previous experiences, Castle Point council will likely continue to do whatever it suits the current administration.

This is probably why so many attempts to achieve a Local Plan have been forced into withdrawal and fallen by the wayside, and the Government through the Chief Planner, are keeping a very close watch on cpbc’s Local Plan process.

This may be why such a small response was achieved through the Consultation.

 

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Local Plan – is it “Coming Home”, or Not? Roll up, Roll Up! Two Plans for the Price of just One – Castle Point’s Never had it so Good!

Canvey Island and Castle Point residents are being asked to add their opinions and thoughts to the latest Local Plan 2018 consultation process.

Town Centre
This is despite the fact that the Secretary of State, through the opinion of the Government’s Chief Planner, has yet to decide whether Castle Point council are deemed willing and capable of completing the Local Plan publication process themselves to the point of adoption!

The whole Castle Point Local Plan process is being carried out in a Rush under the threat of Intervention!

This despite the Secretary of State’s own office taking from 18 December 2015, when the Inspector issued his report into the Jotmans Farm housing Appeal inquiry, until the 21st April 2017, 16 whole months, to come to a decision. Apparently no hurry then to come to a planning decision, until an Election was imminent.

Residents entering the LP2018 process will note that there isn’t a Local Plan to actually consider, instead there are 2 !

Two Local Plans, from a single Evidence Base!

This shows, as Canvey Islanders should by now be aware, how “Local Factors” and politics can distort and manipulate the contents of Local Plans!

According to the cpbc Chief Executive officer up to 100,000 consultees are invited to respond, despite the 2011 population of Castle Point being just 88,011 and many of these being young children. this may lead to the Consultation response rate being skewed low! Previous response rates have been around just 12%

These Low response rates can lead to distortions of the “Feed Back” by the cpbc officers and our elected representatives. Previously, through these influences, we have seen Housing Growth directed onto Canvey Island despite Flood Risk being an issue, and the reduction of Housing Numbers, due to the concerns over Green Belt loss.

These influences on the Housing Growth have chiefly been in response to mainland residents concerns, indicated through the previous draft Local Plans consultations.

In recent times we have witnessed the pressure of residents and mainland councillors protest be successful in the prevention of the proposed Essex County Council closure of the Deanes school. This was strengthened by the cpbc chief executive’s supporting statement that there was to be a large Housing development site in the surrounding area, residents of which would be attending the Deanes to bring the attendance numbers nearer ECC expectations.

In contrast Canvey’s Castle View school, serving the most densely urbanised part of Castle Point and South Benfleet, was simply Closed!

A public facility closed, and sold off to a sectarian private enterprise.

The Paddocks, allowed to deteriorate despite money being available some years ago for improvements with a top up from CPBC funds, is now seen as a potential Housing development site.

If Canvey Island residents are tired of being dictated to, they must take the trouble to involve themselves in the Consultation.

This is crucial as, not only will a low response rate allow certain councillors to suggest that he, or she represents the “silent majority”, but will allow a potential disastrous Local Plan to emerge just so that it may appear CPBC are compliant with the 2 new strategic “Quango’s”, the “Association of South Essex Local Authorities” (ASELA) and the “Thames Estuary 2050 Growth Commission”!

Dalliance with either or both will lead to major growth changes, both in population from the 90,000 dwellings across the area and traffic especially locally, with no infrastructure improvements. Canvey Island, purely due to its situation will always remain an outpost. However many people are managed to be housed here, little infrastructure will be forthcoming simply because we are in Austere times.

Infrastructure requires maintenance, ECC are not looking to spend more on maintenance!

For all of the Canvey Island Petitions and Referendum the past has proved that election words and promises are cheap, we need to accept that due to our location, the area is seen as Developable, whether Housing, Business or Industrial, yet little benefit or financial return is gained by Infrastructure improvements.

As it stands your Local plan consultation response, in the first instance, will be weighed against mainland responses.

If you  as a Canvey resident consider;

that Canvey Island has become over developed to the point that New Large Housing development sites are unviable,

that the Traffic Issues mean the potential congestion is unreasonable,

that Tidal Flood Risk is not taken seriously enough when distributing Housing Growth,

that the whole of the increasing Urbanised area of Canvey Island is a Critical Drainage Area and the ever increasing development is putting too greater strain on the drainage system,

that the Road Access is inadequate for the current population, many of whom commute, and unsuitable and especially inadequate in the event of an Emergency Evacuation,

that in a severe Emergency, whether Flood Risk or Industrial, the sheer number of Residents on Canvey Island and the island’s location, mean that any response by the Emergency Services will be inadequate and a Danger to Life, despite responders best efforts,

that our Green Spaces and Green Belt are important to our well-being and should NOT be developed,

that our Town Centre is badly in need of Regeneration and Re-development and under serious threat from out of town shopping areas,

then you really should make the effort to Log onto the Castle Point council website and respond to the Consultation.

Otherwise it will be left to the Government, Council officers and the majority mainland representatives to impose on us “their” Local Plan.

To add your thoughts and concerns to the cpbc Local plan Consultation, log on HERE.

To view the documentation, log on HERE.

To Intervene or to Not Intervene, that is the question: Whether ’tis nobler in the mind to suffer, as Simple Minded and Disobedient Canvey Folk suffer, Or to take arms against a sea of troubles.

Much will be read and disclosed over the next year or so, when it will be wondered whether the June 2018 decision by Castle Point council, to rush into a Local Plan schedule, with the prospect of a New Local Plan approved by Council for publication by November followed by submission to the Inspectorate in April 2019, or alternatively to face the prospect of Government Intervention, is the best path to tread, especially where Canvey Island is concerned.

“sometimes orders given to the simple-minded have to be reinforced with a threat, a suggestion that something terrible will happen to the disobedient,”

And so it was, when the cpbc chief executive, the council leader and his deputy, stated the case for cpbc seeking to retain control of its Local Plan making, rather than allow Intervention from the Government Planner.

The councillors and residents were not permitted an address from the Government chief planner, choices and their consequences were expressed only third hand delivered by the cpbc triumvirate.

But whilst keeping control of the Local Plan process is in the very best interests of parts of the mainland, is it also in the best interests of Canvey Island, a reasonable question to ask?

Harking back to the Core Strategy we exposed a Plot by the “Ruling” mainland party to sacrifice Canvey’s Dutch Village Green Belt site, as the sole Green Belt site released for development, so as to appease their mainland concerns and allow publication of a cpbc Core Strategy, local plan!

We remember well, the mainland residents Green Belt campaign group, during the council Task and Finish group meeting, standing to address council members confirming that they agreed and supported the Plan “in its entirety!”

Where was the “united” Borough then?

When the Core Strategy was rejected by the Examining Inspector due to the unreasonable Housing Growth Distribution and the Dutch Village site being, a Green Belt site within a Flood Risk Zone, the cpbc ceo made sure that the Dutch Village remained within the list of Green Belt sites for development, whilst adding some mainland sites to meet the Housing Need of the Borough, within the 2014 daft Local Plan!

Of course the retention of the Canvey Dutch Village site, despite the Inspector’s opinion, meant that one large mainland site would be saved from development.

Now by returning to the 2014 draft local Plan as a starting place for the 2018 Local Plan, concerns return as to whether it is intelligent and responsible for Canvey residents to put their faith, as we are being told and advised so to do, within the “Ruling” party’s successful motion to Control the 2018 local Plan.

“sometimes orders given to the simple-minded have to be reinforced with a threat, a suggestion that something terrible will happen to the disobedient,”

The threat has been delivered and something terrible may still apparently happen!

We are reminded that the Dutch Village site is owned by Persimmon, implying that this would speed the process through Planning resulting in an early supply of Housing, For The Borough!

Meanwhile, the more lucrative development sites elsewhere in the Borough would, following this logic, remain undeveloped for longer, especially when the ongoing development of approximately 900 Sandy Bay Park Homes, also on Canvey Island, are put into the equation!

This may encourage some conspiracy theory, has the call for sites from cpbc entailed dealings between officers members and developers as to which site or sites would be released in which order, specifically if the developer were to agree to initially focus on Dutch Village first?

As it stands in practise cpbc focus on applying constraints on development in the so called “virgin” Green Belt areas of the Borough. Canvey Island Flood Risk is also applied to the constraints so as to limit numbers, but that constraint is applied to housing Need numbers across the whole Borough, rather than Canvey Island in particular!

Making cpbc’s approach to the application of the Sequential Test simply contrived and, a Farce!

But can Canvey residents be certain that the Government Planner would apply to Canvey Island, the supposed Constraints on Housing Development such as Flood Risk, the threat to what remains of its Green Belt and the Hazardous Industrial sites any less fairly than the cpbc “Ruling” party and officers?

Especially going by their proven Local Planning track record!

Under Cllr Riley’s regime Canvey fared better than during any of the previous attempts at Plan making.

Now Cllr Riley has been side lined by the Triumvirate now in control, and previously chiefly responsible for the 2014 daft Local Plan, despite two of them apparently also claiming to support the 2016 Plan’s attempt to constrain the borough’s Housing Numbers!

To mainlanders these thoughts may sound pessimistic and overly cautious, however being fed rumours and not having the access to decision makers that some residents appear to have, however furtive, leads to a lack of an Open and Transparent Local Plan process.

Faith in Leaders must be Earned, Blind Faith is a dangerous option.

PLANING-APPEAL-SIGN

 

Canvey Island development Free for All! Environment Agency weak approach encourages Castle Point Council’s laissez-faire attitude to Planning!

Are you sitting Comfortably?

Then I’ll begin –

“The (Canvey Island) application site is located within Flood Zone 3a, which has a high probability of flooding. Looking at the whole of Castle Point District it would seem that there are areas within Flood Zone 1 that could accommodate this form of development.

However, given that the only areas of Flood Zone 1 in the district are on the “mainland” part, such an approach would direct all new development towards Benfleet and Hadleigh.

Canvey is a self-contained community with its own housing needs and directing all new development towards Benfleet and Hadleigh could have an adverse impact on Canvey socially and economically.

Furthermore, a need for housing on Canvey cannot be met by building around Benfleet and Hadleigh due to other constraints such as the Green Belt.”

So says the cpbc Planning Officer as the latest attempt to convince residents, councillors and, no doubt the Planning Inspectorate, that castle point council’s approach to the application of the Flood Risk Sequential Test is morally sound!

July 2014photo3

Going back just 10 years things were different and the Environment Agency held a more cautious and responsible stance:-

Extract from the 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.”
The 1953 Canvey flood claimed the lives of 58 people.

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,

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”

Disappointing then, that following the Summer Flooding of 2014 the cpbc chief executive officer should point out that the Canvey Island drainage system – was never intended to be able to cope with Tidal Flooding of the Island!

But of course the findings of the cpbc Scrutiny Committee’s meetings to discuss the flooding and its consequences, during which the ceo made the admittance, has never been published, despite the flood occuring 4 years past!

To enforce the Association of British Insurers position, above, the Flood Re scheme to guarantee affordable house insurance against flooding does not cover houses built since January 2009.

Has Caveat emptor, been anymore appropriate?

I have been reminded by a sceptical mainlander that, “IT IS HARD TO FOOL PEOPLE, BUT IT’S EVEN HARDER TO CONVINCE PEOPLE THAT THEY HAVE BEEN FOOLED.”

The short EA video below may give you some insight as to the sensibility of those that propose and support the over development of Canvey Island and whether the drainage system could ever be made capable of alleviating Flood Risk!

The EA expert’s explanation of how the drainage System is designed to work, appears to be far different to the practical experiences during 2013 and 2014 and the isolated Flooding incidents during other periods!

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

Canvey Island, is synonymous with Flooding.

rebecca_harris_mp_flood_free_homes

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.