Tag Archives: Flood Risk

Canvey Island Residents left Bamboozled by Flood Protection Funding Maze!

The flooding of Canvey Island during the summers of 2013 and 2014 and the ongoing concerns of a repeat event have been the subject of recent local news reports and social media posts.

A recent visit was carried out by the Government under Secretary of State for the Environment, Thérèse Coffey MP to meet a delegation of CPBC councillors and officers and representatives of the multi agency partnership to view the work carried out so far in response to the 2014 flooding.

Press reports suggested that time was spent observing the achievements rather than viewing areas of the Island’s drainage scheme that remained to be upgraded.

For instance, Essex Highways have accounted for a promised routine improvement of Canvey’s road gully maintenance, whereas in fact certain roads gullies on the Island have not received any cleansing for a number of years! And yet apparently huge sums of central funding has been claimed by ECC, whilst routine work is neglected.

Essex Highways claim, “that (they) have shown its commitment by investing more than £1 million of additional funding to help tackle localised problems such as blocked gullies”, appears to have gone unchallenged by cpbc representatives, whilst they should be fully aware that regular routine maintenance is not carried out, except perhaps in those areas that were previously reported flooded.

The implication in this case being, prevention is not better than cure!

It cannot be denied that keeping the profile high on the amount of work needed to upgrade Canvey’s drainage system is a very good thing, but the release of central funding must be used on tangible works.

Canvey residents, whose properties suffered from the flooding during 2014 have been urged to make a claim for a grant towards installing Flood Prevention measures.

This encouragement to claim by council officials, appears to indicate a concession that future flood events may well occur, despite the work carried out so far, or that the maintenance programme and upgrading of the drainage system, reliant on the £24,000,000 grant from Government, may well not be forthcoming.

However, the ease of residents seeking access to funding for the installation of flood prevention measures appears not so easy to locate, despite the encouragement from local representatives.

A visit to our local authority’s website seeking residents funding reveals only;

Castle Point Council

“Council Tax Discount for properties affected by flooding on 20th July 2014. Deadline Extended to 30.11.2014”

Using a little initiative a search for and read of the famous 6 Point Plan reveals a lead;

“Following detailed investigations, the group envisages this scheme benefiting around 15,000 high risk properties – or around 40,000 residents – on the Island. It is estimated that these measures will require an additional £500,000 of allocated funding to support the PLP package, which was introduced in September of this year. This scheme will continue to be run and managed by Essex County Council in their role as Lead Local Flood Authority (LLFA).”

The impliction being all properties on Canvey are subject to some level of surface water flood risk.

This led us to then log onto the ECC website where upon, using a couple of search words the following was discovered, an application area for qualifying residents of the whole  of Essex, not just Canvey Island, to claim for flood prevention measures. Disappointingly the situation is not as rosy as some, having suffered flooding, may have wished;

Essex County Council

“Please note: Due to the high number of applications, we’re currently unable to confirm if your application will be successful.

We will notify you as soon as the status of your application changes.”

It is a concern that an element of transparency regarding whether some of this may be old or new money being granted and whether grants are being used in central budgets, as we know of the multi agency partnership Essex Highways for one, are over stating their commitment!

The Castle Point Conservatives post on social media from the MPs and delegates meeting reads;

Thérèse Coffey MP, the Parliamentary under Secretary of State for the Environment, visited Castle Point at the request of local MP Rebecca Harris. The Minister was invited to see the joint work that Essex County Council, Anglian Water, the Environment Agency and Castle Point Borough Council have undertaken to reduce the risk of future flooding and hear what progress has been made on the Six Point Plan Proposal.

Canvey Island was especially badly flooded in the summers of 2013 and 2014 and in the aftermath of the flooding a Multi-Agency Partnership (MAP) was formed between Essex County Council, Anglian Water, The Environment Agency and Castle Point Borough Council to prevent future flooding. The MAP created a 6 Point Plan setting out actions that the agencies could undertake to increase resilience to surface water flooding. The Plan includes: property level flood protection; dredging Canvey Lake; Increasing capacity of the drainage infrastructure by building an Integrated Urban Drainage Model for Canvey; create the Canvey Resilient Communities Programme; development of innovative flood management technologies and investment in green surface water storage.

During the visit the Environment Agency’s Eastern Region Deputy Director, Charles Beardall, and Anglian Water’s Head of Flood Risk Management, Jonathan Glerum, explained to the Minister the work done so far on the Integrated Urban Drainage model and the significant investment made into the various pumping stations around the Island and on the Benfleet Creek Barrier.

The Minister also visited Canvey Lake where Castle Point Borough Council’s CEO, David Marchant, and Essex County Council’s Head of Environment and Flood Management, John Meehan, updated the Minister on the progress made on the 6 Point Plan to date. They also touched on future challenges facing the MAP.

Following the visit, Environment Minister Thérèse Coffey MP said “Protecting people from flooding is an absolute priority, which is why we are spending more than £1 million to refurbish floodgates and on work investigating new local defences on Canvey Island.

“I was delighted to see first-hand what’s being done on the ground to better protect the community and will continue to follow the work with interest.”

Commenting, Castle Point MP Rebecca Harris said “I would like to thank the Minister for taking the time out of her busy schedule to visit Castle Point. We have made real progress to ensure that residents don’t suffer the terrible flooding of 2014 again and I am pleased that the Minister had the chance to see the progress first hand. There is still however more to do and I will be making sure that the County Council, Borough Council, Anglian Water and Environment Agency continue to work well together.

Cllr Ian Grundy, Essex County Council Cabinet Member for Highways, said “Essex County Council is proud to be part of the Multi-Agency Task Group which works to reduce the flood risk in Canvey. Friday’s visit from MP Thérèse Coffey offered a welcome opportunity to increase awareness of the key challenges we all face and how we are working collaboratively to find solutions.

“Since the task group was formed in 2014/15, Essex Highways has shown its commitment by investing more than £1 million of additional funding to help tackle localised problems such as blocked gullies and defective pipework in Canvey. We are also investing a further £500,000 over the next two years to address broader drainage issues. Our colleagues in Flood Management have invested £600,000 and will have protected 100 properties as part of their Property Protection scheme and have done numerous floods studies to target our future investments

“Essex Highways and the Flood Management team pride themselves on being innovative in their approach to deliver more, for less, for the taxpayer. We will continue to be a keen contributor to the work of the Multi-Agency Task Group, with a focus on delivering greener, more sustainable solutions to help solve these issues.” “

Jonathan Glerum, Anglian Water’s Head of Flood Risk Management, said “We were delighted to welcome the Minister to Canvey and show her the great partnership work that has been delivered. The approach to multi-agency working that has been developed on Canvey is a game changer and has delivered significant investment in flood mitigation on the island.”

“Anglian Water has invested over £2million on improvements to our drainage network on the Island and is committed to continued working with partners, and Government, as we look to develop and deliver innovation solutions to flood risk management for Canvey.”

Environment Agency’s Eastern Region Deputy Director, Charles Beardall, said “The day was a great opportunity to highlight the scale of the Environment Agency’s investment on Canvey, from our ongoing maintenance work to significant improvements to the protection of properties from main river flooding. It also gave us a chance to showcase our work with partner organisations as they look at future options to reduce surface water flood risk.”

Castle Point Borough CEO, David Marchant, said “All of the agencies involved were able to demonstrate to the Minister how much progress they have made since the disastrous flooding of 2013/14. Working together we have invested or plan to invest nearly £6m in accordance with the Six Point Plan to ensure the existing network operates as effectively as possible. However there is still more to do but the unique nature of the drainage system means that innovation in design is necessary particularly when the essential balance between the environment and critical drainage infrastructure on Canvey Lake has to be maintained.”

Canvey Councillor Ray Howard MBE, Castle Point Borough Council’s Cabinet Member for Waste and Flooding, said ‘It was very encouraging to have a Minister of the Crown visit Canvey Island. The Minister showed a great interest in our previous flooding problems and assured us that her department would do all they could to assist in future flooding matters’.

One thing appears absolutely clear is that despite some claims to the contrary, the possibility of a repeat of the devastating events is now accepted by many agency representatives!

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We Must Build on Canvey Island in the interests of Sustainability, regardless of no future plan to Care for those made Homeless! And Inside Housing Report on Thorney Bay.

Soon Castle Point Council may well be faced with a Housing problem. One that has not been publically discussed, but nevertheless will one day soon need to be addressed. One that is out of the local authority’s ability to address or control.

Thorney Bay is “Home” to many people and families who, through no fault of their own, are in need of decent living accommodation.

Thorney Bay Beach Camp, Canvey Island, Essex

copyright Jason Hawkes

Some families may have been relocated to Canvey Island from distant areas, and now consider Canvey AND Castle Point their home.

Castle Point Council point out;

“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. To this extent the proposal does therefore have sustainability benefits. However, it must also be remembered that at the present time the site is occupied by park homes. These are single storey, relatively lightweight structures, which would offer little resistance to flood waters. The replacement of these structures with robust brick buildings, incorporating flood resilience measures and providing safe refuge in the event of a flood is considered to represent a significant sustainability benefit which far outweighs flood risk. In risk terms the proposal is considered to offer significant benefits for occupiers of the site”.

So as far as the “No Threat from Tidal Flooding” brigade are concerned, CPBC are also, it appears scare-mongerers! Or at least they are when it suits them!!

How kind of them to consider that they are compelled to continue developing on Canvey, for our own benefit!!!

Never mind that the increased Population and Property at Risk on the Island may have less sustainability benefits, and indeed may cause Economic Blight!

The substantial Land Raising that has been carried out on the Thorney Bay site, appears to be of little or no concern of Castle Point Council, this despite the implications for off-site Flood Risk, both from Tidal and Surface Water sources, to neighbouring properties in the Thorney Bay area!

Currently Thorney Bay has been identified in “recent” draft editions of their Local Plan as being allocated for Housing development of in excess of 600 dwellings.

Permission has been levered through,by CPBC development committee,  for a first phase of 89 Detached Dwellings plus 24 Flats.

Surprisingly, or perhaps Not, prior to any “bricks and mortar” dwellings, which would offer more “resistance to flood waters”, the site owners are going ahead with installing a new Park Home estate.

A Park Homes development at Thorney Bay, or Sandy Bay, presumably will side step the “agreed” requirements for the developer to provide;

affordable housing, £241 per Resident Dwelling towards the provision of adult social care, £73,774 per 100 Residential Dwellings towards post sixteen education services, £97.42 per Residential Dwelling towards adult education services, Net Early Years and Childcare Pupil Product contribution, £281.48 per Residential Dwelling towards the County’s library services on Canvey Island, additional access onto Thorney Bay Road in the form of a roundabout junction and access road, this Schedule requiring the Developer and Owner to transfer free from incumbrances the Roscommon Way Phase 2 Land to the County or the County’s Nominee, the provision of a 19m undeveloped and unfettered development protection zone, measured from the landward toe of the existing tidal defences and the financial contribution of £100,000 Index Linked towards the capital construction costs of the first phase of tidal defence improvements required by c.2040. 

CPBC themselves, appear to have a very low and demeaning opinion of the current occupants of Thorney Bay, indicating no comments on the local authority’s responsibilities towards their likely re-homing requirements;

” It is considered that Thorney Bay has contributed in the region of 330 additional permanent residential homes to the overall housing provision within Castle Point in the period 2001 to 2011.”

” Due to the relatively low costs of this accommodation compared to that on offer in London, the site has been advertised there, attracting a large wave of migrants in addition to local people in need of cheap and/or quickly available accommodation. This has resulted in the rapid creation, since 2006, of a low income, vulnerable community including many families with children.”

“when compared to other local authority areas in England, Castle Point has the 2nd highest proportion of households living in caravans in 2011.

In 2001 Castle Point had the 31st highest proportion of households living in caravans.”

“Due to these issues there is support for proposals to redevelop a significant proportion of the site (Thorney Bay) for traditional homes. However, it is the intention of the owner to retain a smaller caravan park of 300 caravans for residential use towards the west of the existing site.

The Council need to consider how it will ensure that the socio-economic issues that have arisen on the larger site do not occur again on the smaller site, and also how this smaller site should be brought forward in a way that co-exists happily alongside the larger community as Holehaven Caravan Park, Kings Park and Kingsley Park do.

In this regard it is recommended that the Council work with the Thorney Bay owner to ensure that the quality of accommodation, the tenure arrangements and the pace of provision are appropriate to ensuring the health and well-being of residents and creating a more stable community.”

“Thorney Bay meanwhile, also experiences issues associated with unemployment and crime. There are also a number of young people living in income deprivation upon the site. This has long-term consequences for the ability of these children to achieve their potential, and for the community in terms of supporting an economically inactive population. “

“Thorney Bay however has wider implications for the local community and the local economy. The use of mobile homes for accommodation has acted to concentrate low income families, resulting in a concentration of unemployed people, children experiencing income deprivation and increased criminal activity. “

This issue has been picked up on by the UK’s building and development press:

Inside Housing article

Thousands of people on low incomes are choosing to live in caravans and mobile homes.

Martin Hilditch uncovers a hidden world that raises questions about the housing benefit system.

” Leanne McGowan lives with her daughter and two sons in a three-bedroom caravan in Canvey Island. It’s a squeeze. Her three-year-old son and seven year-old daughter share, while Ms McGowan and her fourteen-year-old son sleep in the remaining rooms.

Lack of options

The kids are at school now, but their scattered playthings mean their presence is still felt – a toy gun and motorbike lie on the floor and four Teletubbies are lined up like ornaments on a shelf in one corner of the room.

Ms McGowan occupies one of hundreds of static caravans that are sandwiched between a small, sandy beach and the looming terminals of a Calor Gas plant. She’s lived on the site for two years and housing benefit covers most, but not all, of the rent. She has to pay£18 a week top-up to cover the remainder. “It ain’t easy,” she says.

She ended up on the site after the landlord of the nearby private rented home she previously lived in sold the house.

“I didn’t have a choice when I moved here,” she says, adding that she thought the move would “just be short term”. But trying to get into another house that is affordable on housing benefit has proved impossible. “I phoned up all the [lettings] agents,” she says. “They never have anything at all.”

She’s lived in the caravan ever since. “It is cramped,” she admits, saying ultimately that “I don’t think it is suitable for families to be in here.”

Sitting between two electric heaters, Ms McGowan admits that the caravan gets “ever so cold” in the winter – and keeping it warm is an expensive business. She has spent £4 on heating in less than 24 hours. In the winter months the family sometimes keeps warm by effectively living in the lounge. “We get the mattresses in here,” she says. “We sleep here sometimes, yes. I don’t mind being cold, but it’s the kids. It is like we are camping out in the front room.”

The site itself is “not a bad place to be”, says Ms McGowan, who is on a waiting list for a council home.She adds that it’s well-maintained and there’s a friendly atmosphere. “There are some nice people on here and they look after each other,” she says. “It’s nice in that respect. We are all in the same situation.”

She’s not wrong there. In fact, there are currently 268 housing benefit claims registered to addresses on the site. Research carried out by Inside Housing this year has revealed Canvey Island’s Thorney Bay Village has more housing benefit claims registered to it than any other caravan or mobile home site in the UK. Last year, £1.9m of housing benefit was paid to addresses here. Our investigation reveals that the residents of Thorney Bay Village are far from unique. In fact, we found that there are thousands of people on low incomes currently living in caravan and mobile home parks across the UK. Responses received between May and August this year reveal the 271 councils that provided information to Inside Housing made more than 12,000 housing benefit payments to addresses on caravan and mobile home parks in the UK – with 11,162 of these being made in England (an average of 47 claims per authority. See box: Caravan counts).

The payments, obviously,do not reveal people’s motivations for making these choices – and clearly there will be variations in quality between permanent mobile homes and holiday caravans that people are occupying permanently.Nonetheless it does reveal a significant number of people living in non-traditional housing that the majority of councils know next to nothing about. Almost everyone Inside Housing spoke to at Thorney Bay Village cited affordability as one of their central reasons for ending up on the site.

The research certainly raises some serious questions, according to Matt Downie, director of policy and external affairs at homelessness charity Crisis.

“This investigation has revealed millions of pounds of benefits being spent on keeping people incompletely substandard living conditions,” he says. “This sorry state of affairs is a direct result of cuts to housing benefit combined with the failure of a succession of governments to build enough decent, affordable homes.”

Certainly, the availability of housing benefit is driving decision-making for a number of residents living in Thorney Bay Village – and housing benefit did not even cover the full rental cost of a caravan for any of the occupants Inside Housing met. Rents ranged from £145 to £175 a week, based on the people we spoke to. One woman, who lives in a van with her young children, said she was topping up her housing benefit to cover the rent. She picked the site because“it was this or a hostel”, she adds.

Other residents are more enthusiastic. Dean Simmonds and Helen Davies live in a three-bed caravan with Ms Davies’ two children. Helen has lived there for more than four years since moving from her native Wales (and a Welsh flag hangs proudly outside the couple’s home). Their front room is the picture of domestic life, with paintings by the kids decorating the wall and photos of the children dotted around the place.

“I love it here,” Ms Davies says. “The camp is very clean all the time.” The couple’s van is spotlessly tidy, but Ms Davies admits that the festive season is more complicated when you live in a caravan. “At Christmas time you have got to think about what [presents] you’re getting because you have got to find somewhere to put it,” she says with a laugh. Ms Davies pays £18 a week top-up to cover her rent, and says she has fallen slightly into arrears as a result. A similar story is told by a couple of other residents.

Clearly the fact that housing benefit can’t even cover the cost of a static caravan – when people on low incomes are choosing to live there because they are seen as the most affordable option locally – raises its own questions. Like Mr Downie, a spokesperson for Castle Point Council points a finger at the housing benefit system. The council is currently making 468 housing benefit payments to addresses on caravan and mobile home sites – more than any other local authority in the UK.

Thorney Bay’s caravanners’ struggles to cover the rent from housing benefit “is not unique to Thorney Bay”, the spokesperson suggests. “This is the story behind the majority of housing benefit cases within the private sector, where housing benefit is based on Local Housing Allowance rent levels, which do not reflect the increase year-on-year of the private rental market.”

Gathering evidence

Other councils have been investigating their caravan and mobile home populations too in recent years. In 2014, Folkestone Council found“emerging evidence from around the district that some residents are occupying holiday-let caravans as their main or sole home”. It found 45 occupants in receipt of housing benefit from holiday-let caravans. Denbighshire Council estimated that “175 individuals in the county were living all year round in‘holiday’ caravans.”

Some sites are marketing caravans specifically as a solution for people on low incomes. A post earlier this year on spareroom.co.uk advertised caravans in Greetham, Rutland for £90,stating that “DSS is welcome” and people could move into “not just a room – a full caravan to yourself at room rates”. And Falcon Mobile Homes makes an explicit pitch on Facebook to people on low incomes, asking: “Are you receiving housing benefit? If so you can rent one of our static caravans”.

Posts on property websites provide a snapshot into the lives of some people looking for or living in caravans. One 47-year-old man posting on Gumtree says he and his dog“desperately need a home as we have become homeless” and is looking for a flat,a house or a caravan. Other people are looking to move out of vans. One woman posts on behalf of her mother saying she is “currently sofa surfing from my house to a crabby broken caravan” and is “in desperate need of a home so she can have my brother live with her again”.

A spokesperson for the Department for Work and Pensions says it has “no evidence that use of this type of accommodation is increasing or that there is any link to welfare reform”.

While many councils appear to have little idea about the extent to which people are living permanently in caravans and mobile homes in their areas, some local authorities have carried out specific pieces of research – presenting them with an unanticipated windfall.

East Lindsey Council, for example, launched a review at the end of 2014 into the occupation of caravan/chalet sites and said residents had raised concerns about “breaches of occupancy at caravan sites”.

The results of East Lindsey’s research took it by surprise. It uncovered 502 residents living in mobile homes or caravans. In turn, the council effectively suggests the work has brought 502 “new” homes into use. This has led it to claim New Homes Bonus– the grant paid by the government to councils to reflect and incentivise housing growth in their areas.

Since the review was started it has successfully claimed £605,000 of New Homes Bonus for these properties, according to a council spokesperson. It’s not alone; a company called Mobile Homes Review claimed it has generated £4.2m in additional New Homes Bonus funding in 2014 by registering 700 mobile homes in seven local authority areas.

Ros Pritchard, director general of the British Holiday & Home Parks Association, stresses that more research is needed to find out if claims were being made from high-quality residential parks (that look like “lovely bungalows”) or holiday accommodation.“Residential parks are an enormous form of low-cost market housing,” she adds.

Nevertheless, the scale of housing benefit payments uncovered by Inside Housing’s investigation suggests that more research should be carried out by councils and the government into the reasons people on low incomes are choosing to live in caravans and mobile homes – and the quality of the accommodation available to them.

Back at Thorney Bay Village, we meet Paul Birch and his husband Tom. They moved to the site after becoming homeless and had previously lived in a transit van for a month. The unpacked removal boxes in the corner of their room reveal the couple don’t see this as their permanent home. They have been on the site for the past year –and say winter is the worst time.

“The winter was hell,” Mr Birch states. “It is like a fridge.” His husband says they spent £35 a week on heating the van last winter. Both are looking forward to the future – as the removal boxes indicate. “As soon as we move out, hopefully it will be onwards and upwards,” Mr Birch says.”

Hypocrisy, the Use of Substitutes, a Deciding Vote and a Divided Borough? Sequentially Unsound!

It appeared that what can only be described as a level of Hypocrisy was displayed by certain Castle Point Development Committee members towards a view suggested by the opposition group at the 5th September’s meeting!

The suggestion appeared that Canvey was, put simplistically, being targeted for development so as to protect the mainland areas. It was expressed that Canvey should not be portrayed as an individual area, rather than an equal part of the whole Borough of Castle Point.

However the whole basis of the Flood Risk Sequential Test, as interpreted by Castle Point Council, is to treat Canvey Island in isolation!

“it is considered that continued development is necessary in order that the settlement of Canvey can continue to thrive economically and socially.”

” Canvey needs continued development if it is to continue to thrive economically. A lack of housebuilding on the island could mean that the island stagnates in economic terms which is likely to affect opportunities for employment. “

Indeed the Thorney Bay proposal for 600+ dwellings  was subject to a CPBC Planning Policy statement stating that “the site was identified as having the potential to contribute towards the 5 Year Housing Supply (of the Borough)”!

Regardless of the application being considered, whether for a single unit or a proposal for over 600 dwellings on Canvey Island, it is fairly clear that using this interpretation of the Sequential Test to support development proposals, there is no likelihood of any planning proposal Failing the Test!

It is a convenient and flimsy argument to accuse Islanders of focussing on cpbc’s apparent approach to Canvey development, whilst the Sequential Test is used to do precisely that!

It should be of concern, that since Canvey land was designated for the use of Housing in the 1998 Local Plan, and that since the Sequential Test approach towards its application on Canvey development proposals was adopted by CPBC in 2007, these events have occurred and these Reports have been published;

  • The Pitt Review-Learning Lessons from the 2007 floods. (Published 2008) !!!
  • The CPBC Strategic Flood Risk Assessment published in 2010. (In itself due an Update.)
  • Surface Water Flooding has occurred on Canvey Island during 2013.
  • Surface Water Flooding has occurred on Canvey Island during 2014.
  • Government Office for Science – Canvey Island Section 19 Report
  • The requested Drainage Improvement / Upgrade funding has not materialised.
  • We learned that the land on Canvey Island has a High Water Table, subject to influence by the Tidal Water encroaching Under the Sea Defences. (Land East of Canvey Road document).
  • The Integrated Urban Drainage Study was published, which challenged the credibility of the CPBC Surface Water Management Plan published 2012.

Quite clearly the Castle Point Council approach to the application of the Sequential Test on Canvey Island in isolation, is Obsolete and Unjustified!

Attenuation Tanks were discussed as a means of a suitable drainage system. Had the committee not considered that Canvey has a High Water Table, now known to be subject to Tidal influence? In this case the Tank would be sunk into the application site property, how efficient would this system of drainage be?

Photo Police helicopter 2014

The focus of the drainage system needs to be to prevent off-site flooding of neighbouring property and land. Without going through the exercise of producing a Practical Model on Canvey island and monitoring over an extended period councillors should not be in a position to simply go by unsubstantiated opinion in their decision making!

Whilst the protection of Green Belt, which is admirable, is at the forefront of councillors minds, it must be borne in mind that Paragraph 14 of the national Planning Policy Framework contains Footnote 9, which indicates;

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

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.

Whilst this specifically relates to Plan making, it is clear that, if the concern is present amongst decision makers development in a Flood Zone and in a Critical Drainage Area, in which Canvey Island falls into both categories, caution should be the operative position to adopt.

Residents suffering the Canvey Island Flooding of 2013 and 2014 may well feel appalled at the rigid Rejection of development applications on Green Belt, whilst a less than cautious approach appears to be adopted where Flood Risk is concerned, by certain cpbc development committee members.

The cpbc officer appeared unaware that the whole of Canvey Island is a Critical Drainage Area.

The questionable use of Substitute councillors to replace two absentees at the meeting, bearing in mind the technical issues highlighted in this planning proposal, proved to be decisive, as 1 voted to Approve and 1 voted to Abstain.

With the votes recorded as 5 to Approve and 5 Against, with 2 Abstentions, the Chairman chose to use his Casting Vote, and consequently rather than holding further deliberations on the subjects contained within this post and others not mentioned, the Application was Approved!

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

 

 

 

 

 

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!