Tag Archives: Flood Zone

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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Canvey Island Population set to grow despite, ASPIRATIONAL Sea Defence improvements and Flood Re Insurance being unavailable!

A “proposed” new development of Flats for Canvey Island that WILL receive Approval from Castle Point Council reveals 3 serious issues.

Firstly it is correct to point out that the proposed Flats are in the Canvey Island town centre, and if anywhere is to be developed here is more appropriate so as to assist the regeneration of the town centre Retail outlets, under threat from out of town local authority preferences.

The first issue is the continued increase in population in the Flood Risk Zone of Canvey Island. Castle Point councillors and officers appear to be relaxed and show little moral concern in locating more and more people into an area at some risk of both surface water and tidal flooding.

Secondly a point given no relevance by the same Castle Point members and officers is that Canvey Island, being a FLOOD Plain is reliant on its sea defences.

 

sea wall damage

Previous damage acts as reminder of the Tidal power.

 

These sea defences will need to be raised and improved prior to the year 2100, as clearly explained by the area’s Strategic Flood Risk Assessment, to prevent potential over-topping! The potential for a breach in the defences remains.

Whilst the Environment Agency, recognising Canvey Island is a “special case”, emit the music to Castle Point’s ears “have no objection to the proposals”, however in this case feel it of the most importance to make very clear to our Local Authority the uncertainty that faces Canvey Island’s sea defence!

The EA warns;

“The TE2100 Plan is an aspirational document, rather than a definitive policy, so whether the defences are raised in the future will be dependent on a cost benefit analysis and the required funding becoming available.”

“When determining the safety of the proposed development, you should take this uncertainty over the future flood defences and level of flood protection into account.

This may require consideration of whether obtaining the funds necessary to enable the defences to be raised in line with climate change is achievable.”

Thirdly, much has been said about the benefits and protection that the Flood Re insurance scheme delivers. However this scheme will NOT benefit residential properties built post January 2009!

As a director of the Flood Re scheme pointed out to the Canvey Green Belt Campaign group, the idea of the insurance scheme is NOT to encourage development in Flood Zones!

Going by previous development committee meetings you will not hear these 3 matters discussed. Officers will make a strong point of informing members that the Environment Agency “have no objection to the proposals”.

Consequently, the level of population of Canvey Island at Risk from Flooding, continues to Grow!

Will the Castle Point development committee swallow this? Going by recent decisions YES!

Persimmons refuse to give up on Canvey Green Belt development.

Being fully aware that Canvey Island is affected by Surface Water flooding issues and potentially Tidal flooding issues these “Prospective” developers are also aware that development regulations leave them supposedly charged with not increasing flood risk off site.

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The National Policy Planning Framework  goes further, it expects developers to lessen off-site flood risk;

 “a site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall.”

Persimmon, possibly having noted the leniency with which the castle point council development committee apply rules and policies, admit that their proposed development at the Dutch Village does not comply with the NPPF, expecting Canvey Residents to take comfort that their development will only increase flooding a little!

Persimmons latest HYDRAULIC MODELLING TECHNICAL NOTE states;

“For all events considered, the proposed development is shown to have a very small impact on flood risk elsewhere. During the 3.33% AEP event, differences are small, with a minor increase in maximum depths of <50mm along Dyke Crescent – a highway already flooded by approximately 200-250mm. These small relative increases are isolated to flooded highways only, no properties are effected.”

Homeowners in Dyke Crescent and Limburg Road beware!

Canvey Island, Dutch Village, Green Belt development Refused, but don’t mention the “F” word

A Unanimous decision to Refuse the Dutch Village, Holland Avenue Green Belt planning proposal was decided upon by the Castle Point planning committee last evening.

Objections from both the Environment Agency and the Lead Local Flood Authority, made the decision fairly obvious, although with CPBC you can never be certain.

At last the area was given the Green Belt recognition and respect that has been overdue. Previously the area had been the first in line for release for development. The Local Plan2016 shifts focus onto previously developed Green Belt, land that already contains a level of development, as that which is preferred for housing supply.

The fact that the Holland Avenue site is Green Belt within a Flood Zone should have offered more protection from development than most in the Borough, however logic doesn’t always prevail.

The reliance upon our “impregnable” sea defences, which by the way can do little to halt water seeping under them, and our “broken” drainage system, should result in a Sequential Approach to development. If similar development areas outside of the flood zone are available, then development in the flood zone would be Refused.

However using the overly simplistic logic, that Canvey is a “Special Case,” due to Canvey Island being a developed area it must follow that it must be continued to be developed!

The officers report offered no other reasoning nor explanation, than that!

A case was offered by us that the development in a flood zone, Sequential Test decision was challengeable, as was the Exception Test, which was actually mentioned as being failed in the officers report. We asked that both Tests should be recorded as Reasons for Refusal, most disappointingly councillors allowed this to slip the net!

couriermail.com

Members agreed that the access to the proposed site was inadequate, hardly surprising considering the condition and specification of the approach road, which we must add past planning administrations had allowed approval.

IMG_0324 (2)

Thankfully the “F” word wasn’t uttered by development committee members although in this instance we mean the “Flood RE” word.

Consideration should be given by as to whether the development committee can be assured that housing development in a Flood Zone will be able to obtain flood insurance over the life time of new dwellings.

The Flood RE scheme, which guarantees affordable insurance to such new dwellings, excludes all development built since 2008!

Therefore, as in the case of Canvey homes flooded in 2013 and 2014, insurance premiums and excesses are open to the market forces, meaning insurance premiums and excesses if offered, are extortionately high.

Whilst the Canvey Green Belt Campaign group made this point in representation, the issue received no consideration.

This is quite incredible as we hear that funding is neither identified nor allotted for improvements for the sea defence nor improvements for the drainage system.

ostriches-head-in-sand

Non-discussion will not exempt Castle Point Council from blame. A head in the sand attitude towards this evidenced Risk is a gamble. A gamble with residents and future residents, financial assets and well being. A gamble with the socio-economic stability of Canvey Island.

We welcome and endorse the committee’s decision, but  will continue to press for a realistic approach to local planning matters.

A link to the committee meeting can be reached HERE.

More Castle Point Green Belt identified for housing. Blinking Owl, more like Blinking Hopeless!

The irony within discussions on Castle Point’s Green Belt was not lost on residents.

The draft New Local Plan Task and Finish (T+F) group met last evening with the agenda concentrated around the feasibility of the site best known as the Blinking Owl, or H18.

This site, despite officers indicating the difficulties, appeared to be receiving support for development from the “Council.”

The proposal of site H18 is projected as a means of saving other mainland Green Belt sites threatened with housing development.

Whilst some areas of Green Belt are considered a sacrosanct constraint on development, this site, alongside Canvey sites appears not, hence the irony.

Officers pointed out that should the Blinking Owl site be considered suitable for development it would be considered additional land to the Green Belt areas that are already included in the draft Local Plan!

The argument for H18, is that there is potential to affect less residents, has closer links to the main road arteries outside of the Borough.

However the access to main highways are problematical and un-funded.

The T+F group in the end decided to defer further exploratory work on the Blinking Owl site until the group had reconsidered the Borough’s Housing constraints findings and responses.

The officers’ case, as in development issues on Canvey Island, was opinionated.

They portrayed the negatives, for instance 18.1% of consultation responders objected to the proposal for H18, rather than81.9% didn’t object!

In itself this showed a remarkable display of sympathy for residents, you may remember, our Referendum of over 6,500 Canvey residents with 99.13% in favour of no further development of Canvey Green Belt, resulted in no concession by our local authority. Canvey Green Belt sites were in the Plan from day 1 and remain in the Plan now!

This despite the fact that Canvey Green Belt sites are also in a Flood Zone.

The T+F group whilst touching upon the fact that Flood Zones were a physical constraint on housing development, focussed on Green Belt, itself a policy constraint, being almost sacrosanct.

Cabinet member cllr Isaacs suggested that the Environment Agency had imposed a 12 month moratorium on development on Canvey Island. The officer explained that in fact the EA had suggested they were unwilling to commit to withdrawing objection until the results of the Integrated Urban Drainage study of the Island’s assets was completed and the implications understood.

It further emerged, within the Agenda paperwork, that the current estimate for the necessary investment in infrastructure for Castle Point stands at £133,000,000.

This figure does not include the likely funds required to implement the improvements identified following Canvey’s Integrated Urban Drainage study.

The Canvey Green Belt Campaign group, alongside the residents of Canvey Island support the Councillors in their defence of the Green Belt.

We hope that by identifying the Blinking Owl site does not mean that our currently constrained proposal for 200 new dwellings per annum will be adjusted to nearer the identified housing need of 320 homes per annum.

We also hope they can introduce a more moral methodology to their constraining argument, where their preference for placing new residences in a Flood Zone even if other sites are available, has no place.

Suggestion was made by an experienced councillor that the decision to defer further exploration into the feasibility of the Blinking Owl site may have jeopardised the Jotmans Farm Appeal fight.

Cllr Sheldon and a senior officer “explored” the exact meaning of certain Government Planning Guidance. And cllr Dick mentioned his full Council motion to consider whether the scrapping of the current version of the draft New Local Plan had merit.

Overall where the Castle Point Local Plan process is concerned, not so much Blinking Owl as Blinking Hopeless!

The webcast of the meeting is available HERE.

“Don’t mention the Floods!” New Castle Point Flood Risk Management Plan consultation debated.

Castle Point Cabinet “debated” the new Environment Agency (EA) Draft Flood Risk Management Plan that is out for consultation. A subject having great concern in the recent few years locally, not least for Canvey Island.

During the previous two years, storms have highlighted how the Canvey Island drainage system has been found wanting through ill-prepardness, lack of maintenance and basically of limited capability, in light of the topography of the area.

View of Canvey Island flooding from Police Helicopter July 2014

View of Canvey Island flooding from Police Helicopter July 2014

The two existing flood Plans, the Surface Water Management Plan (SWMP) and the Strategic Flood Risk Assessment SFRA) are open to criticism.

Firstly, the SFRA delivered some months late, in fact causing the suspension of the Examination in Public of the Core Strategy!

This delay appeared to be caused by CPBC,  realising the foreboding manner of presentation of the draft documents contents, meeting with the EA so as to finalise a less sensational and public concerning document with it’s producers Scott Wilson.

This was made more evident by the empty chair, vacated by Scott Wilson’s representative, at the Core Strategy Examination on the day that Flood Risk in the Borough was debated!

The fact that CPBC published a local Plan, with the housing growth distribution agreed (on Canvey Green Belt), ahead of  evidence from the Flood Risk Assessment was indication itself that “Local Factors” was influencing decision making!

The continuing reassurance that our sea defence is the finest in the UK is all well and good, however it is not the finest in Europe, by some measure. It is the best that could be afforded at the time. God forbid it is not tested in the same way that the drainage system was during the August and July floods. Ongoing work is required in the medium term to maintain the standard of its defence.

Residents should not be under the assumption that the drainage pumps will cope with flooding should the sea defence be breached.

The SWMP, gleefully adopted by the CPBC as it misleadingly indicated the mainland was at a higher risk of flooding compared with Canvey Island, is another document with serious issues.

Unfortunately the desk work failed to prepare us for the practical effects from flooding felt by residents of Canvey Island during 2013 and 2014.

There are serious faults in this SWMP that the Canvey Green Belt Campaign group have documented and challenged the Environment Agency over.

Input of historical events by CPBC officers have been a hindrance, and the checking of detail found wanting.

Further probing by us has led to the document’s whole relevance being doubted. A fact endorsed by the EA.

The apparent esteem in which Scott Wilson is held in by CPBC cabinet is correct, except where local interference of their documents effectively dilutes the messages contained within them.

The trivialising of debate by certain cabinet members was illustrated by the patronising response by one member, who defended an officer under question, with the comment: “we have professional officers who are professional!”

Don't mention the war, Pike!

Don’t mention the war, Pike!

Locally the positive shift of responsibility for flood risk onto one lead authority,Essex County, appears to be an opportunity to direct blame for previous misdemeanours, inappropriate levels of housing growth, lack of an emergency evacuation plan etc, onto the newly appointed responsible agency.

The value of green open space, the dykes, ditches and rivers in the drainage of Canvey must be realised and their status maintained.

Green Belt protection, agreed by Planning Inspectorate and Government, raises hopes in Castle Point!

During the meeting with the Housing Minister, Castle Point mainland Green Belt groups and the Council Leaders heard Brandon Lewis refer to Planning Appeal news that he was not at liberty to give details of until an official announcement was made.

Brandon Lewis

Possibly he was referring to the proposal for 500 dwellings on Green Belt in Aveley.

The Government have backed the Planning Inspector’s decision to refuse the development. Previously, under these circumstances, the Inspectorate’s decisions have been somewhat at odds with Government Guidance.

The Aveley decision is despite the local council having a “significant shortfall in its 5 year housing land supply.”

“the Secretary of State agrees with the Inspector that the development would reduce significantly the openness of this part of the Green Belt. As noted at IR14.10, the proposal would result in the permanent loss of some 14.5 hectares of Green Belt, harming the fundamental aim of the Green Belt to prevent urban sprawl by keeping land permanently open.”

Furthermore:

“the Secretary of State agrees with the Inspector that that the proposed development would cause some harm to the Green Belt purpose of preventing the merging of neighbouring towns.”

“the Secretary of State agrees with the Inspector that that the proposed development would encroach into the countryside, at least to some extent, and therefore that there would be some harm to this Green Belt purpose.”

“the Secretary of State agrees with the Inspector that that the proposed development would not intrude unduly into the views identified at IR14.17 and that its impact on the character and appearance of the area would be limited (IR14.31). Accordingly he gives this only limited weight.”

So it now appears, as in the Glebelands Appeal, where the Government considered that harm to the the Green Belt purposes should be not be added accumulatively, the Planning Inspector is now in agreement with this approach in considering harm.

Affordable housing was not considered sufficiently covered. The old Local Plan, similar to Castle Point’s, required a 35% allowance, however locally we have seen the affordable housing requirement being adjusted by our local authority down to nearer 10% !

 “The Secretary of State agrees with the Inspector that, in this case (Aveley), the combined weight of the contribution of the proposal to housing land supply and the limited weight that can be afforded to the provision of some affordable housing and the education contribution, does not clearly outweigh the substantial negative weight he attaches to the Green Belt by reason of inappropriateness, loss of openness and permanence, and conflict with at least three of the five stated purposes for Green Belt, and the additional limited weight he attaches to the harm to the character and appearance of the area.”

“On balance therefore, the Secretary of State concludes that very special circumstances to justify the proposal do not exist in this case (IR14.75). Even if the Inspector was incorrect in her reasoning in regard to the matter considered at paragraph 26 above, the Secretary of State considers that although the balance of benefits and harms would shift in those circumstances, this would not, in his view, alter the balance sufficiently to establish very special circumstances and justify grant of planning permission.”

This, Aveley, decision further supported the hopes of Castle Point campaigners that their own Green Belt sites can be protected.

Across the country there is a need for housing, locally we are considered to have a poor record in supply. We also do not have a current 5 year supply of housing land.

Recent decisions suggest that whilst the Local Plan is being processed it can be assumed there is a level of protection for Green Belt against development.

This will be used in support of the Thorney Bay development proposal, despite the locality of this site, being in a Flood risk Zone 3 area and in very close proximity to the Calor Gas hazardous site.

The Thorney Bay area, not being in the Green Belt, will not be afforded that status’ protection despite the fact it may be an unsuitable area to propose for permanent dwellings.

The main problem with Castle Point’s Green Belt may be to follow in the Local Plan’s Examination.

There is, I gather some further investigation into the feasibility on whether the Blinking Owl site may yet be available for housing development, despite that its position may be considered to fulfill the GB purpose of preventing towns merging.  This is a large site that is capable of realising in excess of 1200 dwellings.

Developers will be observing and concerned should this site be formally added to the medium term Local Plan housing supply.

These developers will, in support of their own site’s suitability, point out that their sites had been indicated as available and suitable within the Castle Point Local Plan within the first 5 years housing supply.

In effect the Castle Point Council have suggested, by voting that they considered the draft New Local Plan suitable for consultation, that local Green Belt is available for development.                                                                         And there is quite a lot of it that the Plan indicates suitable for  release!

What developers could be claiming is that Castle Point’s consideration of Green Belt release, rather than being decided by Planning Practice, with its 5 Purposes of the Green Belt etc, could be being “out-weighed” by Residents’ Preference.

Developers will suggest that that is localism gone too far.

This may well not be decided by local decision makers, but by an Inspector and / or the Government at Examination or Appeal.

The Government puts great store in the house building industry driving the economy back onto the track.

The NPPF has sustainable development as the “golden thread” running through it.

Green belt is important to local residents, hopefully not just on the basis that housing is not developed in their own locality.

There will need to be a balance between developing in the “correct” places and Green Belt protection within the Local Plan.

The level of protection afforded to Green belt sites under threat of development at present, is directly affected by the stage of progress the Local Plan has reached. Green Belt boundary consideration during this process will be expected and examined.

The new Local Plan will need to be re-addressed carefully and skilfully if housing need is to be fulfilled and Green belt protected.