No doubt the Government Intervention team will be the fall guys should the CPBC Local Plan hit choppy waters at the Examination stage, having supposedly “pressurised” the council members into approving the latest daft Plan!
I mean, what Local Authority, in its right mind, would seek to Plan to build so many new Houses on Canvey Island, in the Green Belt, in a Critical Drainage Area, in a Flood Zone, within close proximity to 2 Hazardous Industrial sites?
Castle Point Council would for certain.
* Approving the contents of their draft Local Plan just 3 weeks before the massive expansion in the handling of volatile and dangerous fuels at OIKOS on Canvey, is made known to Residents, could be politely described as “Insensitive”.
* Approving the contents of their draft Local Plan just 3 weeks before the Surface Water Flooding across major parts of the UK, in the full knowledge that Canvey Island itself suffered similarly during 2013 and 2014, could be politely described as “Fortunate”.
* Approving the contents of their draft Local Plan, containing an ambition to see an allocation of up to 40% Affordable homes, in the same month that CPRE published their report “Space to Breathe, A state of the Green Belt”, in which was found; “Only 1 in 10 homes built on land released from the Green Belt over the past decade are ‘affordable,” “The report says that harmful development on the Green Belt, often in the guise of providing ‘affordable’ homes, is squandering this valuable asset at a time when it is needed for our own health and well-being, and to address the climate change crisis” could be politely described as “Ambitious”.
the OIKOS situation, no doubt we will have more to say prior to the Public
exhibition at the Paddocks on Thursday 21st November.
the Surface Water Flooding issues we would add that Canvey Island appears to
have been conveniently forgotten where the promise of £24,500,000 worth of funding,
to bring our drainage facilities up to some sort of standard, is concerned.
is accepted by the Environment Agency that the drainage scheme on Canvey Island
is “Complex”! And that is when it is being maintained and cleared, as so often
is not the case!
Castle Point Borough Council continue to Encourage, Direct and Approve more Housing and Population onto the Flood Risk part of the Borough, that is Canvey Island than the Safer Areas of the Borough!
It is apparent, through conversations with Castle Point
and Residents, that the draft Local Plan 2018 that you are due to consider
Tuesday evening is giving serious cause for concern.
Tuesday evening’s Agenda Item 4 at Paragraph 4.9 indicates
that you as Councillors must, for the sake of this Plan, intrinsically accept
As you will be aware, this small Borough has various Constraints on Development, such as Flood Risk, from both Tidal and Surface Water, Green Belt and the Hazardous Industries. As well as parts of the mainland, the whole of Canvey Island is designated a Critical Drainage Area,
Others may also consider traffic congestion and housing market forces are also relevant Constraining factors.
The draft Local Plan’s Housing Strategy for 15 year Plan period indicates a total of 5,295 dwellings, or 353 dwellings per annum, a figure far beyond previous completions. Taking into account current short to mid term market forces, these numbers set an unrealistic Target. The Objectively Assessed Housing Need is calculated by the Government national fixed formula and not related to local needs.
Green Belt is to be given Substantial Weight of Protection against Development, whilst requiring evidence of “Very Special Circumstances” before allowing development.
Flood Risk, of which Canvey Island is a Zone 3a area, requires the area must be Sequentially Tested. However officers have applied the Sequential Test to Canvey Island in isolation, rather than the whole of the Borough. Furthermore the Planning Framework suggests that failing that, the Test should incorporate areas further afield, ie other local authority areas. An indication that we are NOT advocating that Canvey Housing Need need not be transferred to the mainland, an area with its own issues.
It has been suggested that the area to the North west of the Borough, around the Blinking Owl site should be included within the Plan and ahead of some of the sites already included, despite officers indicating that it is unviable at present. However it is apparent that with CPBC’s partnership within the Association of South Essex Local Authorities, this site is highly likely to become strategically adopted as a Housing Development site within their Plans for the ASELA area.
A Loss for CPBC’s Local Plan due to being a Gain for an
ASELA strategic Plan!
Many of you Councillors will be uncomfortable with the proposals for Housing Development included within the proposed CPBC draft Local Plan 2018 document.
In light of the potential impact upon the Borough by a strategic ASELA Plan, the Constraints on Development in the Borough, the above average Previous Completions Housing figure proposed in this CPBC Local Plan, and the apparent fact that the Secretary of State, rather than enforcing Intervention, appears to be generous in recognising Castle Point Council’s difficulties in achieving an agreeable Local Plan, we call for you as our representatives to:
Reject this draft Local Plan.
And to instead Amend to propose a constructive and open debate with the input of all members under guidance of a Planning Inspector, in the hope that an amended document can be achieved acceptable to all Residents, Councillors and Inspector alike.
Kind Regards, the Canvey Green Belt Campaign group.
It appears that Castle Point Borough Council are far from being the only Local Authority struggling to meet its Housing Needs. Whether the Government step in to scoop up the left-overs of the various Local Plan versions devised within CPBC Runnymede Towers, or whether CPBC are Actually Attempting to resurrect a Local Plan, rather than twiddling their thumbs waiting for the Government Chief Planner, Residents remain in the Dark!
With the last version of the Local Plan 2018, voted down at the Special Council meeting, it may have been appropriate for a councillor, or a group of councillors, to have proposed a return to the 2016 version, and seen whether a concensus could have been gained on that within a council members meeting.
At least the CPBC Local Plan process would have been seen to be advancing rather than the pathetic Standstill we appear to be held in.
Whether CPBC have had word of Bad News from the Secretary of State for Housing, Communities and Local Government, James Brokenshire, but we will not be hearing officially his verdict on Intervention ahead of the May local elections, we can only surmise.
But with news from Manchester that Government Ministers and The Planning Inspectorate not appearing to be on the “same page” where the calculation of Housing Targets and indeed the Supply of Land is concerned, CPBC may well have missed a trick in not continuing to at least try to advance its Local Plan!
We have to assume that CPBC council officers have been working to fulfil the Duty to Cooperate part of the Local Plan process, if not, why not, so why haven’t councillors taken it upon themselves to work on the Local Plan itself?
A Local Plan, whether fully Sound, but at least Agreed upon, could be considered and possibly consulted upon, outside of Intervention. The Green Belt, Flood Risk and the Hazardous Industries could be debated in open Examination, rather than in private!
The Local Government Chronicle Reported on the 26th February 2019:
Greater Manchester CA mayor Andy Burnham has accused the housing minister Kit Malthouse of being ‘at best partial and at worst misleading’ over comments made regarding Greater Manchester’s plans for new homes.
The issue of whether it is really necessary to build on greenbelt land in Greater Manchester is a contentious one right now. After being beset by delays, the latest consultation on the Greater Manchester Spatial Framework opened last month and runs until 18 March.
Greater Manchester has calculated how many new homes it will require by 2037 based on 2014 household projections, in accordance with the government’s proposed methodology for calculating local housing need.
This required Greater Manchester to plan for 73,500 more dwellings than had it used more recent 2016 projections. In order to meet these targets the combined authority has earmarked nearly 64,000 dwellings on a series of greenfield sites, predominantly within the green belt.
The mayor claims that the government’s insistence on using these “outdated housing targets” had left him with “no choice” but to plan to build on green belt land. But housing minister Kit Malthouse denied that the government’s targets were mandatory.
Mr Malthouse stated that any inspector will accept a “properly evidenced and assessed variation” from that target.
“If, for example, you have constraints like areas of outstanding natural beauty or green belt, or whatever it might be, and you can justify a lower number, then an inspector should accept that.”
Mr Burnham claims that Mr Malthouse’s comments, which were made during last week’s parliamentary debate on the framework came as a “surprise” to him.
“They do not reflect current government policy,” he said. “They give a very different impression to the one offered in private by civil servants.”
“Under pressure from Conservative backbenchers, it would appear that the Government is trying to soften its line on housing numbers and greenbelt and deflect blame towards councils…It is unfair and dishonest.”
Mr Burnham claims that Greater Manchester does not believe it has discretion over housing numbers, because the government’s planning guidance says local authorities are “expected” to use the government methodology to calculate housing need and will be required to “demonstrate exceptional circumstances” to deviate from it.
The government’s target, based on its standard methodology, is to build a million homes by the end of 2020. But a report released this month by the National Audit Office, ‘Planning for New Homes’, admitted this target will be “challenging to meet”, and found the standard methodology approach has “weaknesses” and “as a result will be revised”.
Although local authorities in the South and East of England are being pushed to build significantly more new homes, the report explains that the latest standard method of assessing housing need specifies that the minimum numbers of new homes needed in some areas is now less than the local authorities had previously assessed – in the North West, by 24%.
Responding to Mr Burnham’s comments, Mr Malthouse said: “We need more homes in the right places and we are reforming the planning system to ensure this occurs. “But we have been clear that the use of green belt land should be a last resort, with the standard method not providing a mandatory target.
“That’s why we strengthened green belt protection with councils now having to show they have exhausted all other reasonable options to meet development needs before even considering changes to the green belt and then evidence exceptional circumstances to justify development.”
Copyright: Jessica Hill, Local Government Chronicle
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.
“The continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement.”
So say, Castle Point borough council planning officers in their programmed approach to avoiding objections to each and every proposal for development on Canvey Island.
This programmed response, supporting perpetual development, is in respect of evading opposition and objection to the “Special Case” position the officers are ordered to adopt in consideration of Canvey’s Flood Risk Exception test.
Whilst Constraints on development in other areas of the borough are sited and strictly adhered to, as a matter of policy, similar approach to Canvey Island proposals appear less rigorously imposed.
Given that Canvey development should be constrained by the fact that the Island is a tidal Flood Risk Zone 3a area, is now deemed a Critical Drainage Area following the surface water flooding during 2014 and previously, as well as being the location of 2 Top Tier Comah hazardous industrial sites.
That there is only one access / egress point, that the Island’s dedicated Rapid Response (paramedic) Vehicle is being withdrawn and that, like other areas the Police and the Fire and Rescue service presence has diminished.
These factors, one would think given Canvey Island’s geographical position, may cause outsiders to wonder why castle point borough council planning department should be so manipulative, when they recite such Unsound Drivel as “the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement”!
Higher up the local government ladder the planning department superiors have indentified in contrast, that on tidal Flood Risk alone, they consider that the population of Canvey Island should be limited to the level prior to 2011, OR LESS!
However cpbc Cabinet, Councillors, Officers and Planners ALL choose to ignore this apparently sensible and cautious approach to Housing Numbers, one can only assume, so as to limit the levels of apparently necessary, but unpopular, Housing Need elsewhere in the Borough!
Now whilst our local “public servants” propose and impose yet more development, both Housing and Industrial, onto Canvey Island under the pretext that, “the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement” they would do well to appreciate what is going on far from here.
Local decision makers, in their desperation to support the Borough’s income stream and limit the perceived Housing Need on the mainland, are willing to overlook potential Hazards and Constraints that should, by Rights, limit the ever-increasing Canvey Island Population Growth, through the means of our broken Local Plan process!
This Blindfolded and Wreckless approach to Development Planning on Canvey Island, has directly led to the flooding of many properties during 2013 / 2014, and is continued unabated, despite the clear warning towards adoption of a more cautious approach following the Calor escape of 163 tonnes of liquified gas forming a vapour cloud over the Island!
Whilst the efforts of the Essex Fire and Rescue Service to convince cpbc members that their vastly reduced level of cover for Canvey Island would be adequate in the event of a major accident at either of the 2 Hazardous sites, their claim should not serve as supporting evidence for continually increasing the Population of Canvey.
Castle Point, we believe, would be totally justified in adopting a Limited Population Approach to its Housing Supply through its Local Plan Process, especially where Canvey Island is concerned.
This approach would be fully justified and would protect local builders and developers alike.
An ever-increasing population has little or no justification in any of the reasons recited by cpbc in its flimsy evidence to direct the levels of development growth towards Canvey Island, indicated in their various versions of failed Local Plans .
It is Amazing then to discover that a Far Eastern Country should have adopted a Plan that puts concerns for its Population and Environment first, by recognising the Need to Limit Population Levels.
Whilst we do not compare the population levels of Shanghai and Canvey Island, it does indicate that limiting population, rather than the contrived reasoning behind the proposal for the ever-increasing population numbers policy, as applied by Castle Point Council Strategic and Local Planners!
“China’s financial hub of Shanghai will limit its population to 25 million people by 2035 as part of a quest to manage “big city disease”, authorities have said.
The State Council said on its website late on Monday the goal to control the size of the city was part of Shanghai’s masterplan for 2017-2035, which the government body had approved. “By 2035, the resident population in Shanghai will be controlled at around 25 million and the total amount of land made available for construction will not exceed 3,200 square kilometres,” it said. State media has defined “big city disease” as arising when a megacity becomes plagued with environmental pollution, traffic congestion and a shortage of public services, including education and medical care.
But some experts doubt the feasibility of the plans, with one researcher at a Chinese government thinktank describing the scheme as “unpractical and against the social development trend”. Migrant workers and the city’s poor would suffer the most, predicted Liang Zhongtang last year in an interview with state media, when Shanghai’s target was being drafted.
The government set a similar limit for Beijing in September, declaring the city’s population should not exceed 23 million by 2020. Beijing had a population of 21.5 million in 2014. Officials also want to reduce the population of six core districts by 15% compared with 2014 levels. To help achieve this goal authorities said in April some government agencies, state-owned companies and other “non-core” functions of the Chinese capital would be moved to a newly created city about 100 kilometres south of Beijing. An exact date for when those offices will have to move has not been set, but Beijing officials have already begun reshaping the city’s population.
Tens of thousands of migrant workers were evicted from their homes beginning in November, after authorities launches a 40-day crackdown on unsafe buildings in the wake of a fire. Many of China’s biggest cities also face surging house prices, stirring fears of a property bubble. Beijing and Shanghai have enacted strict rules on who can purchase property and the two cities are the most vulnerable if prices begin to tumble. Shanghai had a permanent population of 24.15 million at the end of 2015, the official Xinhua news agency said last year. The city has also said it would intensify efforts to protect the environment and historic sites as part of its masterplan.” *
As a further reminder, we make no apologies for reminding readers of the devastating effects on households Hazardous Accidents have the potential to cause, as seen in this Video recording.
Grateful thanks go to Ian Silverstein for use of his video.
*Report filed for the Guardian by; Benjamin Haas in Hong Kong and agencies @haasbenjamin Tue 26 Dec ‘17 Reuters contributed to this report
And for those who have read this far, here is a link to some music – China Crisis’ recording of “Wishful Thinking”.
Hence they held a Referendum to Protect what is left of the Island’s Green Belt, then a Petition was completed objecting to large scale development.
All to No Avail.
Both Referendum and Petition were Ignored by castle point borough council!
Now we learn that it is the intention of Rochford councillors to carry out a Referendum over the district’s Local Plan.
Councillor John Mason, leader of the Green and Rochford District Residents Group said that during the early stages of the new housing plan, residents have complained “they feel that they will not be listened to” about their council and councillors.
No doubt Rochford council will spot the opportunity of the “Tick Box” exercise, as have castle point council, in suggesting this fills the community involvement requisite!
You may well remember that the Canvey Green Belt Campaign supporters went out in 16 groups of 2, over a two week period seeking the views of residents about cpbc plans to develop Canvey Island Green Belt.
Over 6,500 votes were cast and under MP Rebecca Harris, cllrs Ray Howard and Dave Blackwell’s observation an objection via 99.13% of voters was recorded!
Typically the daft Local Plan 2014 ignored these views!
Following this a Petition was raised by a group of 6 Canvey Ladies and a total of 12,000 names were added to their Petition list. The Petition was against large scale development on Canvey, whilst the opportunity to protect the local builders could remain.
The Petition has also had No Impact with those controlling cpbc!
This despite the constraints that would normally be applied to development in areas such as Canvey!
Whilst Rochford does not have constraining issues, such as 2 Hazardous Industrial sites, being in a Flood Risk Zone 3 area, having the access issues that Canvey is restricted by nor the whole of the town being a Critical Drainage Area, we do wish the Rochford councillors success in their Referendum.
Far greater success and acknowledgement than Canvey Island residents received by the controlling group of our local authority!
The Echo article on the Rochford Referendum news is available via this LINK HERE.
I assume Cllr Martin Tucker will be enjoying a good breakfast this morning following the meeting he arranged last evening to share information on the Castle Point Local Plan’s progress.
Pic courtesy: CPBC
A refreshing amount of knowledge and interest was shown by the residents into the issues that, we feel should be given more weight in local policies.
Cllr Tucker took those attending through the Plan process through from the now out of date 1998 Local Plan, up to the current situation.
The current situation appears to be one where on the 27th January a vote will be taken on a Local Plan that is backed by very little Local Support. Councillors are being asked to consider whether they feel that the current draft version would be found “sound” and is the best that can be produced for the Borough. Or to take a last ditch opportunity to produce a more acceptable, yet still “sound”, alternative Plan.
Pressure is coming from central government to achieve a timetable that requires a new Local Plan in place by 2017. Castle Point are not the only local authority in a similar situation, but they are getting a reputation that borders not being able to achieve! This point has been raised in the fairly recent planning inquiries over Glebelands and Jotmans Farm. In the Glebelands case the Secretary of State felt that the Plan making process was making some progress, enough to refuse planning permission and the process to continue.
It is easy, and understandable, for residents to be complacent or apathetic about local authority matters.
But cllr Tucker’s meeting revealed in Canvey’s case this could be catastrophic for the Island.
Too many Canvey decisions appear to be made on political lines, too many issues are decided by representatives of other Towns, is the assumption, right or wrong.
After all Parliament has woken up to the fact that more decisions should be decided by the individual nations of the UK, rather than collectively, over issues that affect the individual nation concerned.
Finances would not permit going back to Canvey splitting from Castle Point, so it is even more important that Canvey residents expect more representation from their councillors. Canvey residents should be prepared to insist that councillors achieve a better Local Plan than what is currently on offer and we should monitor their efforts more closely along the way.
Let cllr Tucker also consider that whilst he enjoys his breakfast!
All in all cllr Tucker must be thanked for taking this initiative and allowing us the platform to try to express the issues and concerns as we see them.
The ability, or lack of, of Castle Point Council to communicate with residents was apparent during the Reports, Reviews and Scrutiny following the floods during 2013 and 2014.
Whilst more and more development, both residential and housing, is being planned and proposed for Canvey Island the continued failure of communication leads to emergency planning issues being compounded. Promises of new roads cloud the waters, evacuation is not an option according to Castle Point Council.
Having limited information hidden away on the Council’s website is of little value, but allows the local authority to exonerate themselves.
The denser the urbanisation becomes, the more complex the response to emergencies become, whether through surface water flooding, flooding from the estuary or an incident at the hazardous industry sites.
Mushroom syndrome where you’re fed bullshit and kept in the dark
The flooding during 2014 illustrated the weakness of the initial response to an emergency on Canvey Island. There were difficulties, understandably, for the Environment Agency teams to respond to failures with the pumps. The Essex County report into the event was critical of the failures and messages coming from our local authority. Residents requested sand bags to protect property, unaware that CPBC have no sand bag issuing facilities!
Should a breach of the sea defences occur the problems and dangers would multiply.
Equally there is little attempt to inform residents of safe procedures for self protection in the event of an incident at the Hazardous Industrial sites.
And yet Local plan Constraints on housing development have been discussed and used by the local authority to the effect that the housing numbers should be limited for the Borough, but that still large housing and industrial / business development is proposed for Canvey that will effectively compound the potential problems.
While we are kept unaware, it can be assumed Canvey residents will not object.
It appears that these proposals are being proposed knowingly, that little effort is being made to make Canvey residents more informed.
The lack of effort by CPBC has been noted even by Essex County Council, yet little changes!
Over 2 years ago Essex County Council, in September 2013 recorded;
“With specific reference to Canvey Island, the Committee acknowledged that the close proximity of COMAH sites to residential areas probably does contribute to an increased perception of danger among residents. While there are historical reasons for the location of the COMAH Sites and residential areas that have developed in close proximity to those sites, it was agreed that in an ideal world such sites would be planned distant from houses. However, the Committee focussed its attention on existing circumstances and believed that the best way of countering those fears is by effective public information systems and robust emergency planning.
The Committee was disappointed with the limited information available via the Council’s (CPBC) own website, which was exacerbated by the fact that some of the valuable materials produced by the ECPEM team (Essex Civil Protection and Emergency Management Team) could not apparently be published on the site even though other local authorities had published the same materials. Furthermore attention had been drawn to advances in technology such as real time information and social media systems that could be harnessed to develop even greater community resilience.”
Wednesday’s Local Plan Task and Finish Group meeting covered the Constraints on Housing within Castle Point, see our previous Blog post covering the meeting HERE.
Views were expressed on the protection of Green Belt, the status of our Green Belt, Flood Risk from both surface and Estuary and at this very late stage of the Local Plan proceedings the Hazardous Industries on Canvey Island.
This debate appeared to expose the complacent, if not deceptive way the issue of Safety has been presented through the Core Strategy and the Local Plan!
Here for clarity is an explanation that not only clears up the matter for residents, but also questions Castle Point Council’s approach;
There is a requirement of all operators of Top Tier COMAH Hazardous Site Installations such as the Calor Gas LPG Storage Site on Canvey Island, to provide a comprehensive Safety Report.
Reports are submitted to the Competent Authority for assessment against the Safety Report Assessment Manual. Once passed through examination the report is made available to Local Authorities, in this case Castle Point Borough Council .
An important aspect of this risk based approach to mitigation is to recognise that it is based upon the likelihood of an incident and that should one occur the potential consequences will, in the worst case, extend beyond the land use planning zones in the down wind direction.
Thus local authorities off site emergency plans need to be drawn up accordingly.
Hazardous Installation Safety Reports are designed and expected to provide additional information than that identified by Consultation Distances and Public Information Zones.
The Control of Major Accident Hazards Regulations 2015
“251 The local authority cannot prepare an external emergency plan for an establishment without obtaining necessary information from the operator. This information will not normally be the entire safety report.
The operator should provide that information which is relevant to preparing the external plan, including major accident scenarios and consequences.
The operator must provide this information by the date on which the internal plan has to be prepared to comply with regulation 12(2) and should also ensure that any information supplied to the local authority is updated as necessary in the light of any changes.
252 Some establishments may be designated by the competent authority as being part of a ‘domino group’ – establishments where the likelihood or consequences of a major accident may be increased because of the location and proximity of other establishments and the dangerous substances present there.
These establishments need special consideration in terms of emergency planning and the testing of the off-site response. The operators in the group must co-operate with each other in supplying any relevant information to the local authority.”
Those parts of the Calor Gas safety report that deal with “The Population at Risk” and the Impact on Population, demonstrate the extent and severity of a credible major accident scenarios which has been modelled to reveal that there is an extensive population likely to be affected.
It would seem that this aspect has not been considered when planning applications are being deliberated upon by the Castle Point Borough Council Planning Authority, even though they act as the Boroughs Hazardous Substance Authority.
The subject of safety reports has been covered within this site and
having noted a recent local newspaper article that deals with the expectations of the availability of Hazardous Sites Safety Reports I would like to take an opportunity to dispel any suggestion that the Calor Gas Company on Canvey Island have in any way failed to provide the required information to the HSE/ Environment Agency i.e. the Competent Authority that satisfies the necessary criteria and content of its current Safety Report.
The most recent COMAH regulations require that a review of Safety Reports be undertaken to take account of, amongst other points, the following issues.
“At least every five years – regulation 10(1)
191 It is important that the review not only details the changes that have occurred, but also assesses the significance of the changes in terms of the identification, prevention, control and mitigation of major accidents. Examples include: changes in the land use of areas surrounding the establishment, including changes in population; or changes in the conservation designations of the surrounding area.
Particular attention should be given to the cumulative effects of any minor changes that have taken place over the period.
192 One of the purposes of the review is to see whether the standards, both
technical and procedural, remain appropriate in the light of new knowledge and technological developments. For example, it may not always be sufficient for the operator to maintain the plant and systems in an ‘as built’ condition. If the review reveals that further measures are necessary, these additional measures should be taken.”
Given this requirement It would seem imperative that a Planning Authority keep this in mind when dealing with a planning application as it may have a financial implication on the ability of an installation to maintain its safety systems to the required expectations.