No doubt that the Castle Point Council lead group members would have impressed upon the Government Local Plan Intervention team, the suitability, the appropriateness of including the Dutch Village and Jotmans Farm Green Belt sites as the prime Housing Development sites for the Borough!
As outrageous and politically motivated as these sites being selected for development is, neither the Councillors who are opposed to these parts of the Green Belt being allocated for development, nor very few Residents, will get a further say on the matter.
The latest draft Local Plan will be presented to the Secretary of State, once it has received further fiddling with to appease meeting the consultation requirements, without further ado!
Attention has recently been drawn to the fact that an Inspector has rejected proposals for 2 of the 3 new “Garden Community” schemes included in the North Essex Local Plan. Once the 2 Garden Community schemes were removed the North Essex local Plan could proceed.
What is the relevance to the CPBC Local Plan? Well the Canvey Dutch Village and Jotmans Farm sites are both equally contentious, both being Large sites in the Green Belt, one being on Canvey Island in a 3A Flood Zone, within the Public Information Zone of 2 Top Tier COMAH sites, whilst the other, Jotmans Farm, reliant on a multi-million Pound Highway Improvement scheme providing access to the proposed site via the notorious Canvey Way!
Not exactly obvious Site Selections for easy implementation, unless of course where Castle Point Borough Council way of thinking is concerned! We must wonder what other sites in the Borough are being protected, by identifying Jotmans and the Dutch Village for the major Housing Development supply within the Local Plan.
Whilst some Local Councillors appear content with these Sites being selected rather than others, they would do well to take note of these considerations by Nathaniel Lichfield, the pre-eminent planning and development consultancy in the UK.
“Our research shows that if a scheme of more than 500 dwellings has an outline permission, then on average it delivers its first home in c.3 years. However, from the date at which an outline application is validated, the average figures can be 5.0-8.4 years for the first home to be delivered; such sites would make no contribution to completions in the first five years.” 
“Recent Inspectors’ findings on local plans have shone a light on the challenges of allocating large-scale new settlements and Garden Communities (GCs). Most recent was North Essex where an experienced Inspector – Roger Clews – concluded two of the three proposed GCs should be deleted in order for the Plan to proceed.
This has reignited the debate about whether the Local Plans system is appropriate for judging soundness on these inherently difficult, uncertain projects.”
Whilst these two references may not be exactly the same issues as facing the CPBC Local Plan, neither the Dutch Village nor Jotmans Farm are the most Sustainable and earliest deliverable sites identified in the CPBC’s Local Plan.
Surely the Full Castle Point Borough Council should be allowed to Consider and Vote on the final version of this Castle Point Local Plan before it is put in the hands of the Secretary of state and the Planning Inspectorate, rather than the 2 Men and their Dog currently controlling this debacle of a Document!
So far we have heard no Call from Councillors for a final review of the CPBC Local Plan final document.
Deliberately shortened to hold certain councillors attention span.
The Covid-19 Pandemic may have provided Castle Point Council with the perfect opportunity to distract residents from ongoing Housing Development desires across Canvey Island and the mainland. Whilst an apparent Blackout on Local Plan news and information leaves CPBC with a window of opportunity for avoiding accountability.
Residents who took part, in good faith, in the Local Plan Consultation have had their names made public, yet remain unable to view what major Developers have planned for the area, what OIKOS and Calor Gas positions are, what little Infrastructure monies are actually available via Essex County Council, and what the Environment Agency have funds for where improvements to Canvey Island’s sea defences are required, as their actual submissions remain secret!
Castle Point Council’s intention to not be Open and Transparent with local Residents is apparent, when they say;
“The Pre-submission plan, associated evidence documents, together with all the representations made and the statement of representations will be submitted to the Secretary of State for an examination in public. We will contact you when the submission has taken place.”
I have contacted cpbc councillors to get this intention confirmed, or whether CPBC will allow residents to view the Consultation submissions, but alas have received no reply!
However, we have seen Essex County Council’s response to the CPBC Local Plan and they highlight certain areas of concern, especially for Canvey Island Residents.
Major development which CPBC intend for Canvey, the Dutch Village fields and the Triangle site, both Green Belt areas, are included in the Local Plan, despite them being Sequentially unsuitable due to Flood Risk.
CPBC openly disregard Planning Guidance by their desire to develop on Canvey Island, by “suggesting” that development will not take place until such time that there is no longer a 5 Year Housing Supply across the whole of the Borough!
The CPBC Local Plan is scheduled to cover a 15 Year period. A major site supporting the early part of the Local Plan’s Housing Supply is the contentious Jotmans Farm site, Prime Green Belt edging a built up area. the site is currently intended for 850 dwellings, this total protected by CPBC’s Master-planning day dream.
“The 24 housing site allocations are a mix of 12 brownfield sites within the urban area and 12 sites outside the urban area, including on Green Belt land, providing 974 and 2,745 new homes respectively,” of a Nett Total Housing Supply of 5,284
Canvey Island sites, “The site(s) can only come forward when the housing supply remaining falls below 5 years supply, in order to meet the sequential test for flood risk”
However the Jotmans farm site, known as, “HO9 Land West of Benfleet , Benfleet”, being the largest site off of the Island and “potentially” within the Local Plan, is expected to supply 850 Dwellings.
However, there is very little chance that Essex County Council or other Highway agencies will find Funding for the aspiration for a Roundabout and dedicated carriageway onto and along Canvey Way, from the Jotmans farm site to Sadlers Farm Junction!
This could be interpreted as there being little chance of Jotmans Farm, the Land west of Benfleet, being developed until, at the earliest the very latter years of the Local Plan period, or that Persimmons will introduce Development in Phased Stages of perhaps 250 – 300 dwellings per Phase, getting around the obligation to install an access road and junction off of Canvey Way. Or, even worse still for Benfleet residents with eventually the whole new Estate having access via the existing road network!
On one hand Castle Point Council actively promote Jotmans Farm and Canvey Island Green Belt sites, despite all of these sites requiring extensive Infrastructure improvements, and yet land at North West Thundersley is withheld / protected for exactly the same requirement; Infrastructure improvements!
“The Draft Plan notes that some landowners have promoted the above site but, as there are multiple landowners in this area , there are currently no comprehensive development plans that are deliverable. Additionally, there would be a commitment and significant investment in infrastructure given the site is significantly constrained by a lack of appropriate access and risks to the strategic network, as well as other infrastructure requirements to support growth in this location addressing matters such as water supply, drainage and energy infrastructure and community services, affecting the viability and likelihood of development in the plan period . The majority Of the land at North West Thundersley, the “Blinking Owl” site, highway improvements which would be required to support development at North West Thundersley are not currently funded, although initial discussions have taken place between ECC as the Highway Authority, landowners and developers. Fur- thermore, the government’s commitment to the Lower Thames Crossing, will have a significant impact on the strategic highway network (A13, A127, A130). ECC has advised that further development which affects the highway network will not be supported until fu nding for the A127/A130 Fairglen Interchange is committed and in place. ECC ’s previous position on this site remains unchanged, namely that ECC would not support any new development and employment allocations until the proposed long term transport scheme for the junction is implemented; hence the safeguarding of the site is only supported subject to the prior implementation of the long term highway improvement scheme for the A127/A130 Fairglen Interchange”
Canvey Residents should note where Essex County Council point out; “highway improvements which would be required to support development at North West Thundersley are not currently funded,”
This is also the case where Canvey Island Sea Defence improvements against Tidal Flooding is concerned, these also being “not currently funded,” as the Local Plan supporters amongst Castle Point Council members know so well!
And yet land on Canvey Island continues to be EXPLOITED!
Castle Point Borough Council intend to approve the development of 5,100+ New Houses over the next 15 years, with many of these on Canvey Island.
OIKOS intend to DOUBLE their capacity of Importation, Storage and Distribution of Hazardous Fuels such as Jet Fuels. These Fuels will be carried via an increase in Fuel Tankers on local roads, and the Pipelines that cross Canvey, some under roads, to the south east’s airports etc.
Every single Household on Canvey Island, would have received Notification of the Levels of Housing Development from CPBC!
Every single Household on Canvey Island, within the Public Information Zone, should have received Notification of the OIKOS Expansion!
What is the relevance to the average Canvey Islander of the OIKOS Expansion? Because the Public Information Zone is intended to draw Residents awareness via; “Provision of information to persons likely to be affected by a major accident at an upper-tier establishment” (See Map below).
Why do we draw your attention to these two issues? Because Castle Point Council, with their approval of intensification of Housing on sites on Canvey Island, choose to increase even further the number of Residents likely to be affected by a major accident at an upper-tier establishment.
Regardless of the loss of Green Belt, the increase in traffic congestion, the lack of infrastructure, the land drainage issues, CPBC choose to add to these issues.
The Yellow Circle on the Map, is not a safety barrier should an accident occur, in fact well within the Zone is the Calor Gas Plant!
Regardless of all of that CPBC choose to ignore the Constraints on Development that exist on Canvey Island, and instead choose to Increase the Numbers of Residents living at Risk of an Industrial Accident at the two Hazardous Upper Tier COMAH sites on Canvey Island!
Below is a Map of the Island showing the area contained within the Yellow Circle, indicating the 1,500 metres Public Information Zone and “persons likely to be affected by a major accident at an upper-tier establishment.”
You will see that the Dutch Village site, the Triangle site and the Thorney Bay site, all intended for Housing Development and all falling within the area of “persons likely to be affected by a major accident at an upper-tier establishment”
Castle Point Borough Council officers and Lead group chose to ignore this Risk to Life and Property, and increase the Numbers of People at Risk of a Major Accident on Canvey Island.
They will no doubt resort to this as scare-mongering as a defence, so be it!
An Informed Public, is the first step towards a Prepared Public. Increasing the level of population is a travesty of decision making and an immoral Local Plan, let alone an Unjustified Local Plan!
Information on the OIKOS Marine & South Side Development (OMSSD), including the posters used at the November 2019 Paddocks Exhibition and the next steps the Spring 2020 Statutory Consultation on the Plan can be viewed HERE.
Time for every single Canvey Island resident to get their head out of the Sand?
This could threaten everything you hold dear, affecting the current Island Residents and the thousands of new Residents CPBC plan Housing for within their Local Plan!
In brief from the CPBC cabinet minutes;
“Oikos Storage Limited is a nationally significant oil, fuel and bulk liquid import and storage facility, located on Canvey Island. The port was first established in 1936 and has grown to include two jetties; over 35 storage tanks; road loading facilities; and connections into national fuel pipelines.
4.2 The facility imports, stores and distributes refined liquid fuels, principally diesel and aviation fuel – including to London Heathrow, Gatwick and Stansted Airports.
4.3 The port and storage facilities have been expanding, with the last expansion completed in 2018, which included Jetty 2 to take larger ships, and the refurbishment of 12 storage tanks. Old tanks near the seawall have also been removed.
4.4 In order to meet future demand Oikos propose to expand the port and storage facilities. This expansion is by up to 5 million cubic tonnes and is known as the Oikos Marine and South Side Development (OSMSSD)
4.5 The scale of the proposal means that the application must be made using the Development Consent Order process rather than a planning application to the Council as the local planning authority. This requirement is set out in planning law.
4.6 The Development Consent Order (DCO) was introduced in the Planning Act 2008. The Act defines that the Orders can apply to projects ‘within one of the following fields: energy, transport, water, waste water and waste.’
4.7 The purpose of the DCO is to speed up the consenting process for large and complex infrastructure projects. Applications require, by law, that they are considered by the Planning Inspectorate through a Development Consent Order, rather than a planning application to the local planning authority.
Applicants have a statutory duty to undertake consultation on their proposals. This is the best time for stakeholders to seek to influence the application. To date the Oikos project has been launched, but further pre-application consultation is planned for later this year when there are further details on the proposals.
At the pre examination stage an Examining Authority (Inspectors) will be appointed and all Interested Parties will be invited to attend a Preliminary Meeting held by the Examining Authority. Although there are no statutory timescales for this period, it usually takes approximately three months from applicant’s formal notification and publicity of an accepted application.
As the proposed use of the expanded site is for the importation, storage and distribution of hazardous materials (fuels) a Hazardous Substances Consent (HSC) is also required. A HSC is a standalone consent, determined by the hazardous substances authority – Castle Point Borough Council.
The hazardous substances consent process ensures that necessary measures are taken to prevent major accidents and limit their consequences to people and the environment.
This is a key part of the controls for storage and use of hazardous substances which could, in quantities at or above specified limits, present a major off-site risk.
Where the presence of a hazardous substance is directly associated with a proposed development, local planning authorities can exercise control through the decisions on applications for planning permission.
The consent process regulates the storage and use of hazardous substances and enables breaches of control, which may present serious risks, to be dealt with quickly and effectively.
Separate health and safety law ensures measures are in place for the safe use of hazardous substances.
However, even after measures have been taken to prevent major accidents, there will remain the residual risk of an accident which cannot entirely be eliminated.
4.14 The applicant has requested that the HSC is included within the DCO. In doing so, the Council must agree to its inclusion within the DCO and allow for the need for a separate HSC to be removed.
4.15 Planning policy on Hazardous Substances does allow for such a consent to be granted by a DCO to ‘provide a ‘one stop shop’ for consenting for nationally significant infrastructure projects
4.17 The reasonable alternative will be for the Council to determine the HSC as a separate consent. To do so would still involve consultation with the COMAH Authority (the Health and Safety Executive and the Environment Agency), and consultation with a wide range of local stakeholders (such as the police and fire and rescue service) as well as local residents. All of these will be consulted on the DCO.”
4.18 Given that the DCO application will involve widespread engagement and consultation, transparency in terms of the operation and use of the site, with the highest level of scrutiny through the examination process, it is prudent that the Hazardous Substances Consent is included within the DCO.
4.20 It is recommended that the Council agrees to the inclusion of the Hazardous Substances Consent within the Development Control Order for the OMSSD.”
And there you have it, a decision concerning the welfare and safety of 38,000+ Canvey Island Residents, taken by Castle Point cabinet. A Controlling cabinet, with not one member Elected to represent Canvey Island Residents this Approval, for that is what is intended, will Directly Affect.
Now it would not be so bad if the officers and councillors entering into the consultation had our respect for a knowledge or background in such matters, but you can be assured that none of them do! Those in Cabinet and on the Development committee, and we include officers, make Planning decisions ignoring and in spite of warning evidence contained in the Hazardous Industries Safety Reports!
When you go onto consider these controlling councillors eagerness to increase the numbers of residents living within the Hazard Range of the vastly expanded OIKOS site, by means of their disastrous Local Plan 2019, you could be excused for losing any Trust you may have retained in them.
It would be quite remarkable that, with the emerging Local Plan, containing its housing development intended for Canvey Island, just 1 month ahead of OIKOS holding their Paddocks Residents Exhibition, is asking just to much for us to believe in being a coincidence!
These latest intentions by CPBC takes me back to the very first meeting, over a decade ago, between the Canvey Green Belt Campaign group and Lead group members and officers.
I will leave you with two thoughts;
Those co-conspirators, Lead group members and senior officers, conceived a Plan that intended for Canvey Island in isolation would sacrifice Green Belt to Housing Development, whilst, due to an agreement behind closed doors, mainland Green Belt was to be defended! Remember that, Norman, Jeffrey, Simon?
Also during this meeting we were expected to believe that through the power of the then Local Plan, or Core Strategy as it was known, CPBC OIKOS and Calor would be closed and that Canvey Islanders would be blessed with the Port sites would be turned into a sailing and recreational area, alongside river front Flats no doubt!
At the very end of that initial meeting, a CGBC member asked the then CPBC chief planner if he would live on Canvey Island with its 2 Hazardous Industrial sites.
No, I would not! Was his reply.
And there you have it, the Fate of Canvey Island Residents in the Hands of council members and officers, none of whom elected by Islanders, who in turn were, and still are, content to sacrifice Canvey Green Belt, add through development to the number of people living at Risk of a Hazardous Industrial accident and now make the decision to combine the Hazardous Substance Consent within the Development Control Order, without a single representative of Canvey Island having an opportunity to Vote Against!
Anybody unsure of the impact that a Hazardous Incident may have on Property, Residents and their welfare need only click on this LINK.
Approximately 144,000 additional homes are being planned in Essex up to 2036. These latest plans represent a higher rate of housing site delivery than previous plans, with a potential countywide requirement of around 8,800 homes per year to meet the demands of the housing delivery test – the government’s assessment of whether councils are overseeing development of enough homes for their area.
In a reflection of Essex’s high growth rate, roughly 50 per cent of the government’s housing infrastructure funding – equivalent to more than £300million – has come to Essex.
A consultation for a new Essex County Council housing policy setting out its vision for long term growth in the county is to be launched.
The council says a new strategy is needed for it to be part of the wider housing process ensuring the right numbers, types, affordability and quality of housing is provided across Essex to avoid problems in years to come. The process is to tie in with local authorities’ work in preparing local plans.
Approximately 144,000 additional homes are being planned in Essex up to 2036.
These latest plans represent a higher rate of housing site delivery than previous plans, with a potential countywide requirement of around 8,800 homes per year to meet the demands of the housing delivery test – the government’s assessment of whether councils are overseeing development of enough homes for their area.
In a reflection of Essex’s high growth rate, roughly 50 per cent of the government’s housing infrastructure funding – equivalent to more than £300million – has come to Essex.
Councils have responsibility for housing and local plan making, ensuring land is identified for housing in the right places.
Housing associations and private developers then build homes across the county, while Homes England invests funding, land and expertise to support delivery on behalf of government.
But Essex County Council (ECC) plays an important role as part of the housing system in Essex, delivering and maintaining much of the large-scale infrastructure that businesses and residents require including transport, waste facilities and schools.
ECC’s proposed strategy aims to help improve links with its partners focusing on prioritising localities of greatest importance and identifying opportunities for people to live well and independently of social care.
Its commitment to garden communities is also placed at the core of its strategy, with increased investment to deliver supporting infrastructure that enables sustainable development of new communities and meets wider aims, such as a zero-carbon economy.
Steve Evison, director of strategic commissioning and policy, said at a place services and economic growth policy and scrutiny committee on Thursday, January 23: “So the county needs a strategy and rightly a number of the local planning authorities are looking at that and saying that to be able to deal with that over the longer term we need to start to plan for large settlements because the alternative is growth on existing towns and villages.
“There is only so far you can go with that because then it starts to encroach on other settlements and starts to put pressure on services that are there because the scale isn’t there and we can’t therefore bring in the infrastructure.
“Half of the total housing infrastructure fund came to Essex because Essex has shown its willingness to plan for the long term.
“There are twin pressures. It’s the longer term consequences. If we don’t keep up with those longer term delivery rates it will enable private developers to push through developments.
“The whole strategy is part of that response. ECC needs to be in that space because if we are not as a council we will be dealing with the consequences in 30, 40 or 50 years’ time.”
The council wants the consultation to go out before the local elections in May, with early summer as a date for a final draft action plan.
So, word is out that the Castle Point Council latest Local Plan will be, again, considered by council members during late October 2019, or is at least scheduled to be. This may or may not be subject to there being a Parliamentary Election later around that time, which may bring some bearing on the scheduling.
As we are all aware the CPBC Local Plan is a sensitive issue not least amongst the Castle Point Electorate! Ructions were caused when the previous attempt to adopt a Local Plan was bravely thwarted by those council members refusing to inflict certain damage to the borough and Canvey Island, through the draft Local Plan’s level of and siting of huge development sites. This they did under extreme and unfair pressure from Government, the cpbc controlling group and senior officers, insisting that Government Intervention was imminent. The Planning industry’s thoughts on the Intervention topic, and how this threat appears to have subsided were previously covered HERE.
This lessening of the Threat from Government of Local Plan Intervention, should give some encouragement to cpbc councillors to come up with their own Local Plan in line with Residents expectations.
Residents will once again be looking towards the resolve of our Council Representatives to Protect the Borough’s Green Belt and from Over Development. The delivery of supporting Infrastructure is abysmal, any development appearing to only compound issues and problems such as medical services, highway issues etc etc. These issues, however, are not solely confined to Canvey Island, what did concern Canvey Island was the necessary improvements to its Drainage System, some £24,500,000’s worth of remedial work.
Infrastructure Costs should also include the required Improvements to Canvey Island’s Sea Defences, but of course these are not included, nor allowed for within the CPBC Local Plan and its distribution of Housing Development Sites.
The CPBC Corporate Plan acknowledges that Castle Point is :
“a small Borough covering just 17.3 square miles, and an estimated population of 89,700. We are located in South Essex at the heart of the Thames Gateway South Essex sub-region, between Basildon and Southend.”
“Just over 55% of Castle Point’s land is designated as Green Belt. As a result, most of the Borough’s population live within one of four towns Benfleet (22%), Canvey Island (43%), Hadleigh (14%), and Thundersley (21%).”
“Castle Point has a population density of 19.21 persons per hectare, the second highest district in the county and considerably above the 4.0 average for the whole of Essex. The population density map below shows the highest rates of population are in the centre/south east of Canvey Island and within the towns of Benfleet and Hadleigh, although there are also expanses of low population density. Just 51% of the Castle Point district is classified as green space, the lowest proportion in the county (the Essex highest figure is 93% in Uttlesford): green spaces are important for wellbeing, community cohesion and for wildlife.”
The CPBC Local Plan needs to Highlight and expand on this with a suitable Housing Strategy, one that Residents can be comfortable with for a Healthy and Prosperous Future and not be resigned to a continued deterioration of the area as we know it.
We need to think carefully as to how our wishes are being Represented!
Other local authorities are struggling with coming to terms with the pressures of imposed development levels and respecting their Green and Open Spaces. Castle Point Council and its members, Our Representatives, must not buckle under pressure from either Cabinet members nor officers, in the knowledge we are not alone in this difficulty.
Lichfields January Insight, “Planned up and be counted, (Local Plan-making since the NPPF 2012)” clearly highlighted the problems surrounding local authorities affected by Green Belt constraints on development. :
“The majority (63%) of the LPAs which benefit from an up-to-date plan are unconstrained by Green Belt, whereas by contrast, 59% of LPAs without a post NPPF 2012 Local Plan are constrained by Green Belt, with these authorities twice as likely to not have a post-NPPF 2012 Plan as none Green Belt authorities.”
“The Government’s early 2017 deadline for Local Plan submission has been and gone, and in March 2018 the Housing Minister announced an intention to intervene in three (Castle Point, Thanet and Wirral) of fifteen previously-named authorities who were being closely watched. With the Government’s intervention threat still in play and the bite of NPPF 2018 in force from 24 January 2019, can we expect a new rush on Plan-making activity?”
“Green Belt Reflecting the Government’s manifesto pledge, the NPPF 2018 changes Green Belt policy. Under the presumption in favour of sustainable development, its role as restricting development is tied to where it provides a “strong reason” for doing so, whilst those plan makers releasing Green Belt have first to show they have examined all other reasonable options, including brownfield sites, optimising density, and meeting needs in adjoining authorities.”
This final point we wish to point is exactly how site selection should also be viewed where development within Flood Risk zones through the Sequential Test, rather than the CPBC, Canvey Island “special case” method!
Have you wondered why London hasn’t an Eastbound Motorway similar to the west of London.
East houses the business and production areas along with the urbanised towns, almost merging with each other, whereas to the west is a lot more land space and the holiday routes.
On the A127 it is difficult to measure the traffic
What I mean is that it is distorted by being just 2 lanes and has purposely retained slow down mechanisms, namely the fortune of war roundabout, and the poorly, and the economically designed short slip roads, which slows down traffic flows often to a Halt!
Chelmsford is looking after the mid and north of the county routes, intentionally leaving the south and thameside local authorities to seek other funding streams which are barely forthcoming.
Hence the piecemeal patchwork upgrades to the a13
and the lack of improvements to the a127.
Is it a deliberate ploy by Essex County Council to segregate us from them, in the knowledge that Thameside areas under the will of “The Association of South Essex Local Authorities” intends to become more and more intensely urbanised, acting as a buffer to keep mid and north essex leafier and more better funded off the back of us!
The “improvements” on the local major arteries have been piecemeal and catastrophic. The A127 being basically neglected for the last 40 years as for the A13 we need only to consider the sections of lane widening such as now only just commencing at Stanford at the same time as the seemingly continual repairs to the substandard construction of the Sadlers farm Junction.
Locally the incomplete Roscommon Way, the 2nd phase being completed to vastly reduced lifetime standards, whilst the continually promised 3 road off Canvey Island, remains after all of this time an “A”spiration. (Is that what they mean by an “A” road?).
Meanwhile Parliament got in on the act by holding a discussion on the road infrastructure of Essex in Westminster Hall.
Speakers included Priti Patel, Mark Francois, Graham Stringer chair, James Duddbribge, Will Quince, Rachel Maskell, Jesse Norman Min of State Dept of Transport.
Some of the debate included, with no names attached to quotations, but you will note the early emphasis on Mid and North of the County, and you can contemplate this as you sit in your nearest Traffic Jam, in the clear Knowledge that Nothing Will be Done Soon to Improve the Situation!:
“Over the past decade there has been a 25% increase in the number of enterprises across Essex. In 2010, that number stood at 61,540. By 2018 it had risen to 77,365.”
“it is not only individuals who depend on our transport sector, but businesses and everyone else. Essex has a strong advanced manufacturing and engineering sector that employs over 50,000 people in over 4,200 companies.”
“In the county of Essex, farming alone is worth over £400 million to our economy and employs over 8,000 people.”
“every year enough wheat to make 1.3 billion loaves of bread, enough barley to make 280 million pints of beer, and 150 million eggs. We also grow outdoor vegetables on 5,000 acres of land, so roads and transport are important”
“we have 66,000 professionals in Essex, so it is important that we continue to grow and support them. We have a dynamic academic and educational sector, with Writtle University College, Anglia Ruskin University and the University of Essex”
“We have over 1,000 acres of port-adjacent, tri-modally connected logistics and distribution sites, which are the backbone of our economy, and we are connected by road, rail, sea and air to global markets. We have four major seaports—London Gateway, Tilbury, Harwich and Purfleet—with a fifth major port, Felixstowe, just over the border in Suffolk. There are also six port-side rail freight terminals and three key tri-modal logistic sites at London Gateway and the London distribution park.”
“our airports: Stansted, which is the UK’s third largest air freight hub by capacity, and Southend airport. Those airports are not just growing, but experiencing considerable passenger growth and, in the case of Stansted, benefiting from private sector investment to the tune of £600 million.”
“One statistic says it all: it is not surprising to learn that Essex is the local authority with the second-highest traffic level in the country, with 9.68 billion vehicle miles in 2017 alone. That is 2 billion miles more than in 1997, and if the unitary authorities of Thurrock and Southend-on-Sea are included, the greater Essex area has the highest traffic level by distance, with 11.2 billion miles.”
“The Minister must understand that our main arterial routes—the A13, the A127 and the A12—are bursting at the seams.”
“The Government want more house building in south Essex and the rest of the county. I make it plain to the Minister that he has to pay for the infrastructure if he wants those houses built. If the Government will not come up with the money, for instance to make the A127 the M127, they can forget their housing targets.”
“Chairman “I remind Members that, although this is not a well-attended debate, interventions should be short, brief and to the point.””
“The case for investment in the A12 and the A120 is compelling”
A12 “below standard slip roads and capacity problems which can result in tailbacks.”
“Minister, if this were legislation, I would suggest a very simple amendment: delete “A” and insert “M”. I refer, of course, to the A127. We want it to be a motorway. When I say “we”, I do not mean me, or a collection of a few random individuals; the whole of Essex wants it to be a motorway. In November 2018, a group came together—the south Essex A127 taskforce—led by Councillor Mike Steptoe, who is both of Essex County Council and deputy leader of Rochford Council. That group included Essex, Southend, Thurrock, Rochford, Basildon, Castle Point, Brentwood, Chelmsford, Malden, Havering, Transport for London and Highways England.”
“The A127 carries more than 75,000 people every day.”
“we need to make sure that all incremental improvements to the A127 do not stand in the way of a future motorway—developments such as the Fairglen interchange between the A130 and the A127 need to be motorway-proof.”
“Although right hon. and hon. Members have extolled the economic opportunities for their areas and discussed the housing developments that are putting pressure on the infrastructure, which is clearly under severe pressure and needs to be redressed, I urge the Minister to take a more strategic view of how we develop our transport infrastructure. The reality is that we need to plan not just for the next decade or two, but for the long term.”
“In December 2014 the Government launched the first road investment strategy, which outlined how more than £15 billion is to be invested in our strategic roads between 2015 and 2021. That is the biggest upgrade to strategic roads in a generation, and it will be exceeded in RIS2 from 2025, which is of the scale of £25 billion.”
“To zero-in on Essex, my right hon. Friend the Member for Witham pointed out that the first road investment strategy includes the widening of the A12 between junction 19 at Chelmsford and junction 25 at Marks Tey, where it currently joins the A120.”
“Question put and agreed to.
“That this House has considered transport infrastructure in Essex.”
For Canvey Islanders the daily commute, whether by car or public transport, can be, to put it politely, “challenging”! Castle Point Council will tell you that it is the same across the whole Borough.
As we are all aware there is pressure to supply yet more and more Housing development. This will inevitably add to the problem.
One would have thought that, CPBC would have adopted a strategy by now, especially over the extended period taken to arrive at a 3 times rejected Local Plan, that would at least start to address the congestion problem.
But no, where Canvey Island is concerned, the Town Centre Regeneration scheme has been ignored and dismissed where convenient to CPBC! The old Nat West building and neighbouring property, identified as space for road realignment is set to become a community centre and bakery, with new development adjoining.
More concerning however, is the lack of correlation between, new Builds and the accompanying Car Parking spaces, and the major Business and Retail Parks receiving all being Approved on the Island!
These planning proposals all due to impose a Negative Impact on Canvey Island’s Car Parking and Road Network, despite the fine words included within the Local Plan 2018.
The Castle Point Borough Council Emerging Local Plan proposed Policies that seeks “Opportunities to promote walking, cycling and public transport are pursued; The environmental impact of traffic and transport infrastructure is taken into account; and Movement, streets and parking are integrated into designs”
The Emerging Local Plan recognises “Many of the main routes within the borough are single carriageway roads with little prospect for widening due to the proximity of existing development. This also limits the potential to provide dedicated passenger transport routes and cycleways” “Castle Point is peripheral on the bus service network and whilst there are good services during the day on most routes, service frequency is not as good in the evenings and on Sundays.”” The cycle network within Castle Point is limited, and where it does exist it is disjointed and poorly maintained.”
The New Out of Town Retail / Business sites will not only be to the detriment of the Canvey Town Centre but also intensify the Congestion heading towards and from Canvey West. However, almost every Flatted development Approved on Canvey, has a shortfall of Car Parking Spaces, officers suggesting that isn’t their concern as Town centre Flats benefit from facilities being nearby and benefit from regular public transport!
Equally there is a consistency with the Approved Retail / Business sites, that they to, when residents and mainlanders arrive, will also have a Shortfall of Car Parking Spaces!
Below are a few examples indicating the Castle Point Council’s Planning officers and committee approach to the issues of Car Parking and new Housing Development and Retail / Business development.
Spot the Connections!
King Canute Flats, Vetenary practice and CO OP store.
“The proposed car park…..would result in a significant level of harmful conflict… between the 3 independent uses, adversely affecting the ease of movement within the site, and if approved, likely to accumulate in the displacement of the residential occupiers vehicles onto Edith road, to the detriment of safety and traffic flows,”
The Flats “attract a requirement of two parking spaces” each…. “the provision of 3 spaces (in total) would appear to represent a deficiency, however….””where Flats will have easy access to the bus network…” “the parking provision is considered satisfactory.”
“With regard to the retail element” the area of floor space results” in a maximum requirement of 25 parking spaces.”
“The retail element is provided with some 13 parking spaces.” Recommended for Approval and subsequently Approved by Committee.
125 – 127 High Street Canvey Island. 14 x 2 Bedroom Flats
“ The currently adopted parking standards published by ECC require the provision of two spaces per property. Within Town Centres this may be reduced.”
“The site is remote from the core of the Town Centre…”
“Visitor parking should be provided at a rate of 0.25 spaces per dwelling.”
“Application of parking standards generates a requirement of 32 parking spaces.”
“The proposal would provide 15 spaces and should therefore attract a recommendation of Refusal.” Approved on Appeal
Canvey Supply Ltd 74 High Street Canvey Island 16/0212/OUT
The scheme would provide 24 car parking spaces and 32 cycle parking spaces to serve the needs of the residential development and 4 spaces to serve the shops.
The maximum parking requirement for this development is as follows:
12 x 1 bed apartments 12 spaces, 12 x 2 bed apartments 24 spaces, Visitors 0.25 x 24 = 6 = 6 spaces 42 spaces parking spaces.
The proposed retail units have an area of some 268m2 and therefore attract a requirement for 14 parking spaces.
A maximum total of 56 spaces is therefore required on the site.
The proposal seeks to provide 24 residential parking spaces.
The proposed development is deficient in parking provision and ordinarily would attract a recommendation of refusal. However, the site is located within a Town Centre where the availability of private parking and service areas is extremely limited and where access to other public car parks and public transport is available. Approved by CPBC committee.
Now let’s look at our New Retail / Business developments!
Land Opposite Morrisons Northwick Road 15/0293/RES
Hotel and motor dealership. Approx. 27 Units various sizes.
This site has a total area of 7.5ha, the north of which connects to Northwick Road. The east of the site is bounded by Roscommon Way and the Morrisons site
Parking Requirement 590 Spaces. 565 Spaces to be provided. Projected Shortfall 25 Spaces.
Lidl foodstore 18/0868/FUL
Lidls presents itself as a local convenience retailer and therefore operates on the basis of a limited catchment area. Usually this would be a five minute drive time. However given the somewhat unique circumstances of Canvey Island, this has been extended to eight minutes in order, primarily to capture the whole of Canvey.
A significant proportion of turnover will therefore be derived from diversion from existing retailers.
The impact of this diversion on the vitality and viability of the Centres must now be considered.
102 car parking spaces would be provided. The proposed store would attract a requirement for 149 car parking spaces. Shortfall of 47 Spaces.
Land South Of Roscommon Way Canvey Island 14/0707/OUT, Demolition of disused pumping station and construction of commercial and industrial development
The proposed Layout indicates the intention to provide 566 Parking Spaces. However the Actual Supply should be 662 a Shortfall of 96 Parking spaces.
Retail Site M and S, Costa, B and M, Sports Direct, Garden Centre etc
Land off Roscommon Way Canvey Island 16/0419/FUL
3.4Ha site (approx).
Approved with undersize car parking spaces, inconsistent with adopted parking standards.
The proposal should be required to provide 456 car Parking Spaces
Actual Supply 240 Parking Spaces. Just 53% of the Requirement “This deficiency would appear to represent a significant objection to be proposal.”
Next time you are out sitting in Traffic or wondering why people are Parking on Pavements etc, just Remember, it’s all part of somebody’s Big Plan!
38,459+ Residents living on Canvey Island, seemingly oblivious to the everyday Risks and potential Harm facing them!
Whether the Risk is Tidal from the Estuary, Surface Water flooding or from the Hazardous Industries on the Island, a suitable Emergency Plan involving the Residents is essential.
The old Adage “we are safe
from the Sea” is bunkum, as Castle Point Borough Council’s own evidence
“Given the risk to the population, various measures are required to deal with the concerns to human health and wellbeing. These include:
• The need for an emergency plan to be in place;
• The need for sea defences to be maintained and improved;
• The need to maintain the population living in the flood risk zone at current levels or lower;
• The need for existing homes to be made more flood resilient, and include areas where people can remain safe in the event of a flood;
• The need for new development to incorporate design elements that make them safe in the event of a flood for occupiers;
• The need for building techniques to be used that enable easy restoration in the event of a flood.” (1)
Further CPBC Local Plan Evidence Documentation enforces the issues;
10.4 Tidal and fluvial flooding poses the most significant flood risk to the Castle Point Borough, in particular Canvey Island and Hadleigh Marshes. The topography and location of watercourses on Canvey Island means that the whole island is at risk from tidal and fluvial flooding. Although much of the Island is protected by the presence of defences, the island is still at residual risk of flooding if the defences were to fail or to be overtopped.
10.5 In the event that a breach in the existing flood defences was to occur, or a failure of one of the existing flood barriers (residual risk), significant depths of floodwater would be experienced on Canvey Island and the southern portion of the mainland. Given the low lying nature of these parts of the Borough, floodwaters would propagate rapidly across Canvey Island thereby reducing the time for warning and evacuation of residents. (2)
During the Local Plan Intervention fiasco, CPBC informed the Secretary of State of particular physical circumstances of the Borough, considered to be legitimate constraints as to why the Authority could not provide for its Housing Development Needs.
“Of the urban areas of the Borough, Canvey Island, with approximately half of the Borough’s population, is defined by the Environment Agency as Flood Risk Zone 3a, being at or below sea level.
Further land is likely to be required on Canvey Island by the Environment Agency for improvement to existing sea defences in the lifetime of a Local Plan, further restricting opportunity for development
The Health & Safety Executive require significant exclusion areas to be maintained by the Local Planning authority around two top-tier COMAH sites on Canvey Island’s Thames Estuary frontage”, (3)
Direct Recommendations detailed within the CPBC Strategic Flood Risk Assessment state:
“The majority of the sites will rely on the provision of adequate emergency planning measures to mitigate the residual risk of tidal flooding in the event of a breach in the tidal flood defences.
It is therefore strongly recommended that the suitability of locating more residential accommodation on Canvey Island and the capacity of the existing egress routes off the island is further discussed with the Emergency Planning Team at Castle Point Borough Council and/or Essex County Council prior to site allocation” (4)
Remarkably, CPBCs Development Control Committee has taken responsibility, (having only aspirational resolutions for the various preventative requirements), for successfully seeing-through Housing developments at Canvey Island since January 2012.
In doing so exposing an increased number of residential and commercial population to Residual and/or Actual Societal Risks.
Emergency Plans supporting
increased development on Canvey Island are seemingly only “Generic”, where by
dealing with a wide range of possible scenarios such as for example Influenza
Pandemics, with no “Specific Plans” that relate to a particular emergency.
Specific Plans are a
detailed set of arrangements designed to go beyond the generic arrangements,
when the latter are likely to prove insufficient in particular cases such as
breaching of flood defences or total LPG tank failure. (5)
It would appear that CPBC have not considered the value of Specific Planning in relation to Canvey Island, if they have, they have not included the involvement of the community in the production of specific planning for viable emergency incidents.
Editor, I will leave the reader with an opportunity to provide a Rationale as to how our local authority, Castle Point Borough Council has managed “Residual Risks” via its Local Planning strategy.
The CPBC Sustainability Appraisal and Strategic Environmental Assessment Scoping Report, New Local Plan January 2012
Castle Point Borough Council New Local Plan 2018 Technical Evidence: Summary Document June 2018
CPBC Response letter to Sajid Javid 31st Jan 2018, regarding why Government Intervention in the Local Plan process was unnecessary.
Revised Castle Point 2018 Strategic Flood Risk Assessment
Chapter 5 Cabinet Office Revised Emergency Preparedness. Definitions of “Generic” and “Specific” Emergency Planning.
Canvey Island residents lay claim that they are treated unfairly by Castle Point Council. In turn CPBC claim they are being treated unfairly by the Government, by being threatened with Intervention due to their Tardiness with producing a Local Plan!
Apparent outragefrom the CPBC leader and chief executive, at those Councillors brave enough to Reject the draft Local Plan, did not disguise the fact that the emerging Plan deserved closer Scrutiny and Challenge from Councillors, than those Reasons given for their votes of Rejection during the December Council Meeting.
Whether the Failure of the Local Plan 2018 is due to CPBC Incompetence, or whether some perceived levels of Immorality, or political corruption, is involved in the selection of the Canvey Island Green Belt sites for Housing Development, especially in the approach to the application of the Sustainability Tests involved, we leave the Reader to decide.
As you are probably aware, the whole of Canvey Island is regarded as being in Flood Zone 3a. Housing in this Zone is considered as being Vulnerable development.
The whole of Canvey Island is also considered to be a Critical Drainage Area.
For ease and to avoid confusionwording highlighted in Blue are those of CPBCwhilst wording in Red is official Government Guidance.
The Castle Point Local Plan 2018 version at Paragraph 17.4 states“planning policies should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes and policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts”
Typically though, of CPBC, and despite their Officers and some members, insisting that the NPPF should be “Read as a Whole”, the Local Plan 2018 version Craftily fails to include the final, and most Important part of the NPPF text of the above Paragraph 17.4.
That is; “ , such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.”
CPBC Sequential Test Page 2
This Local Plan Evidence document almost immediately sets out to justify, carte blanche, large scale Housing development on Canvey Island.
Bear in mind that Housing and Residential care Homes are considered to be a “More Vulnerable” uses of Land in Canvey Island a Flood Zone 3a area.
“The NPPF recognises that following the application of the sequential test, it is not always possible, consistent with wider objectives, for certain development proposals/requirements to be located in lower ‘flood risk zones’. It therefore also sets out a test that needs to be passed if certain types of development are to be exceptionally allocated in a local plan”
All of the Canvey Island Housing Sites are considered by CPBC to Pass the Exception Test, “This site has significant positive impacts related to the sustainability objective concerning the provision of housing, including affordable housing.”
Affordable Housing being considered practically Unviable on all Housing Development Sites, even those not requiring the Surface Water Management measures, and Sustainable Urban Drainage schemes, and Raised Floor Levels that are now required on Canvey Island.
Additionally the CPBC Sequential Test found that, NONE of the 9 Housing Development Sites allocated for Canvey Island is considered to be “Within a Potential Surface Water Flooding Hotspot”,whilst 4 of the Mainland Housing Sites were within a potential flooding Hotspot !
Clearly the evidence found in the Reports, on the Canvey Island Summer Flooding 2014 and 2013, has been discounted, ignored and will be hidden from the Government Chief Planner and Planning Inspector examining the Next CPBC Local Plan!
“All the deliverable and developable sites assessed in terms of their risk of groundwater flooding were found to be appropriate for development, at least in this respect.”
We would ask CPBC “what Tests and Reports were their Assessments based on?”
Once again only certain Mainland Sites were considered to be “Within an Area Susceptible to Groundwater Flooding”,NONE of the Canvey Island Sites allocated for Housing Development were considered to be affected!
This goes Against common local knowledge AND written evidenced Reports to be found on CPBC’s own website!
“Subject to other considerations, it is recommended that when selecting sites for development in the New Local Plan, preference is given to those sites within the highest preference ranking groups over those in lower groups. This will reduce the exposure of new development to flood risk.
It is recommended that housing sites on Canvey are only allocated as a means of providing flexibility to the housing land supply. If sites on Canvey are included within the New Local Plan, a sequential phasing requirement should be applied within their allocation policy to ensure other sequentially preferable allocated sites are brought forward first. Additionally, requirements in the allocations policies should include the provision of flood resistant and resilient design.”
Quite clearly the Housing Development Site Allocation process, of Castle Point Borough Council, applies considerably more Weight on Green Belt protection over that of Flood Risk. The local authority Actively Chooses to adopt this approach despite some sites on Canvey Island being both Green Belt, within a 3a Flood Risk Zone and a Critical Drainage Area!
Government Guidance in the NPPF continues to point out;
“11. Plans and decisions should apply a presumption in favour of sustainable development.
For plan-making this means that:
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area, see Footnote 6
Footnote 6 The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.”
“Incompetence”, perceived “Political Immorality”, or a “Corruption of Facts”, you decide, if not the Examining Planning Inspector most certainly will!
Canvey Island, densely urbanised yet always room for more!