Tag Archives: Housing Need

Canvey Island Flood Risk Zone a Valuable Commodity both Financially and Politically! Caveat emptor an appropriate Back Stop?

SO, those accountable for the Castle Point’s regeneration, sustainability and growth agenda are seeking congratulations for the huge swathes of development of Canvey Island! The completion of this long term project seemingly being very advantageous to some current councillors and predecessors.

Convinced of the apparent sustainability of Canvey Island, investors of commercial and residential developments are completely reliant upon Environment Agency recommendations. Clearly the EA recognise that the Island’s sea defences are in need of further improvements, if only to keep pace with the ever more present impacts of a changing climate.

Claims that there is no need for concern, or that Canvey already has substantial sea defences, will not be helpful in formulating a business case for the funding of the inevitable improvement requirements.

CPBC’s failed bid for central government funding for the £24,500,000 needed to address the deficiency in the current drainage network, and fund capital projects to dramatically improve the drainage infrastructure across Canvey Island, is a clear indication that flood risk is NOT a priority issue.

CPBC have, on more than one occasion, been reminded by the Environment Agency that it is incorrect to assume that the maintenance of the flood defences is programmed as part the Thames Estuary (TE) 2100 Plan. To proclaim that the sustainability of Canvey Island is secured, for the foreseeable future, when that is simply not the case, may be questioned at a later date.

The TE2100 Plan provides for a flood management strategy for the whole of the Thames Estuary, and includes recommendations regarding necessary maintenance and improvements programmes to the engineered defences along the Thames Estuary. The final decision on these programmes will be made by Defra and future funding streams, however, at this time no funding is guaranteed!

In the knowledge of the consequences of a significant risk of flooding from a variety of events, to then subsequently continue increasing the population of Canvey Island, needs some explanation. To actively seek to increase those numbers of residents, including those that are “more vulnerable”, without having a viable emergency evacuation plan, may well be catastrophic!

For CPBC Local Plan to repudiate up-to-date flooding predictions, and to then persist with the continued development of historically designated land and brown field sites, within an already significantly urbanised and populated flood plain, possesses no logistical justification.

It has previously been stated by CPBC and supported by the EA that the delivery of new development must not be considered in isolation from the drainage issues in the Borough and that existing conditions should be improved and not exacerbated. Canvey Island is at the highest Risk of Surface Water flooding, with a high probability of Surface Water flooding across the Borough as a whole.

Inappropriate development, effectively removing space that served as water dispersal areas, will have consequences.  Site selection criteria, as well as a Flood Risk Assessment, should be used to identify whether broad potential future locations for development represent the most appropriate choices in terms of flood risk.

CPBC have argued that without a Local Plan, the level of detail used to inform decisions of a strategic nature may not be as robust, especially regarding cumulative impacts. In addition, policy content can be used to set conditions on developments or determine their refusal in areas of flood risk.

I would argue that the Plan has always been to develop the zone 3 flood plain of Canvey Island regardless of any serious consequences.

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Residents of Canvey Island left to Face the Risks, whilst Castle Point Council, Fail to Develop an Adequate, operable Emergency 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 Highlights!   

 “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.

Document References

  1. The CPBC Sustainability Appraisal and Strategic Environmental Assessment Scoping Report, New Local Plan January 2012
  2. Castle Point Borough Council New Local Plan 2018 Technical Evidence: Summary Document June 2018
  3. CPBC Response letter to Sajid Javid 31st Jan 2018, regarding why Government Intervention in the Local Plan process was unnecessary.
  4. Revised Castle Point 2018 Strategic Flood Risk Assessment
  5. Chapter 5 Cabinet Office Revised Emergency Preparedness. Definitions of “Generic” and “Specific” Emergency Planning.

Castle Point Local Plan clear hints that Green Belt and Greenfield Land to be sacrificed! Household Projection and Development Delivery doubts mean it’s time for local MP’s involvement?

The Outlook is Bleak for Canvey Island and Castle Point residents, regarding the levels and locations of the raft of new development, both Housing and Business, planned for the borough!

Conversations between “informed contacts” over the Local Plan have confirmed an extremely pessimistic outlook, especially where Green Belt, safety, commuting, policing, health services and general Infrastructure is concerned!

The likely proposed Housing Need numbers will propose eating into the Green Belt and green fields. This will quite rightly raise residents concerns and focus thoughts as to whose Housing Needs are being fulfilled.

this especially following the latest Household Growth Projections being lower than previously estimated. The most recent effect of this has prompted the North Herts local authority to revisit their Housing Need projections at the behest of the Local Plan examining Inspector!

The latest housing projection figures have emerged as being significantly lower than the proposed number of homes to be built in the North Hertfordshire Local Plan, with the district council criticised for “sweeping the numbers under the carpet”. Article may be viewed HERE.

The question raised is whether the substance of the Government’s drive for 300,000 new builds per annum, is to match actual Housing Need, or to fulfil an aspiration.

In the case of the North Herts Local Plan the Inspector has suggested that the LA’s Housing target should be revisited despite the suggestion the Housing Minister, having commented on the general subject;

Kit Malthouse acknowledged the impact of this (Household Projection levels being lower), and advised plan-making authorities should not “take their foot off the accelerator”

Surely if the Policy of Green Belt and its permanence, plus other accepted physical Constraints are to have any Credibility at all, an aspirational drive for a Housing Target that is beyond Need should be challenged.

Is this not time for our MP Rebecca Harris, to not be asking and providing answers ahead of the Castle Point “Special Council” meeting, part of the rigid Government Timetable set only to avoid Intervention?

A Local Plan solely drawn up to a rigid Timetable, rather than being supported by the latest Evidence Base documentation, Risks being found Unsound!

“In July 2017, the Leaders and Chief Executives of the South Essex Authorities (Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council) initiated an approach of collaboration to develop a long-term place-based growth ambition.
South Essex Joint Strategic Plan.

It is set to deliver a minimum of 90,000 new homes and 52,000 new jobs by 2038.”

Note the date July 2018, well ahead of Household Projection changes, Castle Point leader and ceo, have fully engaged on behalf of Castle Point in this venture, that has also set Housing Figures ahead of the Household Projections, knowing full well that we will not see Highway Infrastructure improvements in the Borough.

Whilst, the 3rd quarter 2018 New House Builds numbers are 15% up on last year, much of this may be influenced by Housing Association involvement in large projects.

Housing associations are involved in a number of big London developments, including Swan Housing Association’s £300m project in Poplar with 1,500 planned homes, half of which are slated as affordable.
Developer Countryside Properties and London & Quadrant (L&Q) Housing Trust have teamed up to redevelop the former Ford factory site in Dagenham with up to 3,000 homes, half of them affordable. Housing associations also play a big part in the north-west of England, where L&Q has gone into partnership with Trafford Housing Trust in Manchester.
Full report HERE.

Castle Point appears to hold more appeal to developers of Market Priced Housing, rather than Affordable builds.

Generally speaking the target of 300,000* new builds per Annum, apart from being an unsubstantiated target, also appears to be out of reach, at least for this year. Whether this is down to the economic background, especially where the current high deposit required for a mortgage is concerned, or the doubts over the Building Industry workforce in the uncertainty over Brexit**, is concerned should not influence to great an extent, the cpbc Local Plan.

What must be considered is how will releasing Green Field land affect the Borough without improved Infrastructure first, as we were promised.

CPBC leader cllr smith said;

Any development has to have infrastructure and that is the whole point of us having control of our plan. All of these issues will be taken into account, when we put forward our plan.” “Roads and the number of homes built are being considered because if we do not do something about it now, the Government will.”

Now it appears, following feedback, there may be little gained by Castle Point Borough council avoiding Intervention!

smiff

  • More about falling short of the 300,000 target by 50,000 HERE
  • More on Brexit and Building workforce HERE

 

 

Local Housing Need, Calculations due to change, in light of significant reduction in Numbers!

The approach to assessing Local Housing Need, in the light of the present method of Calculation resulting in Lower Housing Need numbers, is due to change.

The Government has entered a period of Consultation.

The Consultation is due to end on the 7th December, just 9 days after Castle Point Council are due to approve a draft copy of their 2018 Local Plan.

The publication of new household projections by the Office for National Statistics has led to a significant reduction in the overall numbers generated by the standard method for assessing local housing need.

This consultation sets out proposals to update planning practice guidance on housing need assessment to be consistent with increasing housing supply.

This consultation also proposes clarifications of national planning policy on:
housing land supply
the definition of deliverable
appropriate assessment

A Link to the Government Consultation can be found HERE.

Residents in Castle Point wait to hear the Up Side of retaining the Local Plan In-House, rather than facing Government Intervention! Oh and how much Green Belt to be Released!

The latest public “announcement” on the Castle Point council Local Plan will be made during the cpbc cabinet meeting on Wednesday 19th September.

Residents will learn exactly what cpbc spokespeople actually meant when they stated they must keep the Local Plan within the council’s grasp, rather than face Government Intervention and all that that entailed!

In a report compiled by the ceo D Marchant, that may more aptly be delivered by wearing the cloak of the Grim Reaper, members will hear in clear terms the penalties that will befall residents of Castle Point, if they were not to fall in line and endorse whatever local plan messrs Smith, Marchant and Rogers enforce into publication.

Obviously there will be the intention to release more Green Belt land than was previously agreed, otherwise there would have been little need to delay progress of the 2016 local plan.

Instead Bureaucratic measures by this miserable triumvirate have taken over what should have been a democratic and public exercise!

“Intervention by Government in any area of local government business is a last resort and follows poor decision making and failure to follow Government direction and advice.

We have been reminded by Government that intervention is a sanction and should not be considered as an alternative mechanism to deliver a Local Plan.

We are aware that the Secretary of State is still considering whether to intervene in the local plan process.”

There then follows a further threat to Cabinet members, and other council members in attendance;

“In terms of decision-taking, the Government will wish to make certain after intervention that the statutory development plan and policies for the Borough will be implemented and will not allow the local plan once agreed to be frustrated by the Development Control process.

Consequently as the Borough Council had no role in the preparation of the plan, indications from the MHCLG are that the Secretary of State will exercise powers available to him to direct that any strategic planning applications submitted pursuant to the plan will be referred to the Planning Inspectorate directly rather than the Borough Council,”

“As one of the very few planning authorities under intense scrutiny by MHCLG* the Council remains at great risk of intervention and this will lead to considerable reputational damage on a national scale.”

*Ministry of Housing, Communities & Local Government

BUT what if, this likely release of Green Belt and denser Urbanisation of previously developed land, fails to see Developers and Builders deliver the required Housing Needs of London and Castle Point?

It would be naíve to think that developers would build at a rate that would jeopardise the Market Price of Housing. What if the Governor of the Bank of England’s worse projection, a 30% fall in house prices following a bad Brexit, comes to fruition?

Will more land be required to be released because other developers have put forward alternative proposals to those in the Local Plan, which they suggest they are more able to deliver?

Government and local authorities cannot manipulate the market. previous delivery rates ARE relevant, especially when you remember that only Glebelands and part of Jotmans Farm have seen applications lodged and rejected in Castle Point for, a Total of 405 dwellings since 2010!

A cpbc Local Plan that proposes to Release anymore than the 100 Dwellings per Annum agreed by the local council in the 2016 local plan, will not only see protests by residents but will also likely lead to Polling day reaction.

We were promised Localism as the way forward in Plan making.

Instead we will likely see a Bureaucratic plan delivered by the leader of cpbc intended to satisfy the national government.

A Local Plan padded out with aspirational and undeliverable infrastructure and Sea Defence improvements AND a Plan that is Sequentially corrupt!

A new Report by  Lichfields warns of difficulties for local authorities in satisfying the Housing Delivery Test.

Lichfields write;

The housing delivery test (HDT) will become increasingly difficult to satisfy

“The HDT is a monitoring tool the Government will use to demonstrate whether local areas are building enough homes to meet their housing need. Based on the outcome of this monitoring, councils may be required to undertake further action in the near future.”

“In November 2018, the test will compare housing delivery (net additional dwellings plus communal housing) to housing need (the lower of the three years in an up-to-date local plan or household projections plus unmet neighbours’ need).”

The full Lichfield report may be read via this LINK.
maco

Tonight’s the Night – for Canvey Island’s new 57 Bedroomed Residential Care Home? “However”!

The Castle Point borough council Development Committee will tonight consider the proposal for the development of a 57 bedroomed Care Home at the junction of Canvey Road and Northwick Road.

Screenshot (11)

This proposal, within Canvey Island’s depleted Green Belt may present a few contradictory issues during debate.

“Consideration of the proposal under the provisions of the NPPF and adopted Local Plan identifies that the proposal constitutes inappropriate development in the Green Belt, which could only be justified if Very Special Circumstances could be identified,”

“The need for specialist residential accommodation has been identified as a circumstance to which consideration should be given; however, there has been no demonstration that this need can only be met on the application site. In the absence of a clear demonstration that the identified need could not be met elsewhere it is not considered that this circumstance….would justify inappropriate development in the Green Belt.”

The un-identified Need for the Care Home may be difficult to establish, given that the business already has an establishment on a Brownfield site, that it could be argued, may be suitable for renovation to provide the care offered in this new proposal.

“it is considered that the specific scale of development proposed is excessive, resulting in a building of mean and cramped appearance”

“The proposal is therefore contrary to Government guidance as contained in the NPPF.”

The site, currently contains a Garden Centre consisting of basically a large “Green House” style building and wooden canopies to shelter plants. Council officers argue, presumably using imagination, that these they consider “permanent” buildings, in support of the new proposal!

Directly connected to the proposed site is “To the north the site is adjoined by a detached two storey dwelling beyond which is a bungalow and some 112m further to the north, the Dutch Cottage, a Grade II Listed building. 

To the west the site is bounded by open land designated an Ancient Landscape and Wildlife site (West Canvey Marshes Nature Reserve) and used, in part, for the grazing of horses.” 

Given the Approach to development within Castle Point’s Green Belt of late by the local authority on both a Policy level and at Development Committee  level, this proposal may provide some extra confusion to the mix!

Only recently ex-councillor J. King was granted permission for Equestrian facilities consisting of bricks and mortar stables and offices, within the Green Belt.

Contrastingly the need for Housing both market priced and affordable, is proven to exist within the Borough, yet this is denied Approval.

Care MUST be taken in the decision making to establish consistency.

Further, the suitability for a Residential Care Home, within such a small Borough, within an area at Risk of Flooding, should be a serious “consideration”!

The site is opposite an industrial estate with adjoining and nearby roads, Roscommon Way and Northwick Road, the subject of local residents complaints over Noise.

The proposal is also of some considerable size, especially compared to the existing “buildings” on site.

Confusion will be added to debate when the “position” of our previous Local Plans are touched upon. The Adopted 1998 Local Plan is out of date, the Core Strategy is “dead”, the 2014 and 2016 Local Plans are both “withdrawn”, whilst the 2018 hasn’t yet finalised consideration of the Consultation stage!

Most recent development committee decisions have attempted to comply with the proposed non development of so called “virgin Green Belt”, despite the decision in favour of ex-councillor J. King.

The site for the Care Home proposal has been proposed to be included in the most recent draft Local Plan’s. However the 2018 Local Plan is at a development stage, likely to be criticised by an Inspector well ahead of any decision.

Given that the 2 large Green Belt sites in the borough, Jotmans Farm and Glebelands, were both Refused permission  by cpbc officers and committee, and on Appeal also Refused by the Secretary of State on grounds that a decision would be Premature whilst a Local Plan was being produced by the local authority, it may appear “confusing” for a site proposed for inclusion in the 2018 Local Plan, to be decided upon ahead of the new Local Plan’s publication.

A new Local Plan, under close scrutiny from the Government’s Chief Planner, may be better used for Housing or indeed returned to the Green Belt. An interesting proposal indeed.

Whilst this proposal is not exactly the same as either the Jotmans and Glebelands cases we can expect to hear a few “However’s” from the cpbc Case Officer during tonight’s discussion!

Illustration Copyright: Brian Davison estates

Canvey’s Dutch Village GB site back under Threat? Castle Point bc, not only can we produce a sound Local Plan, but we can do so at High Speed! “Watch this Space” indeed!

Short-termism appears to be the “Get Out” approach for Castle Point Borough Council to appease the Government’s intervention team.

Despite no Local Plan emerging over the past 20 years, the latest approach appears to be to crash out an interim 10 Year Plan including Green Belt development sites allocation, and hope for the best that normal service will be resumed with the assistance of our neighbouring Boroughs!
shutterstock_boot_crushing_man

The questions are, which Green Belt sites will be sacrificed in the rush to develop, and which Green Belt sites will developers actually agree with cpbc to build on?

Certainly potentially in the region of 900 dwellings are being installed at Canvey Island’s Sandy Bay, but the distinct threat remains that Canvey Island’s Dutch Village is also cpbc’s preferred Green Belt site in danger of development!

The opinion of outsiders is always useful to keep our feet on the ground, and to help us with that Planning Resource publication have produced their view of the position Castle Point council currently find themselves in, ahead of the secretary of State’s decision on whether cpbc are now trusted to be allowed to produce their own Local Plan under the watchful eye of Government.

As we know a greatly truncated approach has been adopted as the preferred approach of our Borough council, as a means of warding off Intervention in the Plan making process.

CPBC’s interpretation of the situation is directly below, whilst further below is how the “trade” press’ view.

“the Government has confirmed that it will intervene in plan-making in areas where councils without a post 2004 local plan have not submitted a plan for consideration by the Planning Inspectorate. This will reduce the control the local planning authority has over such matters. In March 2018, the Council received a letter from the Secretary of State for Housing, Communities and Local Government confirming the intention to commence Intervention in the Castle Point Local Plan. As of June 2018, the form of this Intervention had not been confirmed, but dialogue with the Ministry has confirmed the need for a Local Plan to be prepared to an accelerated timetable, and this Plan must focus on bringing forward new homes in the early part of the Plan period.”

“The Local Plan will tackle contentious issues that could give rise to significant public opposition. Whilst every effort will be made to build cross community consensus, there remains risk of significant public opposition to the Local Plan proposals.”

“Logistically this could cause a higher volume of work in the processing and analysis of representations than accounted for in the LDS timetable, which could set it back.”

“To help reduce this risk, responses from the 2014 and 2016 draft Local Plan consultations will be used to assess public opinion. The 2014 and 2016 draft Local Plans will form the majority of the new Local Plan so previous consultation responses as well as updated evidence will help inform the Plan.”

“In February 2017, the Government introduced the proposition that all Local Planning Authorities (LPAs) be required to prepare a ‘Statement of Common Ground’ (SCG) to help manage strategic planning matters across local authority areas and strengthen the Duty to Cooperate”

“3.5 Castle Point
Castle Point is a relatively small local authority area just 4,500 hectares in size, with a population of 88,000 people. It sits at the heart of the South Essex sub-region on the northern bank of the Thames Estuary between the larger settlements of Basildon and Southend. It is these larger settlements, along with London, on which Castle Point relies for its employment, services and leisure opportunities.
The key planning issues comprise:
• the challenge of meeting housing need in a borough of significant Green Belt and other environmental constraints and where land availability is confined to small scale infill sites in the built-up area;
• the need to improve infrastructure to address congestion, historic underinvestment and provide capacity for growth;”

“9.1
Castle Point currently has no up to date local plan in place and has therefore been subject to potential government intervention. The Council will therefore prepare an interim local plan covering the next ten years and focusing on planning for housing, with the ambition of meeting local housing needs in this period. In the longer term, local housing needs will be considered through the strategic assessment and allocations prepared for the JSP.”

“The current estimated need for housing across South Essex is 90,000 dwellings over the next 20 years, but with the right conditions to support growth, more could be achieved. As part of the consideration of long term spatial options, the authorities are therefore exploring whether the development of new ‘Garden’ communities could offer a strategic solution to growth.”

“The South Essex Authorities estimate that up to 4,500 new homes will be needed each year to meet housing needs.” *

Planning Resource publisher’s opinion of the situation Castle Point find our / themselves in are reproduced here;

A group of seven Essex councils this month published a draft statement of common ground (SCG) designed to make sure they meet the challenging duty to cooperate. The statement commits them to preparation of a formal joint strategic plan for a green belt-constrained area where local plan processes have been hobbled by an inability to resolve local opposition to much-needed new homes.

The statutory joint plan is being pursued by six districts and boroughs – Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea and Thurrock – and Essex County Council. At the start of the year, they formed the Association of South Essex Local Authorities (ASELA) to formalise joint working arrangements. According to the SCG, the joint plan will provide an “overarching framework within which more focused local development plans will be prepared”.

Requiring unanimous approval from all seven councils to go forward, the joint plan will set out housing targets and distribution as well as key employment sites and infrastructure priorities. Its prime purpose, commentators say, will be to decide where to find space for the required 90,000 new homes in south Essex over the next 20 years, given significant green belt constraints.

Consultant Catriona Riddell, who is advising ASELA, said: “With the area’s large proportion of green belt, all the authorities have challenges in terms of meeting housing needs, so they have decided that looking at strategic growth areas across south Essex would be the most deliverable and sustainable option.”

Nick Davey, partner at Brentwood-based planning consultant JTS, said determining housing allocations has been a big problem. “I feel sorry for the planners,” he said. “They have to try to meet objectively assessed need and that means releasing green belt, but they just can’t get members’ buy-in. All that’s happened since the 2012 National Planning Policy Framework is procrastination.”

The draft SCG doesn’t grasp this nettle.

Instead, it identifies five “strategic areas of opportunity” where housing may be located, all of which straddle local authority boundaries and thus leave exact allocations undetermined.

Riddell said the body has now commissioned a strategic growth study to further develop these proposals. “Some authorities will ultimately have to take a disproportionate share of the homes – those are the issues we haven’t got to yet. They need to stick together like glue,” she said.

The joint plan comes in the context of delays in local plan preparation led to three of the districts – Basildon, Brentwood and Castle Point – being threatened with intervention by former housing secretary Sajid Javid last year for their slow progress. In March, Javid pressed ahead with sending a government team in to scrutinise Castle Point’s local plan preparation arrangements. He told Brentwood and Basildon they’d face no further action, but warned he’d keep a close eye on them.

Castle Point’s last attempt at a local plan, which left 300 of its 400 homes-a-year housing need unmet, was withdrawn last year after failing the duty to cooperate. It is now seeking approval from the government to develop an interim local plan covering just five to ten years, allowing it to avoid large green belt allocations and leaving responsibility for further allocations to the joint planning process.

Riddell said: “The vital thing is that any intervention doesn’t compromise the joint planning effort by forcing Castle Point to release green belt that, from a wider south Essex point of view, might not be in the right place.”

Some fear, however, that the joint plan process will be used to justify continued delay. Tony Collins, owner of consultancy Collins & Coward, said: “Joint plans take a long time to draw up and even longer to deliver. The government wants delivery but joint planning is only going to slow things down.”

Riddell recognised government fears that the joint plan promises “jam tomorrow”, but pointed out that the SCG, once approved, will commit the ASELA authorities to an “accelerated timetable” that will see a draft plan consulted upon early next year, with submission for examination a year later. “It’s really fast,” she said. “These concerns are totally unfounded.”

* 6 Jun 2018 – Special Meeting of Castle Point Borough Council agenda appendices.