Tag Archives: Housing Need

Persimmon approach the First Hurdle for Canvey Island’s Dutch Village Green Belt Development! CPBC Censorship!

Persimmon have Housing Development plans for Canvey Island. However they appear happy to play the Long Game.

Plans have been registered with Castle Point Council for Stables for 3 Horses at the Dutch Village. This will include the “Change of Use of Land” as it is Green Belt.

Their Application stresses the stables will be “Built Development”.

We have covered this in a previous blog post HERE.

For those concerned or wishing to make comment we thought it might be helpful to make public our Grounds for Objection as registered with Castle Point Council, these should be visible below for you to see:-


Runnymede Towers

Please be advised WE DON’T HAVE TO MAKE COMMENTS VISIBLE TO OTHER RESIDENTS on  the Castle Point website. This may be due to us not wanting others to know what Residents think or just us choosing to Censor information.

Anyway we don’t care, cos the legislation says we don’t have to! Editor.

“As prescribed in article 15 of the Development Management Procedure Order, local planning authorities are required to undertake a formal period of public consultation, prior to deciding a planning application. There is however, as you correctly stated, no legislative requirements for any comments received as part of that consultation to be available to view online.

The Castle Point website does however show the number of comments that have been received on any application so the level of public interest can be clearly identified. We are not alone in this approach, it is commonly adopted by a number of authorities, our neighbouring authority of Basildon being one such example.

We have been working in this way for some time now and we certainly have no evidence to suggest that this is in anyway deterring people from commenting. Indeed we have an application which is currently open for consultation that has received 135 comments to date, demonstrating I believe that the community remain fully engaged in the process.

Planning guidance states that officer’s reports should include the ‘substance of any objections, contain technical appraisals which clearly justify the recommendation and should have a written recommendation for the decision to be made’.

Comments received in respect of a planning application can only be considered if they are, what is commonly known as, ‘material planning considerations’. Comments which are not material cannot be considered in the determining of a planning application and any such comments will not therefore be referenced in a report by an officer nor should they be considered by members at Committee.

The information you have appended below your email is indeed an ‘extract’ from a much longer report however I should point out that it omits to make reference to the consideration of all relevant objections in more detail throughout the body of the report, which more fully explain how the objections have been considered against planning policies and guidance.

Development Control Committee can, and often do, make a decision which is different from the officer recommendation and this will often reflect a difference in the assessment of how a policy has been complied with, or different weight ascribed to relevant matters.

Thank you again for contacting us.

Regards, Castle Point Borough Council”


China Crisis = Answer to Canvey Island issues? Or – Castle Point’s Broken Local Plan Process “the continued development of Canvey Island is necessary”???

“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 .

This slideshow requires JavaScript.

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
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”.

We thought the title appropriate!

A Little Government Help with assessing Castle Point’s Annual Housing Needs – as if we needed any!

The Castle Point Council long winded Local Plan process, (yes we know it is important to get it right and that No Plan is better than a Bad Plan, oh sorry that is a different current process), has indicated with the usual accuracy that the current Housing Need is roughly between 326 -410 New Dwellings per Year!

The latest Government Assessment indicates, ahead of a consultation on the methodology used, that Castle Point requires 342 New Dwellings per Annum.

The estimate of Green Belt land in the Borough is 55%.

This consultation sets out a number of proposals to reform the planning system to increase the supply of new homes and increase local authority capacity to manage growth.

Proposals include:

  • a standard method for calculating local authorities’ housing need
  • how neighbourhood planning groups can have greater certainty on the level of housing need to plan for
  • a statement of common ground to improve how local authorities work together to meet housing and other needs across boundaries
  • making the use of viability assessments simpler, quicker and more transparent
  • increased planning application fees in those areas where local planning authorities are delivering the homes their communities need

The ‘Housing need consultation data table’ sets out the housing need for each local planning authority using our proposed method, how many homes every place in the country is currently planning for, and, where available, how many homes they believe they need.

Alongside this consultation, the ‘Comprehensive registration programme: priority areas for land registration’ document lists those areas where Her Majesty’s Land Registry intends to prioritise the registration of ownership of all publicly held land.

A link to the Consultation can be found HERE.

Apologies for the lack of any photograph, we hope it doesn’t detract from the content.


Thorney Bay, change of Use Over-Heard on the Canvey Grapevine! CPBC Local Plan issues?

It started as a Whisper, became a Rumour and has now reached Conjecture level on the Canvey Grapevine!

Thorney Bay, the apparent answer to the Castle Point Council’s Local Plan dreams, has become the subject of unconfirmed speculation. With the humiliating Withdrawal of the cpbc Core Strategy in 2011, it was considered “timely” by cpbc officers that Thorney Bay, despite it being sited within the Hazard range of Calor Gas and within a 3A Flood Zone, should come forward to provide a Housing Development of some 600 dwellings plus sheltered accommodation.

Thorney Bay then became the Backbone, the largest single development site, of Castle Point council’s daft Local Plan and surviving the GB sites cull to remain as the spine of the Local Plan2016, 5 year Housing Supply!

The Thorney Bay proposal passed in Principle by the cpbc development committee, whilst in the following months / years a 1st Phase proposal has gained Health and Safety Executive’s permission and is apparently overcoming the Flooding Objections to the fundamental requirements of the Environment Agency and the ecc Lead Local Flood Authority.

Now then; Listen very carefully, I shall say this only once!

A little Bird has told me, and I must say there is little foundation, so to speak, for this to be considered information, but it could be that the development may not be going much further!

To me this would not be a surprise, I would have thought a more likely idea would be for the developer to follow the Kings Park, and remove the static caravans and replace with Park Homes.

The build cost would be far less, the speed of development would be probably twice as quick and success of the venture equally, if not more so, financially successful as Kings Park!

What’s to lose?

Park Homes and Luxury Lodges can easily reach an asking price of £300,000, the site is opposite Thorney Bay Road, and residents would likely be of an age not too concerned with, the daily commute.

Now that the Canvey Bay Watch team have created such an attractive area of the promenade and beach front, this forms another selling point for potential Park Home buyers. I would have thought that the Canvey Bay Watch team should soon be knocking on the site owner’s door for financial support, should this development rumour come to fruition!

Thorney Bay 1

Photograph courtesy: Dave Harvey

The question for cpbc is whether these Park Homes should count towards the official Housing Supply.

On one hand these Park Homes “are suitable for residential use throughout the year and are built to last at least 50 years”! (Omar park and leisure homes). Although whether 50 years lifespan is considered permanent is challengeable, however, their success is, and there are people desiring to own them.

The Planning Inspector examining the Glebelands, Thundersley, Appeal did not consider the numbers at Kings Park should qualify for inclusion in building numbers, but that may have been due to cpbc being unable to clarify how many caravans were replaced by Park Homes.

We do know that of the caravans at Thorney Bay the Inspector concluded;

“But that does not necessarily mean that the Households now occupying caravans would have chosen that type of accommodation, in preference to bricks and mortar.”

Well, “bricks and mortar” these Park Homes ain’t! But the appeal of Park Home life is generally popular across the UK, so if people are choosing to buy into this type of accommodation, then there is an argument for these dwellings to be included into the Canvey Island Housing Supply count.

With our “Broken Housing Market” leading to the apparent need to revisit Pre-Fabricated Housing, these Park Homes may well have some scope.

Whether or not any Affordable Home supply can be squeezed into the equation will be upto the negotiating abilities of cpbc, so we won’t hold our breath on that one!

What could be expected is for some Canvey Island “bricks and mortar” dwellings to become available, for local young families hoping to get on the property ladder, as older Canvey residents move into the Park Homes.

It may be doubtful , should the development come into fruition, whether the Housing Need in the mainland part of the Borough be part satisfied, as it will be difficult to argue that this type of dwelling satisfies the cross market “bricks and mortar” Housing Need. In fact it probably increases the pressure on mainland site supply.

I remind you this is only speculation.

As a reference, below, I include part of the text of the cpbc Report on Residential use of Caravan and Park Home Sites 2013.

“It is clear from both Census data and from Council Tax data that an increase in the availability of caravans for residential use resulted in an increased housing supply of the order of 800 homes in Castle Point in the period from 2001 to 2011. This increase was largely as a result of the change of use of Kings Park and Thorney Bay Caravan Parks from holiday use to residential use.”

“To date, the Council has only included those caravans registering for Council Tax at Kings Park within the housing figures for the period 2001 to 2011. However, given that caravans at Thorney Bay were included as homes within the Census 2011 outcomes, and this will be reflected in population and household data moving forward, it is appropriate that the housing supply figures for the period 2001 to 2011 are appropriately adjusted to include these homes also.”

“The change of use of static caravans from holiday accommodation to residential accommodation has made a significant contribution to housing provision over the last decade (2001 to 2011). Approximately, 800 additional caravans moved into permanent residential use over this time period, primarily on the Kings Park and Thorney Bay sites. This is supported by evidence from the Census and from Council Tax records.”

“However, whilst some of this provision has contributed positively towards the community, in particular at Kings Park, the nature of the provision at Thorney Bay has had negative socioeconomic consequences both for the surrounding community and for the vulnerable families who have found themselves living at the site.”

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

“Assuming that the proposals to redevelop this site as proposed for traditional housing are delivered in full over the next 10 years, then it is unlikely that the number of households living in caravans in Castle Point will increase further between 2011 and 2021. Indeed, as a result of the development of traditional housing over this period, it is expected that the proportion of households living in caravans will reduce.”

“However, should the Thorney Bay site not be redeveloped as proposed, then there is the potential for a further 800 caravans moving from transient use into permanent residential use. This will increase further the number of households living in caravans, and the associated socio-economic issues arising from this. It is therefore imperative that the Council work alongside the site owners to encourage and facilitate the redevelopment of this site in an appropriate timeframe.”

Video copyright BBC

Green Belt and Housing under Pressure, what’s the answer? Invitation to comment to our Local Representatives!

“Maintain existing strong protections for the Green Belt and clarify that Green Belt boundaries should be amended only in exceptional circumstances when local authorities can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirements.” Part of Summary, Gavin Barwell.

Does this signal a Green Light from the Government to develop across Castle Point’s Green Belt?

Hadleigh Castle land under threat of development

It can be argued that Gavin Barwell’s statement infers that:-

Green Belt boundaries should be amended when local authorities have examined all other reasonable options for meeting their identified housing requirements!

And that a;

Lack of Housing land constitutes the Exceptional Circumstances necessary to require amendments to the Green Belt boundaries.

Extracts from the White Paper include;

A.115 It is imperative that local authorities start to address under delivery in their area through their action plans to ensure they are meeting their delivery requirements.

A.63 We are also proposing that national policy would make clear that when carrying out a Green Belt review, local planning authorities should look first at using any Green Belt land which has been previously developed and/or which surrounds transport hubs.

Given the aspirations of some castle point councillors it may appear appropriate to re-examine the cpbc Green Belt review, even to carry out an independent new review as support evidence for the Local Plan2016.

The growth of intense pressure to alter the appearance of castle point through growth continues. Given the current style of populist politics, it may appear that the residents might deserve a Referendum on the topic, carried out alongside this year’s Local Elections, so that their views on these issues can be registered!

It would of course be appreciated if some clarity, rather than speculation, was to be forthcoming from our local representatives.

To view the Government’s white paper document “Fixing our Broken Housing Market” use this LINK.

CPBC Local Plan2016 Duty to Cooperate Failed. Plan Withdrawal Recommended!

Much as had been predicted by far greater planning minds than ourselves, it has been announced that the Examining Inspector of the Castle Point Local Plan2016 has Failed the LP at the first hurdle – the Duty to Cooperate.

This will be a great disappointment for some, whilst no doubt others will take pleasure in proclaiming “we told you so!”

Given the somewhat aggressive nature of the other neighbouring authorities, especially Thurrock, it is difficult to guess how the position can be brought together.

One can only assume this may cause quite some delay.

From the Inspector’s remarks and conclusions it may be assumed that the hasty conclusion of the cpbc Local Plan Task and Finish group work contributed to the demise of the process.

Whether certain senior councillors should have been aware of this pitfall is open to conjecture.

Officer and councillor work on progressing the Local Plan2016 appears uncoordinated.

This in turn has cost residents some great extra expense.

Furthermore the Jotmans Farm developer may press for the Appeal Inquiry decision and the Dutch Village developer see a loophole in the Green Belt policy in the light of this Duty to Cooperate Failure.

Cherry picked copy and pasted extracts of the Planning Inspector’s letter appear below. The full letter is available on the LP Portal.

Taken as a whole throughout the preparation period from 2011 to August 2016 it appears that cooperation was structured and frequent. Whilst there may have been some loss of focus on strategic planning matters between 2014 and the early part of 2016, activity did not come to a complete stop.  There is no chronological record of what took place when but the picture painted by all those involved is one of active and more or less on-going engagement.

However the information provided is weaker in showing how cooperation actually influenced the New Local Plan.

The New Local Plan is based on an objectively assessed need for housing of 400 dwellings per annum.  Paragraph 13.22 recognises that the target for new homes does not equate with this but it reflects the capacity of the Borough to accommodate growth.  A subsequent updated Strategic Housing Market Assessment (SHMA) in May 2016 gives a range for objectively assessed need of between 326-410 dwellings per annum.  Be that as it may the draft New Local Plan proceeded on the basis of providing 200 dwellings per annum but this was reduced to 100 dwellings after the failure of the Task and Finish Group to reach agreement on the release of Green Belt land for housing in November 2015.

As far as the Council is concerned no amount of further conversations would have altered the difficulties in meeting its objectively assessed needs within its boundaries.


  1. The questions of whether the strategy for housing is the most appropriate one and therefore justified and whether it is consistent with national policy, including paragraph 14 of the NPPF, are soundness ones. However, paragraph 179 of the NPPF provides that:

Joint working should enable local planning authorities to work together to meet development requirements which cannot wholly be met within their own areas – for instance, because of a lack of physical capacity or because to do so would cause significant harm to the principles and policies of this Framework.


This is precisely the situation in Castle Point. Indeed, the officer report of July 2014 which set out the full document representations on the draft New Local Plan (CP/05/008) includes the following as an action point:


Given that the Council has not been able to identify a sufficient supply of housing to meet its objectively assessed needs, it is also necessary to engage with neighbouring authorities under the auspices of the Duty to Cooperate in order to determine how the objectively assessed need for housing, and other strategic matters, will be addressed within the housing market area.

  1. However, notwithstanding the lengthy and detailed engagement across south Essex there is no formal mechanism in place to distribute unmet housing need. In order to comply with the duty there is no requirement for this to be done by any particular means.  Indeed, the outcome of joint working in this respect could take a variety of forms and it is not for me to say what they should be.  Nevertheless, the position is that there is simply nothing in the New Local Plan to indicate how the unmet need for housing will be tackled.  This is because the authorities have not yet deliberated about the matter in any meaningful way.  Therefore the question of how the objectively assessed need will be addressed, as raised by officers in 2014, has not been adequately grappled with.
  2. The Council is now anxious to ensure that the delivery of its objectively assessed needs is addressed with neighbouring authorities and intends to play a full and active part through the various DtC mechanisms that are now operating. There is no reason to doubt this but a failure to demonstrate compliance cannot be corrected after submission (PPG ID 9-018-20140306).

There is no duty to agree (PPG ID 9-00320140306).  However, whilst it might be firmly in view now, there is no clear evidence that consideration of this admittedly difficult issue was attempted as part of the preparation of the New Local Plan.  Within that process it has been treated as an ‘afterthought’.

all the indications are that in this respect the Council decided to ‘plough its own furrow’.  Failing to address the wider impact of its ‘last minute’ decision to lower the housing target by a considerable amount is the very opposite of cooperation in plan preparation.

the Council fell well short of making every effort to secure the necessary cooperation on the strategic cross-boundary matter of housing before submitting the New Local Plan for examination.  The engagement undertaken as part of its preparation was fundamentally flawed.

Whilst the Borough may not hold all or any of the answers to the shortage of (travellers) pitches in Basildon it should attempt to play its part.  Ultimately it might be that providing more traveller sites in Castle Point is not the best planned solution but there is a duty on the Council to try.  In preparing the New Local Plan it simply has not done enough in this respect and there has been a DtC failing.

In specific terms the housing policies have failed to address how unmet need will be dealt with across the housing market area.  This is exacerbated by the lack of consideration of this matter when reducing the housing target by 50%.

However, there have been fundamental shortcomings in the steps taken, or not taken, to secure the necessary cooperation on the strategic cross-boundary matter of housing.  In addition, the Council has not made every effort to consider how it might deal with the significant unmet need for traveller sites in south Essex arising, in particular, from Basildon.

Therefore my final conclusion is that the duty to cooperate has not been complied with.  Clearly this is not the outcome that the Council would have wanted and it is not a view I have reached lightly or without full consideration of the material put to me.

Nevertheless I must recommend non-adoption of the New Local Plan under Section 20(7A) of the 2004 Act. In this situation the PPG advises that the most appropriate course of action is likely to be for the local planning authority to withdraw the plan under Section 22 and engage in necessary discussions and actions with others.  That is the course of action I would favour.  The alternative is to receive my report but the content of this would be substantially the same as this letter.