Tag Archives: May Avenue

Hypocrisy, the Use of Substitutes, a Deciding Vote and a Divided Borough? Sequentially Unsound!

It appeared that what can only be described as a level of Hypocrisy was displayed by certain Castle Point Development Committee members towards a view suggested by the opposition group at the 5th September’s meeting!

The suggestion appeared that Canvey was, put simplistically, being targeted for development so as to protect the mainland areas. It was expressed that Canvey should not be portrayed as an individual area, rather than an equal part of the whole Borough of Castle Point.

However the whole basis of the Flood Risk Sequential Test, as interpreted by Castle Point Council, is to treat Canvey Island in isolation!

“it is considered that continued development is necessary in order that the settlement of Canvey can continue to thrive economically and socially.”

” Canvey needs continued development if it is to continue to thrive economically. A lack of housebuilding on the island could mean that the island stagnates in economic terms which is likely to affect opportunities for employment. “

Indeed the Thorney Bay proposal for 600+ dwellings  was subject to a CPBC Planning Policy statement stating that “the site was identified as having the potential to contribute towards the 5 Year Housing Supply (of the Borough)”!

Regardless of the application being considered, whether for a single unit or a proposal for over 600 dwellings on Canvey Island, it is fairly clear that using this interpretation of the Sequential Test to support development proposals, there is no likelihood of any planning proposal Failing the Test!

It is a convenient and flimsy argument to accuse Islanders of focussing on cpbc’s apparent approach to Canvey development, whilst the Sequential Test is used to do precisely that!

It should be of concern, that since Canvey land was designated for the use of Housing in the 1998 Local Plan, and that since the Sequential Test approach towards its application on Canvey development proposals was adopted by CPBC in 2007, these events have occurred and these Reports have been published;

  • The Pitt Review-Learning Lessons from the 2007 floods. (Published 2008) !!!
  • The CPBC Strategic Flood Risk Assessment published in 2010. (In itself due an Update.)
  • Surface Water Flooding has occurred on Canvey Island during 2013.
  • Surface Water Flooding has occurred on Canvey Island during 2014.
  • Government Office for Science – Canvey Island Section 19 Report
  • The requested Drainage Improvement / Upgrade funding has not materialised.
  • We learned that the land on Canvey Island has a High Water Table, subject to influence by the Tidal Water encroaching Under the Sea Defences. (Land East of Canvey Road document).
  • The Integrated Urban Drainage Study was published, which challenged the credibility of the CPBC Surface Water Management Plan published 2012.

Quite clearly the Castle Point Council approach to the application of the Sequential Test on Canvey Island in isolation, is Obsolete and Unjustified!

Attenuation Tanks were discussed as a means of a suitable drainage system. Had the committee not considered that Canvey has a High Water Table, now known to be subject to Tidal influence? In this case the Tank would be sunk into the application site property, how efficient would this system of drainage be?

Photo Police helicopter 2014

The focus of the drainage system needs to be to prevent off-site flooding of neighbouring property and land. Without going through the exercise of producing a Practical Model on Canvey island and monitoring over an extended period councillors should not be in a position to simply go by unsubstantiated opinion in their decision making!

Whilst the protection of Green Belt, which is admirable, is at the forefront of councillors minds, it must be borne in mind that Paragraph 14 of the national Planning Policy Framework contains Footnote 9, which indicates;

specific policies in this Framework indicate development should be restricted.9

those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion.

Whilst this specifically relates to Plan making, it is clear that, if the concern is present amongst decision makers development in a Flood Zone and in a Critical Drainage Area, in which Canvey Island falls into both categories, caution should be the operative position to adopt.

Residents suffering the Canvey Island Flooding of 2013 and 2014 may well feel appalled at the rigid Rejection of development applications on Green Belt, whilst a less than cautious approach appears to be adopted where Flood Risk is concerned, by certain cpbc development committee members.

The cpbc officer appeared unaware that the whole of Canvey Island is a Critical Drainage Area.

The questionable use of Substitute councillors to replace two absentees at the meeting, bearing in mind the technical issues highlighted in this planning proposal, proved to be decisive, as 1 voted to Approve and 1 voted to Abstain.

With the votes recorded as 5 to Approve and 5 Against, with 2 Abstentions, the Chairman chose to use his Casting Vote, and consequently rather than holding further deliberations on the subjects contained within this post and others not mentioned, the Application was Approved!

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May Avenue, Canvey Island – Flooding Lessons Never Learned by CPBC- or were they never meant to be?

The controversial proposal to develop on a narrow green space in May Avenue, Canvey Island, returned for cpbc development Control committee consideration.

The previous application had been Rejected and on Appeal was upheld by the Planning Inspector.

The problem with cpbc being taken to Appeal over development is the crazy system of officers demanding Reasons for a development’s Rejection immediately the vote has been taken. There should be a process whereby the officers Report including Reasons for Objection is given further consideration before the officers are allowed to sign off their reports.

It is these Reports that stand as the Borough’s case during a written Appeal considered by the Planning Inspectorate and they appear to be practically made up on the hoof!

This time around some members voiced continued concerns, whilst the officer warned against the consequences of again Rejecting the proposal.

In the end a Motion to Defer the decision was Agreed.

One of the main issues MUST be that of the principle of Flood Risk.

No Objection from the Environment Agency, and the Developer indicated that the famed Canvey Integrated Urban Drainage study showed flooding, similar to that of the summer of 2014 would leave the proposed development dry.

Shame the same thing cannot be guaranteed for the Neighbouring Existing May Avenue Properties!

There is an agreed guidance between the Environment Agency and castle point council for small development sites.

Part of this guidance states;

“The National Planning Policy Framework (NPPF) and its supporting Technical Guidance Document set out the Government’s national policy on development in areas at risk of flooding. It seeks, wherever possible, to avoid inappropriate development in areas at risk of flooding. Where it can be demonstrated that development is required in these areas, the NPPF seeks to ensure it will be safe over the lifetime of the development and will not increase flood risk elsewhere and where possible, reduce flood risk”

Developing what is a narrow greensward area between two properties can only add to the pressures on the Canvey Island drainage system.

Replacing a greensward with a bricks and mortar dwelling and driveway will likely increase the Flood Risk to Neighbouring properties, against NPPF requirement.

The cpbc planning officer was dismissive of these concerns stating that the local authority’s position regarding Sequential Testing (where development should take place in less Flood Liable Zones) falls within the usual mantra;

“With regard to the sequential test, the proposal seeks to provide dwellings on Canvey Island. For residential development to serve the community of Canvey Island it is considered that it would need to be located within, or immediately adjacent to, that settlement.
Since the settlement of Canvey Island is located entirely within Flood Zone 3 it is not considered that there are reasonably available alternative sites within the area with a lower probability of flooding that could accommodate the proposed development. Under the circumstances it is considered that the proposal passes the sequential test.”

This is ambiguous! The first paragraph implies that the community of Canvey Island should remain where it is, no migration allowed! Castle Point is one of the smallest Boroughs in England however, no similar concerns are applied to Benfleet, Hadleigh nor Thundersley.

These mainland towns have populations that are barely increasing, and yet they face no similar Flood Risks.

The cpbc New Local Plan Sequential Test for Housing Site Options states;

In order to deliver 200 homes per annum for the period 2011 to 2031 (4,000 homes in total), it is necessary to identify developable sites with a further capacity to accommodate 2,400 homes. Approximately, 500 of these homes will be secured at Thorney Bay Caravan Park, and 99 at the 101 Point Road, Canvey Island. It is expected that redevelopment within the existing residential areas of the borough will secure approximately 380 additional homes in this period also. Therefore, the sequential test will be seeking to identify developable sites with a capacity of 1,421 homes.

Quite clearly, development on Canvey Island is in support of the Borough’s Housing Needs! Therefore this isolationist application of the Sequential Test by castle point council, to Canvey Island alone, has No Justification!

It should be remembered that the National Planning Policy Framework gives Equal Protection to Green Belt land and Land at risk of Flooding;

specific policies in this Framework indicate development should be restricted.9

9 For example, those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion.”

Committee members concerns whether surface water flooding could be prevented by Attenuation Tanks were wide of the mark. Canvey Island has a notoriously High Water Table, create space for a tank below ground simply pushes flood waters higher and wider!

See if these extracts ring any bells, you should all, Canvey Islanders anyway, recognise where these words come from and relate to;

“pumps are the final element of a long, incredibly complex and interlinked surface water drainage system comprising of drains, culverts, sewers, open watercourses, main rivers, pumps and storage areas all with varying capacity, which need to be operating efficiently in order to drain the island. Rainfall on the island may flow a substantial distance before reaching the pumps, through infrastructure owned or managed by a large number of different organisations and individuals and in some cases without a clear understanding of ownership. Any constriction on flow either due to blockage or insufficient capacity for the rainfall event can affect the effective operation of the entire drainage system”

“The pressure on the drainage system on Canvey Island has intensified over the last 50 years due to further development, and it is evident that in some locations some drainage infrastructure is no longer at the necessary capacity to provide sufficient drainage”

” Given the unique nature of the drainage system and the scale of investment needed, to achieve significant results in Canvey Island will require that special support be provided by DEFRA. With this understanding, multiagency cooperation and additional Central Government funding it may be possible to make necessary and feasible improvements to the drainage system and effectively reduce flood risk in some areas.

The population of Canvey Island consisted of 38,459 people back in 2011, and yet cpbc position is that unless the population continues to grow, the Island will become unsustainable.

What utter Tosh!

There are 38,500 people at Risk of Flooding, local agencies have proven they cannot cope should we suffer from Surface Water Flooding, and yet the Local Plan proposal is to put more and more people at Risk!

If that is not what unsustainable development means then I don’t know what does!

The Sequential Test, as adopted by CPBC, is out of date!

The Strategic Flood Risk Assessment is out of date!

The agreement between the Environment Agency allowing Castle Point Council to decide (take responsibility for) the safety of new development over its Lifetime is out of date!

That Canvey is a “Special Case” where development is concerned, is out of date!

The £24,500,000 required to mend the Canvey Island “Broken” Drainage System has never materialised!

The Canvey Green Belt Campaign group maintain the position that the Island’s population should be maintained at the current levels or lower. All planned development on Canvey should be the subject of the Local Plan alone!

The infrastructure cannot cope with more, whilst the Island’s economy is reasonable given the UK’s circumstances. Whilst the Town Centre may be showing some signs of struggling in the more expensive locations, this is not helped by out of town commercial development in the pipeline.

Lessons clearly are not being learned despite assurances from senior officers!