Tag Archives: over development

Canvey Island development Free for All! Environment Agency weak approach encourages Castle Point Council’s laissez-faire attitude to Planning!

Are you sitting Comfortably?

Then I’ll begin –

“The (Canvey Island) application site is located within Flood Zone 3a, which has a high probability of flooding. Looking at the whole of Castle Point District it would seem that there are areas within Flood Zone 1 that could accommodate this form of development.

However, given that the only areas of Flood Zone 1 in the district are on the “mainland” part, such an approach would direct all new development towards Benfleet and Hadleigh.

Canvey is a self-contained community with its own housing needs and directing all new development towards Benfleet and Hadleigh could have an adverse impact on Canvey socially and economically.

Furthermore, a need for housing on Canvey cannot be met by building around Benfleet and Hadleigh due to other constraints such as the Green Belt.”

So says the cpbc Planning Officer as the latest attempt to convince residents, councillors and, no doubt the Planning Inspectorate, that castle point council’s approach to the application of the Flood Risk Sequential Test is morally sound!

July 2014photo3

Going back just 10 years things were different and the Environment Agency held a more cautious and responsible stance:-

Extract from the Echo June 2008
“DEVELOPERS seeking to build new homes on Canvey are being forced to think again because of growing fears about flooding.
The Environment Agency is resolutely pursuing its policy of recommending refusal of plans to build new homes on the island because Canvey is below sea level and therefore on a flood plain.

Castle Point Council is taking those recommendations to heart and rejecting applications for new homes, leaving some developers in limbo.
The council has pledged to continue upholding the Environment Agency’s recommendations until the results of a Government-initiated inquiry into flood plains publishes its findings.

The Government appointed Sir Michael Pitt to carry out the study, following catastrophic floods in Hull after heavy rainfall in June and July last year. It is likely the final report expected, this summer, will recommend tighter restrictions.

Ray Howard, Castle Point and Essex county councillor, said local authorities were reluctant to ignore the Environment Agency’s advice, while they are waiting for the results of the Pitt Report.
Mr Howard has received many letters from people struggling to build on Canvey.
He said: “It’s a big problem that needs to be looked at. We can’t have a blanket ban for building here.
“I believe Canvey is unique, as it has the best flood walls and flood water drainage system in the country.

“The flood plain rules should be relaxed for us.”

Last week localised flooding on the island, caused by heavy rainfall, affected hundreds of residents on the island.

But Mr Howard is convinced it is well protected against severe flooding from the Thames Estuary.
A total of £34 million was spent rebuilding Canvey’s sea walls in the 1970s and 1980s.
A further £6 million was spent last year on 14 giant pumps, spread around the island to force water back into the sea if the walls are ever breached.
Mr Howard said: “The reason Canvey is always considered high-risk is because of the 1953 flood.
“But back then the only sea defences were soil walls, built by the original Dutch settlers.”
The 1953 Canvey flood claimed the lives of 58 people.

Despite Mr Howard’s insistence that Canvey is well protected, the Environment Agency refused to budge from its policy of objecting to all new homes on flood plains.
Spokeswoman Rita Penman insisted the Environment Agency could not relax its planning guidelines for Canvey,

She said: “Although Canvey is well defended, the current understanding across the country is that if there are other areas not on the flood plains, they should be developed first.

“This is in the interests of everyone’s safety. We are therefore unable to recommend approval for any new developments on Canvey at the present time.”

Even if the Government report clears the way for new homes on flood plains, insurers are warning hundreds of thousands of homes built in high-risk areas may not qualify for insurance.

Nick Starling, the Association of British Insurers’ director of general insurance and health, said: “Poor planning decisions will lead to more homes becoming unsaleable, uninsurable and uninhabitable”

Disappointing then, that following the Summer Flooding of 2014 the cpbc chief executive officer should point out that the Canvey Island drainage system – was never intended to be able to cope with Tidal Flooding of the Island!

But of course the findings of the cpbc Scrutiny Committee’s meetings to discuss the flooding and its consequences, during which the ceo made the admittance, has never been published, despite the flood occuring 4 years past!

To enforce the Association of British Insurers position, above, the Flood Re scheme to guarantee affordable house insurance against flooding does not cover houses built since January 2009.

Has Caveat emptor, been anymore appropriate?

I have been reminded by a sceptical mainlander that, “IT IS HARD TO FOOL PEOPLE, BUT IT’S EVEN HARDER TO CONVINCE PEOPLE THAT THEY HAVE BEEN FOOLED.”

The short EA video below may give you some insight as to the sensibility of those that propose and support the over development of Canvey Island and whether the drainage system could ever be made capable of alleviating Flood Risk!

The EA expert’s explanation of how the drainage System is designed to work, appears to be far different to the practical experiences during 2013 and 2014 and the isolated Flooding incidents during other periods!

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Canvey Island, Flooding, Over-Development, Local Plan, draft NPPF Consultation and the National Flood Forum. Unrest Grows!

Canvey Island, is synonymous with Flooding.

rebecca_harris_mp_flood_free_homes

Despite the tragedy of 1953, the major Surface water Flooding of 2014 and other similar events, Canvey is cynically treated as a “Special Case”. This is so that Housing Development, Park Home expansions can continue unabated.

These new homes are sold to unsuspecting buyers, with little reference as to the likely problems in obtaining House Insurance against Flooding on New Builds, since January 2009.

All so that the expectations of a New Local Plan are fulfilled.

The Castle Point Council Strategic Flood Risk Assessment, undertaken by Scot Wilson to comply with the demands of the failed Core Strategy in 2010, identified Canvey Island being “At Risk” from Flooding!

Consequently a Reason had to be “invented” so as to permit all, from Small to Large site Housing Development on Canvey. CPBC’s officers, at the behest of certain councillors, cosied up to the Environment Agency and the Strategic Flood Risk assessment was Distorted to permit continued over development!

Since then no developments are Rejected in principle by cpbc on Flood Risk grounds. CPBC claim that for development to serve, and the continued growth of Canvey Island, the development MUST be ON Canvey Island. As though Castle Point is a massive Borough divided by language barriers and with miles of sea between us and the mainland!

The draft National Planning Policy Framework (NPPF) has recently been consulted upon. We, the Canvey Green Belt Campaign Group, have monitored the submissions, especially where Flood Risk is concerned.

We found that the group known as the National Flood Forum have submitted comments that identified issues most relevant to Canvey Island.

And that if our local authority “Ruling Party” and our new leader, are unwilling to truly represent Canvey Island Residents, at least the National Flood Forum have quite capably stated OUR Position

We make no apologies for this being a long read, but we ask you to at the very least skim through it and allow the relevant issues trigger something in your mind, if you were affected in 1953, 2013, 2014 or have been concerned or affected by Flooding at any stage.

The NPPF Consultation has closed, however we have failed to discover a published response to the consultation from Castle Point Borough Council, perhaps one of our councillors may be able to direct us to the document, if it exists.

The National Flood Forum’s submission the draft NPPF consultation, with highlighted passages of some significance to Canvey residents, reads:

The National Flood Forum is a national charity dedicated to supporting and representing communities and individuals at risk of flooding. We do this by:
1. Supporting people to prepare for flooding
2. Helping people to recover their lives if they have been flooded
3. Working with government and agencies to ensure that they develop a community perspective when addressing flooding issues

As part of the flooded community, the National Flood Forum is a charity that supports communities to tackle the things that matter to them; creating hope and reducing the fear of flooding; helping people to work together to reduce flood exposure and its impacts, both physical and emotional. Over 300 flood groups are affiliated to the National Flood Forum and this response has been developed from their many comments.

The National Flood Forum regularly deals with a range of scenarios:
1. New developments that have flooded or which are likely to flood because, for example, SuDS measures are at capacity under normal weather conditions, or sites have been built on areas that are waterlogged
2. Developments which have apparently caused flooding elsewhere, or are likely to
3. Planning applications and decisions that do not make use of local knowledge of flood risk issues
4. Development planning that does not make use of local knowledge

The result is that people become extremely fearful of the future, distrustful of those in authority. This can appear as either apathy or combative behaviour.
“We had a housing estate built up in Eyam and they concreted over a large natural drainage point. And that’s in the Peak Park which is supposedly highly regulated. It’s a shambles. If you have a lot of money you can do what you want.”

Caterham Flood Action Group are also angry:
Hey “To briefly explain, our community has been blighted by surface water flooding for over twenty years, development has continued, responsibilities have been fractured, affecting maintenance (tantamount to neglect) of the delicate drainage infrastructure leaving residents in fear of precipitation.

On the 7th June 2016, after campaigning and complaining for almost two decades, the great storm wreaked havoc, destroying homes, devastating families, trapping our vulnerable and elderly neighbours for hours without power, as rivers of raw sewage flowed into our homes, through the streets of Surrey across the administrative border into a London Borough (contrary to the draft London plan, Policy Si12 B, which states ‘Boroughs should co-operate and jointly address cross-boundary flood risk issues including with authorities outside London’).

The CFAG must question if measures really are in place to guarantee that councils on the edge of the London Basin are considering the quality and capacity of the infrastructure ‘downstream’.

Paragraphs 154 – 163 of the Draft NPPF are an improvement on previous versions. But Caterham Flood Action Group, and others, do not believe that the Draft NPPF addresses their concerns that people will be put at risk of flooding.

In particular, policies and guidelines need to be much more ambitious if we are to create places that people will want to live in, that are adaptive to the future (such as being able to absorb more development) and where people feel safe.

Policies need to be translated in to action and many of the concerns from Flood Action Groups are that even the existing policies are being ridden over roughshod, with no recourse for affected communities.

The National Flood Forum strongly refutes the notion that flood risk can be outweighed by the economic benefits to the community and does not reflect the absolute misery flooding problems can cause to those involved.

The current wording in the draft NPPF virtually establishes that flooding is acceptable and provides opportunities for those who wish to find loopholes to do so. If development impacts even on a handful of households/properties, then it’s not a benefit to the community. For example, words such as “safe” in paragraph 154 are ambiguous. Whilst no one can ever be without flood risk, the wording here and in wider guidance needs to reflect community perspectives on safety, risk and what it means to feel resilient.

Data from the Association of British Insurers shows that 50% of insurance claims for properties flooded during the winter of 2015/16 were from areas that had not been identified by the public or private sectors as being at risk of flooding. In previous years the figure was sometimes higher (80% in 2007) and never lower, indicating that our understanding of flood risk and the flood risk maps available only cover a proportion of the risk. Surface water, groundwater and combined risks in particular are poorly understood.

For these two reasons greater stress should be placed in the NPPF on the rigour that is required to assess flood risk through all forms of Food Risk Assessments.

The biggest complaint from Flood Action Groups across England is that people’s local knowledge about their area is ignored, resulting in poor decisions about their future. People frequently have knowledge about their local area that professionals do not; details about previous flooding incidents, underground drainage, old drainage systems, etc. Modellers will frequently say that their modelling work simply produces useful tools and does not represent the real world exactly.

It will often lack local information to put in to the model and the parameters through which the model works will have limitations on the accuracy of what results. However, in the planning system models are often regarded as the absolute truth in the decision-making process and other evidence ignored. Communities regularly complain that this is the case. This can include information about local drainage patterns and historic flooding incidents through to the routes of major flow channels, groundwater levels and sea level rise. Therefore, development plans and planning applications should demonstrate how they have listened to local voices and how those views have been taken in to account in developing proposals. In particular they should demonstrate how triangulation has occurred between modelling, local knowledge and other forms of evidence to arrive at the most reasonable answers.

Paragraph 156) demonstrates an improved level of ambition, but not significant enough if we are to tackle flood risk seriously. The example from Shipston in Warwickshre below illustrates the point:
“The NPPF requires new developments to achieve ‘flood neutrality’ as a minimum i.e. that water run off post development should be no worse than the pre-developed site.
We work with our Town Council and the developers in negotiating better than flood neutrality at or before the planning stage and have had some success in getting their drainage strategies to achieve betterment – in most cases within the range of 25/40%.
With modern SUDS systems, their creative application and a willingness to meet improved objectives this is perfectly achievable at relatively low, if any, ‘on cost’ and of course the whole concept of betterment is essential with the increasing pressures brought about by adverse climate change trends and as a community support programme by developers.

We are concerned that the present policy is simply not ambitious enough and consider that a policy of betterment should replace the current ’neutrality’ policy.
Further, whatever the policy, specific local ground and geological conditions should be taken account of when determining the adequacy of drainage strategies by the LPA’s.
In our area Warwickshire clay is the predominant soil type and is almost completely impermeable so a literal ‘greenfield’ site in this area will already have a pre-existing high level of surface water runoff.

Further, should such ‘greenfield’ site have been used for grazing it will be highly compacted making the situation even worse.
Even further, should the site be sloping down to other developed areas great care needs to be taken to design a drainage strategy that absolutely reduces run off compared with the pre-existing situation.

Finally, the requirement that developments of less than 10 dwellings do not need LLFA oversight in giving guidance to the LPA (if different) should be reduced as it seems clear that developments of 9 or less are deliberately introduced perhaps to circumvent properly qualified scrutiny.
At present, it appears that the LPA’s simply have to check that a drainage strategy meets the NPPF guidelines which, in the circumstances described above, would likely be completely inadequate.

Once new developments are built to inadequate drainage standards in their specific local context there is no going back so this consultation is a once off opportunity to address the issue and build better resilience for the future into such developments.”

Para 158 a) contains an assertion that where there is no other option it is acceptable for a development to take precedence over people’s lives, however traumatic the outcomes might be. This is simply not acceptable and should be deleted. Developments that put people or their neighbours at a significant risk of them being flooded should not be built, whatever the pressure for new housing. Areas in Flood Zone 3, where there is significant groundwater (such as permanently within 150 cm of the surface) or significant drainage limitations should not be built on.

Where there are wider societal benefits identified, the risks of any new development should be transparent, so that businesses, infrastructure providers can make judgements about the level of risk that they are prepared to accept.

Para 160 – footnote 41. The site-specific flood risk assessment should triangulate modelling, local knowledge and other evidence. The assessment should proactively seek out local knowledge and demonstrate how this is used to develop an overall assessment. Guidance should be updated.

A common failing of current developments is that drainage plans are developed after the site layout has been determined. Retrofitting a drainage plan to a site can be difficult and lead to inferior results. Drainage plans should be submitted for all outline planning applications and should detail measures to manage water during the construction phase. The example from Charlton Flood Action Group, Worcestershire below illustrates the point.

“The Plan [South Worcestershire Development Plan] does not make any reference to the Environment Agency designated “Rapid Response Catchments” of which the Merry Brook is a very High risk one.
To minimise future flood risk in these particular vulnerable catchments we believe the plan should make reference to these Catchments and further that when any development/planning application is being agreed in these catchments that the conditions of planning should require that:
• Any flood prevention schemes should be put in place prior to the development of houses and other infrastructure being commenced. (During the last few years the development of the housing estate at Hampton, Evesham was commenced with top soil being stripped off the land. Those living in Charlton noticed that the water levels in the Merry brook increased far more quickly due to water running draining off the site. It was only when we started complaining that thought was given to installing the retention ponds and there was then a further delay until weather conditions were suitable).
• That in these catchment areas the water run off levels should be half the normal levels allowed. This should be achieved either by reducing water run-off levels or where this is not possible by the developers installing recommended schemes suggested by the Environment Agency – such as ponding on water courses.
• That all suggestions recommended by the Environment Agency should be installed. (At the Hampton development the Environment Agency had suggested that some ponding take place on the Merry Brook to help reduce water flows. This suggestion was totally ignored).
• That on small / single developments where planning consent is being sought that water run-off be considered and reduced to a minimum. Should there be a small water course running through the site then ponding/other means to reduce the flow should be installed.
• That any work on Highways in Rapid response catchment areas should also involve the installation of measures to reduce the flow of water into water courses.”

161 a) It is difficult to imagine situations where “overriding interest” applies. This clause should be removed, otherwise it will be used to push through inappropriate developments. The overriding concern must be for the wellbeing of people.

161 e) There is some confusion amongst Risk Management Authorities as to which organisation should comment on this aspect of planning applications. This needs clarification
Note 42 does not adequately cover the risks posed by surface water, ground water and combined sources. With at least 50% of flooding incidents involving surface water, this aspect needs particular attention to ensure that people are kept safe, whereas the focus of attention in the guidance is on fluvial flooding because that is where the better evidence base is. Surface and groundwater risks are often highly localised, but the trauma that is caused can be significant because often there is no scheme available that meets benefit cost criteria for investment. Rapid response catchments pose a particular risk. The result is that people continue to suffer without the prospect of ever escaping from the threat. In addition, the National Flood Forum’s experience is that people are increasingly finding it difficult to sell their home, restricting their ability to change employment, move closer to family, etc. Therefore Note 42 should explicitly refer to areas of high surface water and ground water risk, combined sources of flooding and rapid response catchments. The quote from the Food Action Group in South Woodford Ferrer, Essex, illustrates the point:
“We are currently doing our best as a voluntary group to try to alleviate a recurring fluvial/sewage flood in our local area. We are now in 2018 and still do not appear to be able to assist the residents of our town to have a better quality of life. Funding issues and OFWAT regulations leave local residents baffled as to what they can do to resolve this horrendous flood and sewage discharge situation. These flooding events appear to be occurring every 2 years (2012-2014-2016) ….surely this can’t be right? We do understand that funding is a problem but by working together we should be able to come up with a solution for these poor people living with the prospect of a significant flood every time there is a heavy rain fall.”

An area may be in Flood Risk zone 1 but at very high risk from surface water. However, reference to Flood Zone 1 will frequently allow developers to push through schemes in very high surface water risk. The point is well made by Caterham Flood Action Group:
“The Draft NPPF supports small sites being identified, essentially promoting ‘garden grabbing’, to reiterate we’re aware of the need for homes BUT in a surface water flood risk areas, we can confirm this has had devastating results over the decades, hence the need for SuDs in ALL development and retrofitting (refer to 1.2). YET 71) resists ‘inappropriate development in residential gardens, where development would cause harm’… But as we’re technically in a ‘flood zone 1’, on paper there’s NO risk, therefore development is be permitted (refer to 3.3), hence the desperate need to ensure policy guidance is ‘joined up’”

163 Minimal operational standards for Sustainable Urban Drainage systems should go beyond normal and projected normal rainfall events, with or without taking account of climate change projections. Whilst systems are unlikely to cater for every eventuality, they should be designed to cater for abnormal events, occasions where soil moisture levels are full and a series of events over a short period of time.
In some areas SuDS schemes will be inappropriate due to high water tables or permanently waterlogged soils. It may be possible to pump dry sites, but this has carbon emission issues and pumps failure does happen. In these cases, it is especially important to have a full and detailed drainage plan.
Developments currently have a right to connect to sewerage and drainage infrastructure. The National Flood Forum experience is that this may place other people at higher risk of flooding and we deal with people whose homes may not have flooded for 40-50 years, but who suddenly find that they flood every couple of years or more frequently with sewage once a development takes place. Sewerage and drainage undertakings must have the ability to refuse to connect to new developments where appropriate infrastructure is not currently in place.

Many of the issues and concerns that people in communities have relate to the skillsets and resources in drainage and flood risk management in local authorities, particularly planning authorities. These are hugely variable. It is important that Lead Local Flood Authority and Planning authorities have a qualified flood risk managers and drainage engineers to support the planning development and control process. In many cases the lack of the skills to critically examine proposals and applications has led to a failure to spot problems or allowed poor design. Whilst not a consideration for the NPPF, it is a major component of the many failures to see it applied appropriately.

Enforcement is a concern for many communities. Where there is unauthorised development or where there are planning conditions, it is a common experience that these are not enforced effectively, leading to increased flood risk for occupants and/or neighbours. The quote below from a flood group in Essex illustrates the problem:
“As regards, unauthorised development, the local authority (XXX District Council) does not seem to have adequate staff to deal with this by planning enforcement.”
Communities have sometimes worked with developers to bring forward better designs, using their local knowledge. The willingness of developers to engage meaningfully with communities has been very variable, with markedly different approaches even within the same settlement. There should be an expectation in the NPPF for developers to work with communities meaningfully to develop better designs delivering multiple benefits, rather than just running a consultation.

Oh the Irony! Councillors Propose a Referendum!

Canvey Islanders feel they are Not Listened to!

Hence they held a Referendum to Protect what is left of the Island’s Green Belt, then a Petition was completed objecting to large scale development.

All to No Avail.

Both Referendum and Petition were Ignored by castle point borough council!

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Now we learn that it is the intention of Rochford councillors to carry out a Referendum over the district’s Local Plan.

Councillor John Mason, leader of the Green and Rochford District Residents Group said that during the early stages of the new housing plan, residents have complained “they feel that they will not be listened to” about their council and councillors.

No doubt Rochford council will spot the opportunity of the “Tick Box” exercise, as have castle point council, in suggesting this fills the community involvement requisite!

You may well remember that the Canvey Green Belt Campaign supporters went out in 16 groups of 2, over a two week period seeking the views of residents about cpbc plans to develop Canvey Island Green Belt.

Over 6,500 votes were cast and under MP Rebecca Harris, cllrs Ray Howard and Dave Blackwell’s observation an objection via 99.13% of voters was recorded!

Typically the daft Local Plan 2014 ignored these views!

Following this a Petition was raised by a group of 6 Canvey Ladies and a total of 12,000 names were added to their Petition list. The Petition was against large scale development on Canvey, whilst the opportunity to protect the local builders could remain.

The Petition has also had No Impact with those controlling cpbc!

This despite the constraints that would normally be applied to development in areas such as Canvey!

Whilst Rochford does not have constraining issues, such as 2 Hazardous Industrial sites, being in a Flood Risk Zone 3 area, having the access issues that Canvey is restricted by nor the whole of the town being a Critical Drainage Area, we do wish the Rochford councillors success in their Referendum.

Far greater success and acknowledgement than Canvey Island residents received by the controlling group of our local authority!

The Echo article on the Rochford Referendum news is available via this LINK HERE.

Canvey residents add to cause of their own Flooding! Scrutiny committee warn of Chip Fat ahead of final report.

Almost as one final insult to residents who had suffered during the major flooding of July 2014, the Castle Point Council flood scrutiny committee identified one further cause of the flooding,  Canvey Island residents themselves!

It appears that members consider residents pour too much cooking oil into the drainage system, thus adding to the reasons why so many houses were flooded during the heavy rainfall!

cooking-oil-power-660-jpg

Previously residents had heard the Essex Highways representative admit the gulley cleaning scheduling had fallen short of the necessary standards, that Anglian Water had found damage to the drainage pipework had been caused by developers and utility companies. The Environment Agency had found their pumps had failed for short spells due to design flaws and that dykes were in need of more regular maintenance and that some areas of dykes / watercourses had been filled in, adding to the restricted flow of surface water to the pumps.

Last evening’s Flood Scrutiny meeting was felt necessary as the Lead Flood Authority, Essex County Council, the Government Office for Science (GOfS), and DEFRA had each, in their Reports, identified serious shortcomings directly attributable to the local authority, Castle Point Borough Council.

The Canvey Green Belt Campaign group had assembled these identified shortcomings and suggested to the Scrutiny Committee that residents should hear the local authority’s response to them.

The Castle Point Council officer assigned to respond to the individual Peer criticisms denied any flaws in either current or historical policy and decision making.

yesminister

In the light of the level of criticisms of Castle Point Council, contained in both the Essex Lead Flood Authority, the GOfS and DEFRA Reports, and the officer’s refuting of all, the only explanation appears that the blame rests with local decision makers themselves, our local councillors!

There can be no denying that the flooding suffered by residents caused serious damage to property,  major inconvenience and distressing fears that the level of flooding may happen again once the immediate maintenance schedules revert back to normal.

This should have been an opportunity for committee members to have questioned the officer on the policy and implications of continuing to develop housing  in a Critical Drainage Area and Flood Zone 3A whilst new builds will not be covered by the Insurance industry and Government’s Flood Re scheme. This may well leave home owners with difficulty in obtaining House insurance against flooding.

During the New Local Plan Task and Finish group meetings this same officer plus, Brandon Lewis the housing Minister, ex head of the planning Inspectorate Lord Pitt and the Planning Inspector invited by our MP to address a councillors training session, Keith Holland have made clear that Flood Risk is a Policy Constraint on Housing.  There appears a relutance to apply this constraint.

Whilst the meeting was not publicised as well as the previous scrutiny meetings, no Press were in attendance and just 17 Residents were in the public gallery. Whilst no organisation enjoys criticism, the level of flood damage and distress deserved being openly and transparently, publically addressed.

The officer made clear that the currently and previously employed, civil servants had worked within Planning Policy and Guidance in their recommendations.

So we are left with a dilemna of whether the Government Office for Science, the lead Flood Authority Essex County Council and the Environment Agency were wrong to criticise Castle Point Council, whether these were not actual criticisms, whether councillors rather than officers were being criticised, or indeed these comments were not in fact actual criticisms!

The points “suggested” that CPBC may like to address during the scrutiny meeting are reproduced below. The speech marks identify some areas of concern of our local authority made by either the Lead Flood Authority Essex County Council, the Government Office for Science, the Environment Agency or DEFRA:

1. Drainage
Reliance on Inadequate Capacity of the Drainage System.

“Canvey Island is an area that has historical susceptibility to flooding and following the severe 1953 coastal surge, has considerable sea wall defences. As a very low lying area, over thick layers of clay surrounded by sea defence walls the importance of the drainage and associated systems is fundamental to managing the rainfall that the area receives.”
“The flat topography of the Island, combined with the densely developed urban areas and covering of open watercourses has created an exceptional reliance on the designed drainage system. In addition, a large amount of Canvey’s drainage system was designed prior to the introduction of national design standards and is therefore likely to be of lesser capacity than new infrastructure.”

2. Over-Development
Level of Past and Proposed future Development.

“Older drainage systems may have been sufficient at the time of construction, but increased development and subsequent pressure on the already strained drainage system has meant that in some locations the capacity is not sufficient to provide effective drainage and mitigate flood risk. As a result of this, some areas of the Island have suffered from a history of surface water flooding in more moderate events than those of 20th July 2014”
“Due to its location, topography and urban design, Canvey Island as a whole exhibits a significant level of underlying flood risk, with large areas of the island particularly vulnerable to flooding.”
“Poor historical recognition of flood risk in the planning process and increases in areas of impermeable surfaces have led to further difficulties in draining a very low lying area which has historically been very susceptible to all sources of flooding.”

3. Building Control
Lack of enforcement of Planning Conditions

“It is also possible that drainage systems have been misconnected, or not built or maintained as proposed, which are causing local issues. Compliance with planning conditions and enforcement is a matter for Local Councils rather than ourselves.”

4. Surface Water Management Plan
Flawed and irrelevant document.

“We (EA) do consider the outputs of the South Essex Surface Water Management Plan, produced by Essex County Council as the LLFA and within which Canvey Island falls, when commenting upon the adequacy of surface water management proposals.”
“The (Surface Water Management Plan) methodology is applicable for those areas of south Essex where there are significant variations in the land level to generate surface water flow paths during rain fall events, but therefore is not applicable to the flat topography and subsequent reliance upon piped infrastructure and pumping stations found on Canvey Island. As a result it does not provide an accurate reflection of known surface water flood risk on the Island,”

5. Following of Environment Agency Advice through the CPBC
Planning Process.

“We (EA) comment on the adequacy of surface water management proposals for any site greater than 1 hectare. This statutory power was set out in revisions to the General Development Procedure Order (GDPO) published on 1 October 2006. Since this date we have advised Local Councils on the adequacy of Flood Risk Assessments which includes ensuring that flood risk will not be increased as a result of the proposed development. This advice is primarily based on managing any surface water run-off leaving the site. It is however only possible to advise Castle Point Borough Council on flood risk and how it may affect a site based on the best available information at
the time. We are currently working in partnership with Anglian Water, Castle Point Borough Council and Essex County Council to model the urban drainage system on Canvey Island.
It is the responsibility for Local Councils to assess the drainage proposals for
developments less than 1 hectare. Since 1 October 2008 planning permission has been required for converting front gardens into impermeable driveways, prior to that date this could be done under permitted development rights.”

6. Sequential and Exception Test
CPBC Responsibilities

“Concerns about the Sequential Test should also be directed to Castle Point Borough Council. We (the EA) will highlight the need for Local Councils to apply this Test, and the Exception Test, in our planning responses but it is not within our remit to advise on its application as we do not have a detailed understanding of the availability, suitability and viability of alternative sites.”
“28. Further development is planned in a number of locations on Canvey Island.
This could cause increased surface run off and put further pressure on the drainage systems. It may also increase the number of properties at risk of events such as this in the future. Government planning policy requires that future development on Canvey … does not increase overall flood risk.”    “Our remit is to advise Local Councils whether Flood Risk Assessments supporting planning applications comply with flood risk policy set out in the National Planning Policy Framework (NPPF). If there is a local need to consider applications differently then this should be set out in the Local Plan for the area.”

7. Mis-Perception

“Consumer confidence in flooding infrastructure is low. A major concern for the public was the perceived ineffectiveness of the drains and pumps – not just for surface water flooding, but an underlying fear they might not work if Canvey ever suffers from a tidal surge.”

The officer suggested that flooding from surface water  and that from the sea should be addressed separately, despite the statement above having been attributed to his own Chief Executive!

8. Communications
Disconnection with Residents, leading to lack of meaningful communication of information.

“The local authority has a role as a category one responder to warn and inform their residents of risks and respond during such flood events. Castle Point Borough Council receive the same weather forecasts and advice as other category one responders”
“At least 250 from 20th July – 12th August. Potentially greater number as enquiries received through various sources (Elected Members, Officers etc.), although some repeat enquiries were possible.“

Criticism within the Report and Review documents of the July flood incident suggest that communication between the public and the Responsible Agencies has been limited or confusing.
It appeared that local residents suffering from being flooded first turned to the local authority. Castle Point Council use an outside agency, Southend Careline, to handle out of hours emergency calls. This outside agency were unable to handle the number of calls.
“16:12 Request from the Southend Careline for Sandbags to CPBC CCC. Careline was informed that CPBC does not hold stocks of emergency sandbags.”
Not only do Canvey Island residents appear unaware that Castle Point Council do not have a “sand- bag” policy, but also the appointed helpline agency were equally unaware.
There appears very limited awareness of the CPBC “Be aware, Be prepared and Be Resiliant” programme.
Castle Point Council issued a number of messages during the flood event via social media. CPBC should be in full knowledge that of their 2,054 Twitter followers, given the population distribution, just 883 are likely to be residing in Canvey Island.
Likewise the CPBC Facebook page has received just 106 “Likes.”
This indicates a lack of social media communication achieved !
The dis-engagement between the local authority and it’s residents was particularly apparent during the August 2013 and July 2014 times of crises.

 

 

Silver Jubilee proposal considered over development in a flood risk area. A moment of caution by CPBC Planning Committee?

Despite Officers “advice” and the Lead group of councillors voting pattern, Flood Risk was accepted as a reason to Refuse building proposals on Canvey last evening.

Local residents were concerned that the proposed development would be an over development of houses on the size of the ex car park site.

This new cautious approach, ahead of the Integrated Urban Drainage study results are published, is to be welcomed by neighbouring dwellers.

The officers paperwork claimed:

 “The continued development of Canvey is necessary to sustain the local community and prevent the social and economic blight of the settlement.”

The logic of this dubious statement appears to suggest it is logical to continue to develop Canvey until no further land is available and until which time the local economy will collapse. In contrast residents will have found that they were caused “social and economic blight” by the surface water flooding, much of it due to over development, during 2013 and 2014.

 “The second criterion requires that the applicant demonstrates that the development is safe, will not increase flood risk elsewhere and where possible will reduce flood risk overall.”

The Silver Jubilee proposal was accompanied by a flood response Plan which is reliant on occupiers registering with the Environment Agency’s Flood Warning Direct service.

Officers consider the Flood response Plan acceptable to occupiers if a Flood Warning is issued.

However, the Environment Agency accept that in the case of Canvey, the storm event causing flooding in July 2014 was not predictable. Neither would a breach in the sea defences be predictable. Only flooding in the event of over-topping of the sea wall could be predicted in time to release a Flood Warning!

 “The Flood Risk Assessment acknowledges the need for the use of Sustainable Urban Drainage Systems(SUDS) on the site.”

Whilst the proposal was to involve the change to houses from the current car park, thereby replacing a concreted area with some “limited” permeable garden areas.

The “improvement” in developing a car park site into houses, officers suggested, would cause less surface water flooding.

Our initial thoughts are that, car parks do not create sewage. Sewage that can cause the most damage to property in the event of a flood.

According to the Council Lead group representative for Canvey Winter Garden ward, the system of drainage that the developer may employ is to install underground storage tanks. Most residents will be aware that Canvey land is made up a high level of clay. Canvey is also at, or below sea level, alongside the clay this results in a high water table for most years.

The logic therefore of storage tanks to hold water within a water logged area appears to have little benefit or indeed, logic!

Whilst these points were raised by committee members, tellingly none of the points were either addressed or received satisfactory answers from officers!

The Council Lead group representative for Canvey Winter Garden ward also made a concerning comment that I am certain he would have preferred to have worded better when he considered that the proposal would lead to much needed housing for local people and would not lead to (the development) being “flooded with a bunch of immigrants.”

Taking the “immigrants” reference aside, these are to be market value houses, accordingly, they will be purchased by those able to meet the market price valuation. Other than affordable or social housing schemes I would presume there is no condition to enforce any of the proposed development be set aside for the local population.

The Silver Jubilee proposal was Refused, by the opposition group with the aid of the St Mary’s ward representative’s abstention.

Surface Water Flooding appeared to be somewhat reluctantly accepted as a Reason for Refusal.

Whilst seemingly a good use of a brownfield site, the small step by this committee in Refusing the proposal marks a realision that over development in a Flood Zone is not particularly good planning practice.