Tag Archives: SFRA

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.
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Canvey Island Flood Event “Cover Up”? CPBC willing to withhold information, so as to develop Canvey Island!

A recent addition to the Castle Point Borough council’s Local Plan Evidence Base is the Strategic Flood Risk Assessment 2018 Update covering South Essex.

The document, apparently is too large to be downloaded from the cpbc Local Plan website, so we downloaded from the Rochford council website instead!

Of note, and the Canvey Green Belt Campaign did make it known to councillors, Canvey Island had no Historic Flood Events, up until 2011, recorded by Castle Point council except the 1953 Tidal Flood. This despite local knowledge confirmed that there is a Surface Water Drainage issue across Canvey Island!

This information we made available whilst the cpbc cabinet discussed and adopted the Surface Water Management Plan during 2012. Little wonder then that cpbc and their partners, were totally unprepared for the Canvey Island Floods of 2013 and, worse still, 2014!

Those living on Canvey Island at the time would have been well aware of a serious Surface Water Flooding Event during 1968. Previous localised Flooding causing more regular problems had also taken place on the Island on more frequent occasions.

None of this was recorded, nor recollections sought, when cpbc gave information to URS Scott Wilson as they compiled the 2011 Surface Water Management Plan for South Essex.

Now it is evident that cpbc have allowed, one can only think for convenience sake, the South Essex Strategic Flood Risk Assessment to be published and adopted for inclusion in the cpbc 2018 Local Plan evidence base, with the same Flooding Event omitted!

The South Essex SWMP (2012) states that there are 26 recorded flood events from Castle Point Borough Council, the Essex Fire and Rescue Service, Parish Councils and the Highways Agency. The source of flooding is unknown and these records are shown in Appendix A Figure 5.3. Where available, updated flood incident records held by the project stakeholders, including Castle Point Borough Council, ECC, the Environment Agency and AWS, have been provided to support this Level 1 SFRA update.

Records of Flooding included within the document indicate:

1968 “Fluvial flooding from the Benfleet Sewer” Following this event, structural flood mitigation measures were undertaken along the watercourse to improve the standard of protection against flooding including the construction of the bunded washlands area.

Again in 1987 Flood recorded in Hadleigh

For Canvey Island, during these decades, Nothing Recorded!

So despite the Canvey Green Belt Campaign making it known to cpbc that Canvey Island had suffered Flooding incidents and that the 2011 Surface Water Management Plan incorrectly omitted a record of these events, Castle Point Borough council have allowed a new Assessment to be undertaken without correcting these errors!

Not only that, but the Canvey Island Integrated Urban Drainage Study, undertaken following Government departmental advice, was not used as an informative for the South Essex Strategic Flood Risk Assessment, despite being signed off in April 2018!

5.4.2 Canvey Island Integrated Urban Drainage Study
The Canvey Island Integrated Urban Drainage Study (IUD) has been undertaken setting out how surface water drainage should be managed and maintained on the island. The study was not available for inclusion in the Level 1 SFRA; however, the study should be used to inform the Level 2 SFRA and site specific FRAs.

We can only conclude that these omissions and flaws can only be explained by them being deliberate to support the desires of  Castle Point Borough Council to distribute a large level of Housing Development onto the Flood Risk Zone and Critical Drainage Area of Canvey Island within their latest 2018 Local Plan process!

The 1968 Canvey Island flooding was not an insignificant event as much as cpbc may wish it was. These photographs act as proof:

Sandra Davis Photo

copyright: Sandra Davis

Jacksons Photos

Copyright: Jacksons Photos

More information on the 1968 Flooding has been collected, along with many interesting photographs that can be found on the Canvey Island Community Archive. Their website can be found via this LINK.

 

 

Canvey Island Population set to grow despite, ASPIRATIONAL Sea Defence improvements and Flood Re Insurance being unavailable!

A “proposed” new development of Flats for Canvey Island that WILL receive Approval from Castle Point Council reveals 3 serious issues.

Firstly it is correct to point out that the proposed Flats are in the Canvey Island town centre, and if anywhere is to be developed here is more appropriate so as to assist the regeneration of the town centre Retail outlets, under threat from out of town local authority preferences.

The first issue is the continued increase in population in the Flood Risk Zone of Canvey Island. Castle Point councillors and officers appear to be relaxed and show little moral concern in locating more and more people into an area at some risk of both surface water and tidal flooding.

Secondly a point given no relevance by the same Castle Point members and officers is that Canvey Island, being a FLOOD Plain is reliant on its sea defences.

 

sea wall damage

Previous damage acts as reminder of the Tidal power.

 

These sea defences will need to be raised and improved prior to the year 2100, as clearly explained by the area’s Strategic Flood Risk Assessment, to prevent potential over-topping! The potential for a breach in the defences remains.

Whilst the Environment Agency, recognising Canvey Island is a “special case”, emit the music to Castle Point’s ears “have no objection to the proposals”, however in this case feel it of the most importance to make very clear to our Local Authority the uncertainty that faces Canvey Island’s sea defence!

The EA warns;

“The TE2100 Plan is an aspirational document, rather than a definitive policy, so whether the defences are raised in the future will be dependent on a cost benefit analysis and the required funding becoming available.”

“When determining the safety of the proposed development, you should take this uncertainty over the future flood defences and level of flood protection into account.

This may require consideration of whether obtaining the funds necessary to enable the defences to be raised in line with climate change is achievable.”

Thirdly, much has been said about the benefits and protection that the Flood Re insurance scheme delivers. However this scheme will NOT benefit residential properties built post January 2009!

As a director of the Flood Re scheme pointed out to the Canvey Green Belt Campaign group, the idea of the insurance scheme is NOT to encourage development in Flood Zones!

Going by previous development committee meetings you will not hear these 3 matters discussed. Officers will make a strong point of informing members that the Environment Agency “have no objection to the proposals”.

Consequently, the level of population of Canvey Island at Risk from Flooding, continues to Grow!

Castle Point Local Plan – confusing Outside Assistance with Outside Interference!

Blog Post 500!

So our councillor Letchford (according to Echo letters Oct 16th) suggests taking the Castle Point Local Plan out of politicians’ hands! He suggests the possibility of a “revenge vote” next year against Conservative councillors perceived to surrendered mainland sites to developers could give control of the council to the CIIP.” (?)

Also that the plan has taken six years to get to its current position. We suggest that many more years than six, have resources been spent during this saga.

Cllr Letchford continues “Whilst the task and finish group is made up of councillors with one eye on next year’s elections there is unlikely to be agreement on where houses should be built. This conflict of interest could result in the council having a plan imposed on it by the Government and £11 million will be lost.”

By introducing outside professionals who would take into account government requirements, the housing needs of the Borough, the local infrastructure etc a Plan would be conceived and the £11 million would accrue.

Cllr Letchford tells us that “I can live with future development based on good professional advice. What I cannot stomach is more development in one area just because councillors elsewhere were afraid of losing their seats and political power.”

Well during the process of the Core strategy much outside professional advice was commissioned, and much was ignored, including the Sustainability Appraisal and the Strategic Flood Risk Assessment.

The Sustainability Appraisal saw CPBC being questioned why no evidence was illustrated why the borough’s most sustainable development site was totally rejected.

The much delayed, embarrassingly so, Strategic Flood Risk Assessment was used in order to support development within the 3a Flood Zone.

Through the application of the Sequential Test the Flood Zone 3a should have the “more vulnerable” development directed away, onto Zones 1 and 2.

The area that the Sequential Test should be applied across should not be contentious, through a Local Plan it should be Borough-wide, especially in the case of Castle Point being such a small Borough.

The authors, Scott Wilson, of the Castle Point Flood Risk Assessment appeared to have their work under-mined on at least one occasion.

The Environment Agency wrote to Scott Wilson to request;

“Once again we would ask that reference to an agreement made between us and SOS BC (Southend on Sea Borough Council) regarding the area of application for the Sequential Test is removed. We are not aware of a formal agreement on this matter and such an agreement falls outside of our remit. However, as previously stated the LPA are entitled to reduce the area of ST (Sequential Test) application as per Paragraph 4.18 of the Practice Guide – this is their decision and something they should justify. We would not agree the detail of the Sequential Test, just ensure the correct methodology is applied.”

So, some unusual constraining of the area that the Sequential Test has been applied within the Borough by the local authority, has been clearly identified and the detail of the Sequential Test is identified the sole responsibility of CPBC.

The justification continually offered by CPBC being;

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

Some recent Canvey residents exposed to the surface water flooding and the increase in insurance charges may disagree with that sentiment!

Recent Planning Guidance gives some indication that Castle Point Council may be applying the Sequential Test in an “unusual” method;

“As some areas at lower flood risk may not be suitable for development for various reasons and therefore out of consideration, the Sequential Test should be applied to the whole local planning authority area to increase the possibilities of accommodating development which is not exposed to flood risk. More than one local planning authority may jointly review development options over a wider area where this could potentially broaden the scope for opportunities to reduce flood risk and put the most vulnerable development in lower flood risk areas.”

This Guidance clearly suggests that a Borough-wide application of the Sequential Test is expected, alternatively an even wider application would be correctly justified, as opposed to the Castle Point Council’s micro application of the Sequential Test.

Additionally;

“A local planning authority should demonstrate through evidence that it has considered a range of options in the site allocation process, using the Strategic Flood Risk Assessment to apply the Sequential Test and the Exception Test where necessary. This can be undertaken directly or, ideally, as part of the sustainability appraisal. Where other sustainability criteria outweigh flood risk issues, the decision making process should be transparent with reasoned justifications for any decision to allocate land in areas at high flood risk in the sustainability appraisal report. The Sequential Test can also be demonstrated in a free-standing document, or as part of strategic housing land or employment land availability assessments.”

You may have noted, although it has received less focus than other issues, that;

  • Flood Risk is a Constraint on housing development.
  • That the Sequential Test may be applied across more than one local planning authority.

And yet Castle Point Council select to apply the Sequential Test to a limited area, that of Canvey Island.

This despite the CPBC Sustainability Scoping Report identifying;

“Given the risk to the population(from the Risk of Flood), various measures are required to deal with the concerns to human health and wellbeing.

These include:

The need to maintain the population living in the flood risk zone at current levels or lower;”

As attractive as having the £11 million “enticement” for completing the Local Plan and the possibility of retaining positions as ward councillors, the influence on the Local Plan by influential council members may be quite considerably misplaced, and officers input maybe seriously questionable.