Tag Archives: Strategic Flood Risk Assessment

Castle Point Council face Testicular Examination Ahead! Whilst Nuneaton Council act as Local Plan Pathfinders?

Having promised to stand firm over Infrastructure before more Housing, the new Castle Point Borough Council regime will now have their resolve fully tested by the Government’s team sent into the Borough to oversee progress on the Local Plan.

Riley+marchant

Residents, having shown confidence in the Lead group of councillors by giving them an increased majority at the May 2018 local elections, will be expecting them to be able to revive the latest withdrawn Local Plan following 12 months of intensive and “tireless” Duty to Cooperate work following the Examination inspector’s criticisms.

The protection of Green Belt was paramount to Residents concerns, and any backing away from the local authorities position will be open to criticism!

This may be particularly so in the light of promises to overturn the Borough Plan made in another area, Nuneaton, where the successful Conservative group promised to:

“Protect existing communities and deliver the roads, health and school services we need.
 Reduce the housing numbers based on new government guideline figures.
 Withdraw from Labour’s secret agreement to take Coventry’s overspill.” 

“Distribute housing more fairly around the Borough to enhance not destroy existing communities.”
 “Ensure our communities finally receive the much needed road improvements, schools, GPs, shops and essential facilities they deserve, 
 Prioritise Brownfield sites first, protecting our existing communities by removing unsuitable and unsustainable sites from Labour’s broken Borough plan.”

Andrew Lainton, of Decisions Decisions, Decisions blog suggests:

“However the Borough Plan is mid examination with initial findings due to be published this month.

As the inspectors findings are binding the only alternative to fulfill the manifesto would be to withdraw the local plan.

This would put the Council in special measures.” 

The Nuneaton Tory Group’s reference to Unsuitable and Unsustainable sites is interesting and should, but doubtfully will, provoke examination at Castle Point.

The wholesale blanket application of the Sequential Test across Canvey Island would, elsewhere, be expected to be deemed Unsustainable.

In effect despite being a flood Zone 3a, any Housing Development proposed for Canvey Island is deemed appropriate!

This is evidenced in each and every Application paperwork by officers, following councillors instruction, having “persuaded” the Environment Agency that Canvey Island is a Special Case!

An illustration of this, taken from the cpbc Annual Monitoring Report 2016-17 states; “It should be noted that there is no specific policy on flood risk included within the Local Plan (1998 adopted version) and therefore the Council relies on national policy set out in the National Planning Policy Framework and its technical guidance in respect of such matters.

Of course since then the Strategic Flood Risk Assessment has recognised that Canvey Island is at Actual Risk of Tidal Flooding and the Integrated Urban Drainage Study was researched and published following the 2014 Summer Flooding of Canvey Island!

Castle Point councillors, those involved on the development committee at least, appear willing to accept responsibility for future Flooding of housing and danger to residents, whether from Surface Water or Tidal.

So far that has paid handsomely. Over time and following Flood events, that may prove less so, as Housing built since the 1st January 2009 is not eligible for the Flood Re Insurance Protection that makes available affordable insurance.

Should this problem emerge mortgages on “new” builds may well be denied due to insurance issues. New Canvey Island House Buyers may well be walking into this trap unaware.

The development of Canvey Island both Industrial and Housing continues unabated, this will intensify the pressures on the already broken drainage system, and road and health service infrastructures.

The cpbc Annual Monitoring Report also states, “the proportion of new homes provided on previously developed land to remain lower than in earlier years.”

and that, even more worryingly; 

“16 affordable housing units were delivered in Castle Point in 2016/17, representing 14% of total housing provision (114 dwellings). This level of provision is an improvement on the annual average provision for the period 2001 to 2016 of 11.5%,”

An example of the inadequacy of our local authority is illustrated within the cpbc Sequential test documentation to support the first of the local plans, the Core Strategy, in which it was admitted “The Environment Agency met with the Council in 2007 to identify criteria under which they would allow development to proceed on Canvey Island. The final criterion was the need to ensure that the Emergency Planners and Emergency Services were satisfied with the measures in place to ensure safety in the event of a flood.

These services had not been consulted in the preparation of PPS25, and as such this requirement was a surprise to them, for which they were not prepared.

A typical approach by developers to overcome the Constraint on Housing by Flood Risk on Canvey Island and acceptable to CPBC is demonstrated here;

  • “The application site is located on Canvey Island, which is situated entirely within Flood Risk Zone 3a,
  • The Council has undertaken an annual review of Strategic Housing Land Availability (SHLAA) since 2011. This process has consistently indicated the need for a greater supply of housing land to meet the objectively assessed housing needs of the borough.
  • When applying a sequential test it is important to have regard to the local context. Canvey Island is a distinctive community, accommodating 43% of the borough’s population. It has specific identified needs in terms of social, economic and physical regeneration, as well as housing.
  • In order for residential development to serve the community of Canvey Island it is considered that it needs to be located within that settlement.”

The Level of delivery of Affordable Housing and the continued influx of new Residents from outside of the Area onto Canvey Island suggest that “residential development to serve the community of Canvey Island” is simply too broad a sweeping statement intended to be a means of simply granting Planning Permission to bolster the BOROUGH’s Housing Supply in an Unsuitable Location!

It would appear unusual, if not unreasonable, for a local authority to seek to increase the Urban Density by developing Green field land and intensifying Brownfield development,  supposedly under the guise of satisfying the Need of the Canvey Island Community, when in effect it simply intensifies Inward Migration, in an area specifically under the threat of both Tidal and Surface Water Flood Risk!

We eagerly look forward to learn what Resolve, Metal, Determination and hopefully Fairness, the new administration at Castle Point council are able to apply to the ongoing Local Plan process in the shadow of Government Intervention!

local plan.jpg-pwrt3

Like a bad Smell, this just will not Go Away!

The full Decisions Decisions, Decisions post may be read HERE.

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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!

Flooded Canvey Resident? Apathetic or Concerned about Flooding – Flood and Coast Conference

Much has been recorded, not least by ourselves,  regarding Flooding and Canvey Island, so much so that both could be considered synonymous.

References include, our sea defences being the best in the UK, the Surface Water Flooding during 2013 and 2014, “achieving effective drainage is a complicated task”, The flawed Surface Water Management Plan that indicated NO previous recorded flooding incidents on Canvey Island, that residents were allowed to believe that the Island’s drainage pumping system was capable to cope with flooding from Tidal sources, a Strategic Flood Risk Assessment that appeared so onerous that it was quickly removed from the public domain for fear of jeopardising the doomed complete Core Strategy process during 2011, and so on!

canvey flood bid 1.jpg-pwrt3

Little enough Central Government monies are available to improve the situation.

Our position is that, it is wholly unreasonable to increase the size of the population at Risk of Flooding, especially as evidence is clear that it is unlikely ever to be able to guarantee peoples safety. Whilst this is the case, no level of development should be allowed that would increase numbers of people and homes at Risk of Flooding.

Growth for Growth’s sake will only put more strain on the drainage system, as will the accompanying Hard Surface Areas.

In this light, there is a “Flood and Coast” conference in March and Phiala Mehring is participating and asks for your assistance.

She is gathering information about flood risk management to use in her presentation that will also be used in her PhD thesis.

The link following will take you to her simple to follow Questionnaire. If you feel you would like to help and include your Canvey Island flooding experiences or knowledge, please click on this LINK.

Phialia describes her position as an; Advocate of Integrated Flood Risk Management, working with communities.

 

Build on Green Belt, Sequentially you wouldn’t do it – Unless you are in Castle Point of course!

Housing and the supply of, in Castle Point is an ongoing contentious issue, the new Local Plan seeks to address this. Factors influencing the issue range from the objectively assessed need for housing, governed by demographic assessments, the factor that Castle Point is tightly constrained by Green Belt, the road and health service infrastructure and to a lesser degree the flood risk and hazardous industrial sites of Canvey Island. Some point to the historic levels of housing delivery as being a relevant factor, which may have some bearing as County have allocated no money for highway improvements specifically to support housing growth in the Borough.

In support of the Plan the local authority have published a document titled “New Local Plan Sequential and Exception tests for Housing Site Options” dated November 2013.

“This document sets out the sequential and exception tests for those sites that have been promoted to the Council for inclusion in the New Local Plan as housing sites. The National Planning Policy Framework (NPPF) requires local planning authorities to take account of the risk of flooding when preparing their local plans. The NPPF sets out a sequential, risk based approach to the location of development to avoid where possible flood risk to people and property, and to mange any residual risk. It is expected that the impacts of climate change are taken into account when considering flood risk, as properties built now are expected to last at least 100 years.”

“In order to direct development, where possible, away from areas at highest risk of flooding, the NPPF requires local planning authorities to carry out a ‘sequential test’ when preparing their local plans.”

The relevance of this process in relation to Canvey Island is four fold.

July 2014photo3

The Strategic Flood Risk Assessment indicates that Canvey is recognised as being at Actual Risk of Flooding from both over topping of the sea defence and from the residual risk in the event of the defence being breached.

The Environment Agency have highlighted the highly complex nature of the Island’s drainage system. This was the major aspect emerging from the investigations by Essex county Council and the Government Office of Science following the surface water flooding during 2013 and 2014. We still await the findings of the Castle Point Scrutiny Committee.

Lastly the local authority have, in response to criticism of inadequacies from the Planning Inspectorate, identified vast areas of land they consider either deliverable or developable during the Plan period outside of the Flood Zone.

Castle Point Council have identified land that could provide in the region of 3,400 dwellings discounting the long debated Town Centre Regeneration areas potentially provision of up to 300 dwellings.

This also discounts the potential provision of 1,000+ dwellings at the H18 site known as the Blinking Owl or North Thundersley extension.

The CPBC New Local Plan Sequential and Exception Tests document also identifies the approved proposal to develop 606 dwellings at Thorney Bay with a potential of a further 106 dwellings. There is also 99 dwellings proposed at The Point on Canvey.

These large Canvey sites are in addition to what is intended for the Dutch Village fields, East of Canvey Road, the old Castle View School site and the Industrial proposal off of Roscommon Way!

With this in mind it would take some explaining as to why the Green Belt sites on Canvey Island are so consistently promoted as being necessary to develop for either Housing or Industrial use within the local Plan!

The single factor that the local authority attempt to use to support this policy of development growth distribution is through the Exception Test’s element:

“Firstly, they must demonstrate that the development would provide wider sustainability benefits to the community that outweigh flood risk.”

Given the blight inflicted on residents following the surface water flooding of 2013 and 2014 and the potential of flooding from the sea, Canvey is now in a period of economic uncertainty. Uncertainty that insurance will be available to new houses built since 2009, this in turn may reflect upon the ability to secure mortgages and uncertainty what the Integrated Urban Drainage study may discover.

Canvey Town Centre regeneration and a huge amount of investment into the drainage system, in support of the current levels of residency, must be sought prior to looking beyond the urban area to release sites.

In their considerations, the Local Plan Task and Finish group should remember that, Green Belt is Green Belt, wherever it is situated, and that the Council seek to “maintain or reduce the number of residents living at Risk of Flooding.”

With the identification and promotion of the Blinking Owl site, dependent on local residents’ reaction, and the ability to provide the necessary infrastructure, it must be made clear whether this site is in addition to the sites already identified, or instead of.

The attempts being made by the local authority councillors to protect the Borough’s Green Belt is admirable however, they must take care in the relegation of some areas as being of less value ie contains some development, as these same areas may provide more of the function of the Green Belt purpose!

I would suggest that sites providing access to the public provide more value and are entitled to equal protection and consideration.

BwwfFACIYAAwIF3

Either way the continued inclusion of the Canvey Green Belt sites for Housing and Industrial use is very poorly evidenced and accordingly indicates that “Local Factors” remain as the influence behind the local authority’s judgement!

“Don’t mention the Floods!” New Castle Point Flood Risk Management Plan consultation debated.

Castle Point Cabinet “debated” the new Environment Agency (EA) Draft Flood Risk Management Plan that is out for consultation. A subject having great concern in the recent few years locally, not least for Canvey Island.

During the previous two years, storms have highlighted how the Canvey Island drainage system has been found wanting through ill-prepardness, lack of maintenance and basically of limited capability, in light of the topography of the area.

View of Canvey Island flooding from Police Helicopter July 2014

View of Canvey Island flooding from Police Helicopter July 2014

The two existing flood Plans, the Surface Water Management Plan (SWMP) and the Strategic Flood Risk Assessment SFRA) are open to criticism.

Firstly, the SFRA delivered some months late, in fact causing the suspension of the Examination in Public of the Core Strategy!

This delay appeared to be caused by CPBC,  realising the foreboding manner of presentation of the draft documents contents, meeting with the EA so as to finalise a less sensational and public concerning document with it’s producers Scott Wilson.

This was made more evident by the empty chair, vacated by Scott Wilson’s representative, at the Core Strategy Examination on the day that Flood Risk in the Borough was debated!

The fact that CPBC published a local Plan, with the housing growth distribution agreed (on Canvey Green Belt), ahead of  evidence from the Flood Risk Assessment was indication itself that “Local Factors” was influencing decision making!

The continuing reassurance that our sea defence is the finest in the UK is all well and good, however it is not the finest in Europe, by some measure. It is the best that could be afforded at the time. God forbid it is not tested in the same way that the drainage system was during the August and July floods. Ongoing work is required in the medium term to maintain the standard of its defence.

Residents should not be under the assumption that the drainage pumps will cope with flooding should the sea defence be breached.

The SWMP, gleefully adopted by the CPBC as it misleadingly indicated the mainland was at a higher risk of flooding compared with Canvey Island, is another document with serious issues.

Unfortunately the desk work failed to prepare us for the practical effects from flooding felt by residents of Canvey Island during 2013 and 2014.

There are serious faults in this SWMP that the Canvey Green Belt Campaign group have documented and challenged the Environment Agency over.

Input of historical events by CPBC officers have been a hindrance, and the checking of detail found wanting.

Further probing by us has led to the document’s whole relevance being doubted. A fact endorsed by the EA.

The apparent esteem in which Scott Wilson is held in by CPBC cabinet is correct, except where local interference of their documents effectively dilutes the messages contained within them.

The trivialising of debate by certain cabinet members was illustrated by the patronising response by one member, who defended an officer under question, with the comment: “we have professional officers who are professional!”

Don't mention the war, Pike!

Don’t mention the war, Pike!

Locally the positive shift of responsibility for flood risk onto one lead authority,Essex County, appears to be an opportunity to direct blame for previous misdemeanours, inappropriate levels of housing growth, lack of an emergency evacuation plan etc, onto the newly appointed responsible agency.

The value of green open space, the dykes, ditches and rivers in the drainage of Canvey must be realised and their status maintained.

Castle Point housing development, Flood Risk, Climate Change and site selection.

Whilst Canvey Island is benefited by “the best sea defence in the UK,” nature moves on. The Committee on Climate Change has issued a further warning against complacency over sea level rise and protection against the effects.

Whether climate change is something that can be controlled by human adjustments is irrelevant. The facts are sea levels are rising.

Locally Castle Point Council were required to produce a Strategic Flood Risk Assessment (SFRA)  in support of the rejected Core Strategy.

This document researched by experts Scott Wilson, and despite revision by Castle Point Borough Council (CPBC), with the Env Agency’s consent, illustrates clear concerns.

The fact that more recent flooding is now demanding vast sums from us, via the Government, to be spent across the UK in mitigation measures, will inevitably result in any required long term improvements to Canvey sea defences being delayed.

The Castle Point Flood Risk Assessment gives clear advice that future planned development for Canvey Island should be regarded with caution.

Extracts include:

“The results from the increased scope Level 2 SFRA have confirmed that the southern part of Castle Point, namely Canvey Island and the Hadleigh Marshes area are at significant risk of tidal flooding.”

“In the light of this, it is recommended that a survey of the flood defence crest heights around Canvey Island is undertaken in order to refine the assessment of defences that are overtopped and areas that are at real risk of flooding.”

“For an SFRA to serve as a practical planning tool now and in the future, it will be necessary to undertake a periodic update and maintenance exercise. This section clarifies what specific actions are recommended to ensure correct maintenance and updating of the SFRA.”

“Frequency of Updates: It is recommended that the SFRA is maintained on an annual basis. Should any changes be necessary, the SFRA should be updated and re-issued.”

Four years have passed and as far as we are aware the recommended updates have not been undertaken. The survey of the flood defence crest heights, likewise requires undertaking.*

Whether this illustrates CPBC giving flood risk the priority it deserves may be open to debate.

In the light of the Castle Point Local Plan, shortly expected to receive some revision, and the Borough’s housing distribution requiring the consideration of local constraints, it appears timely to suggest our councillors re-read the 2010 Flood Risk Assessment and bear in mind the most recent climate change considerations. This prior to them selecting what should be the most sustainable and appropriate sites for housing development.

In the report by Roger Harrabin, below, an interesting link is included to a report following the Pitt Review on Floods. Click on it and consider whether our local authority have issued residents with the best advice available, or indeed adequate advice at all!

R.Harrabin, BBC Environment Analyst writes:

“England is still not doing enough to tackle the risks from climate change, government advisers say.

The Committee on Climate Change (CCC) says three-quarters of existing flood defences are inadequately maintained because of a cash shortage.

Rules to avoid floods affecting new developments have also been delayed.

The government says it has offered an extra £270m to repair storm-damaged defences and is committed to adapting infrastructure to extreme weather.

But the CCC says that at current rates of investment in flood defences, flood risks for people in England will increase.

The chair of its adaptation sub-committee, Lord Krebs, told BBC News: “The £270m announced by government is a one-off payment to repair damage – not to invest in the future.

“The Environment Agency shows unless that increased investment is sustained until the 2020s, the risk of flood damage will actually increase.

“If you don’t maintain defences properly you will just stack up problems. We are calling on the government to be transparent and explain the rationale behind their policy.”

Lord Krebs’s report does offer praise in some quarters. It says the often-criticised power firms have set an example by increasing resilience to the sort of heavy storms likely if, as expected, the climate warms further. Railways are improving their preparedness in some areas, too, it says.

But it urges that a comprehensive approach should also be adopted for water companies, major roads, ports, airports, and telecommunications.

The report admits that accurately foretelling the UK’s future weather is impossible, but it stresses the need to be resilient to extremes of all kinds.

It maintains that the threat from heatwaves has been too little discussed. It says homes and public buildings are still being constructed for the past climate instead of the future climate, and warns that premature deaths from overheating could triple to 7,000 per year by the 2050s as temperatures rise and the population ages.

The CCC estimates that a fifth of homes are already at risk of overheating, even in a cool summer, and mentions forthcoming research from Cambridge University which concludes that 90% of hospital wards are already prone to overheat.

Lord Krebs said: “There has been a lot of emphasis on energy saving, rightly so, but not enough on the risk of overheating in homes, hospitals and care homes.

“We’re saying: don’t wait and rely on air-con. Install shutters or blinds or tinted windows – or external insulation. And we think new-build properties need new building standards to prevent overheating.”

The report calls on local councils to publish statutory flood risk management plans and take any actions agreed. A minority of councils, it says, are so strapped for cash that they have diverted flood investments into other spending priorities.

It complains that government has also failed to introduce new rules for developments to be self-draining, rather than plugging into the already-stressed sewer network (as recommended in the Pitt Review on flooding).

The committee members also complain that intensive farming is still being supported in areas where the ground needs natural vegetation to soak up rainfall.

A shortage of funds in the Environment Agency also means that small developments on flood plains cannot be scrutinised for their impact on flooding.

“There may be reasons for building on flood plains,” Lord Krebs said. “But there could be up to 12,000 homes going on flood plains with no advice – and that’s just stacking up problems again as sea levels rise and extreme weather events are expected.”

A government spokesman said: “We are spending £3.2bn over the course of this Parliament on flood management and protection from coastal erosion.

“We are committed to addressing the risks from climate change – by increasing awareness and making far-sighted decisions we can address these risks, save money and safeguard our homes and communities for the future.”

Maria Eagle MP, Labour’s shadow environment secretary, said: “The government’s failure to get to grips with the increasing impact of climate change threatens our national security.

“Of course tough decisions have had to be made on spending to reduce the deficit, including within Defra, but we need to end short-termism to ensure we are not storing up problems.””

* Happy to retract and correct this comment should we stand corrected.

A new broom sweeps clean at Castle Point. While they are at it – time to send Local Plan evidence base to the shredders!

Something for the new regime in place at Castle Point Borough Council to consider during their Local Plan considerations, is an early paragraph taken from the CPBC Strategic Flood Risk Assessment (SFRA).

The SFRA was instigated based on evidence provided by Castle Point Council and used to “support” the failed Core Strategy.

I reproduce the statement below as it appears to be based upon a disturbingly misleading fact.

The paragraph in question, produced by Scott Wilson on behalf of CPBC, reads:

 “ It is planned that most of the borough’s housing needs to 2026 can be met from housing provision in the urban area, particularly town centres, main route corridors and other undeveloped land.

However, it is not possible to meet the entire boroughs housing needs from these sources.

This is particularly the case on Canvey Island.

This gives clear indication that the CPBC councillors and officers with authority over the Core Strategy at the time were intent on releasing only Green Belt areas in the Borough on Canvey Island alone, regardless of  existing constraints such as the hazardous industries and Flood Risk.

A means of pressurising the flood risk assessors and influencing their conclusions by implying that little other land within the whole Borough was available!

The significance of the possibility of flooding were concluded by the experts, Scott Wilson, as being:

 The results from the increased scope Level 2 SFRA have confirmed that the southern part of Castle Point, namely Canvey Island and the Hadleigh Marshes area are at significant risk of tidal flooding.

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.

Faced with producing the new Local Plan, CPBC officials came up with evidence that there were indeed available developable areas across the Borough, suggesting that the statement within the 2010 Castle Point SFRA, that specifically it was Canvey Island alone, that could not fulfil it’s housing need by use of town centre, main route corridors and other undeveloped land was at best misleading!

In the draft Local Plan’s housing availability assessment it is indicated that there is now land available out of the flood zone of Canvey Island for in excess of 2550 dwellings.

The obvious question is why was the information regarding these developable areas withheld from Scott Wilson when they undertook the Flood Risk Assessment?

Clearly by withholding information that resulted in the Flood Risk assessors producing evidence that influenced and unwittingly manipulated the Sequential Test.

A Test  devised to protect the well being of local residents from the repercussions of a flood event!

The implication once again leading to the Core Strategy’s Examination Planning Inspectors conclusion that “Local Factors” were at play.

Now, it is fully understandable that mainland residents are disturbed by the implications that green land has now been publically identified as developable, and we offer our support and sympathy to them.

It is clear now however, that the new regime in place under cllr Riley will be expected to address the supply of misleading information that has, for too many years now, been used in local plan making. They have a major task ahead of them and we wish them well, however it is clear their work will be scrutinised.

The Inspectorate and Castle Point residents will be expecting CPBC to not only do the right thing with their Local Plan making, but also to be seen to be doing the right thing.

It should be remembered that:

 “extraordinary claims require extraordinary evidence.” *

We were successful in indicating the “extraordinary claims” within the failed Core Strategy.

Lets hope for a reasoned, evidenced and fair NEW Local Plan!

The Canvey Green Belt Campaign group, when they met with CPBC regarding the draft Local Plan prior to the local elections, said that we would be using CPBC’s own Local Plan evidence in submissions against the draft Plan.

The Chief Executive demanded “what evidence”?

A perfect example is illustrated above!

* Carl Sagan