Tag Archives: surface water flooding

Admiral Jellicoe replaced by 40 Flats – whilst Canvey Island being sold off for 30 Pieces of Silver?

So a proposal that the Admiral Jellicoe public house on Canvey Island is highly likely to be demolished and replaced by 40 Flats has been lodged with Castle Point Borough Council.

Admiral Jellicoe

Admiral Jellicoe. Luke Baker Photography.

This is “timely” news as cpbc will be evaluating the next move forward with their new draft Local Plan2018 at Wednesdays special council meeting. Work is also imminent on the Brownfield Land Register, which will give Permission in Principle for Housing sites across the Borough to meet the Housing Need required of the cpbc Local Plan.

The Housing Need is likely to be set around 342 dwellings per annum.

Currently the Brownfield Land register reads as a paltry supply of a minimum 264 dwellings.

This Supply List appears somewhat misleading as the entry for the Admiral Jellicoe site indicates a minimum of just 15 dwellings, 25 less than the planning proposal applies for!

This misleading figure causes concern as the previous draft Local plans have carried a figure for Thorney Bay of 600 dwellings. This is 33% less than the intended figure, quoted by the Sandy bay site manager, of 900 Park Homes!

How many other discrepancies are contained within the figures for Canvey Island?

Whilst our esteemed councillors consider the new Local Plan2018 Housing Growth Distribution and the numbers they perhaps should consider their morals as they allocate Canvey Island’s proposed Housing Numbers.

According to data published by the Ministry of Housing Communities and Local Government (MHCLG) figures show that 11% of new homes were built within areas of high flood risk, up 9% from 2015/2016.

Castle Point Brownfield Land register indicates that of the minimum numbers identified, 264 dwellings, 43% will be developed on Canvey Island, a Flood Risk Zone 3 area and a Critical Drainage Area!

Compare this 43% with the 11% National Average and you might just begin to realise it may be overdue for councillors to consider their conscience as they allocate yet more dwellings onto Canvey Island.

And that 43% is without allowing for the actual proposed numbers referred to above!

“Geoff Offen, managing director at Future Climate Info pointed out that the figures show that more than one in 10 new homes were built on sea or river flood plains which are prone to flooding.
‘While the national housing shortage compels us to seek out more land across England and Wales to build homes upon, buyers of these new properties must be aware of the risks their new bricks and mortar face,’ he said.”

CPBC Agenda paperwork explains; “Furthermore, Canvey Island is within Flood Risk Zone 3a, and as such planning applications for residential development normally require a Flood Risk Assessment. Advice is awaited from the Environment Agency as to if and how the Council could go about addressing this requirement before proceeding to consider any sites on Canvey Island for inclusion on the Part 2 of the Register”

Cllr Riley letter to Sajid “it (cpbc) will bring forward Part 2 of its Brownfield Land register – the “Permission in Principle” The council has a clear indication of the technical work necessary to bring forward sites from Part 1 of the Register and would commit to and complete this work by summer 2018”.

However cpbc are aware that “Part two of the register is optional” and that “planning permission would not be granted until Technical Details Consent is applied for and approved by the Council.”

Presumably an in-house application of the Sequential Test will suffice!

Furthermore much appears to be being made of residents comparing Canvey Island with the mainland and how this is wrong as we should be viewed simply as “one borough,” as though division is weakness.

Perhaps having considered some of the above the “one borough” approach can be seen as less suiting to Canvey.

However quite rightly the claim is supported by facts that more development has taken place recently on the mainland.

Once again we must point out, “yawn,” that since Castle Point was formed the vast majority of population increase, 42%, has been directed onto Canvey Island.

All well and good until the population level is considered in light of possible emergency situations from flooding or Hazardous Accidents and the inabilities of responders in coping!

We are pointed to the very recent Housing numbers allocated to the mainland compared with Canvey Island and how the mainland has absorbed more.

We need first to accept that recent new housing development numbers in the borough have been very low, little more than 100 dwellings on average per year. We would suggest that nowhere in the Borough has had much Housing development, compared with other areas.

In fact in very recent times only 2014 – 2015, when 214 Housing Completions were achieved, stands out as an above average year for the borough and the distribution of Growth hardly supported the argument that the vast majority were delivered on the mainland.

Information for this 2014 – 2015 period indicates that 86 were completed at Kiln Road, whilst 50 at Long Road, Canvey Island and 30 at Lubbins Car Park, Eastern Esplanade, Canvey Island were the only sites realising over 14 dwellings!

Whichever Local Plan the cpbc councillors are “entrapped” into adopting, whether the 2014 daft Local Plan or the 2016 version, we will hear that Canvey residents should be grateful that more Housing is scheduled for the mainland compared to the Island.

However cpbc do not impose Flood Risk, nor hazardous Industries, as a Constraint on Housing Numbers. Sites are allocated to Canvey Island because of “The Borough’s Housing Need”!

Let us remember on the day of local Plan reckoning that not only will Housing Land be released on Canvey Island but also Green Fields allocated for Industrial and Business Use!

Of which: Land Opposite Morrisons Northwick Road Canvey Island Essex
Area 7.5 Hectares site, Roscommon Way Canvey Island Essex 2.24 Hectares site, Land South Of Roscommon Way Canvey Island 7.41 Hectares site, Extension to Charfleets Industrial Estate Canvey Island 7 Hectares site, Land for Employment South of Northwick Road Canvey Island 8 Hectares site.*

All on Greenfield Land, on land affected by a High Water Table made worse by tidal water penetrating UNDER the sea defences, something never heard considered during planning matters.

As a group and individually, we have nothing against any of the residents of the Borough, and are known to happily collaborate with other GB campaign groups, but if we cannot see a fair and decent Local Plan emerging we will be intent upon challenging!

The cpbc Brownfield Land register, Dated 1. 12. 2017, can be found HERE.

* Happy to correct details if found to be incorrect.

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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.

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!

Continued Development Necessary, for Canvey Island to Thrive Economically and Socially, despite the Hazards!

Is there a point where it becomes inconsiderate, down right fool-hardy or plain morally wrong, to Plan to continually increase the population of Canvey Island?

Or have we already reached the stage where Castle Point Council’s policies have left the Island over populated?

Currently the policy of Castle Point Council is clear, it intends to continue to develop Housing and Business properties on the Island as a necessity as, “it is considered that continued development is necessary in order that the settlement of Canvey can continue to thrive economically and socially.”

Canvey Island, as all residents, prospective and current, should know, is at Actual Risk of Tidal Flooding, suffers from Surface Water Flooding and is home to 2 Top Tier COMAH sites, Oikos and Calor.

In addition to this OIKOS have permission to expand its facilities having had this proposal approved; Construction of a new deep water jetty facility consisting of the refurbishment of and extension to the existing OSL Jetty, refurbishment of an existing 12 tank storage compound and the undertaking of related operational and site infrastructure works.

Calor currently have gas import facility via its own jetty.

Entry and Exit of Canvey Island is possible from just one point, Waterside Farm Roundabout.

Should there be an incident of any type the Council wish Residents, in the first instance, to Shelter.

Sheltering, “is normally the preferred option. This involves residents being asked to stay in their homes, close all doors and windows, tune into local media sources and await further instructions, or the all clear from the emergency services.

The evacuation of residents is normally a last resort, however should the emergency pose a significant risk, then it may be the only viable option.”

So before any reader gets too carried away with us being Scare-mongerers, the possibility of an incident that may require Evacuation of the Island exists and cpbc recognise it!

However the only examination , albeit some years ago, into the logistics of an Evacuation found that the timescale could involve taking over 19 hours! This was prior to the introduction of Traffic Lights at Sadlers Farm Roundabout and the increase in population recorded in the 2011 Census!

It must be assumed that the 19 hours estimated would have been for an orderly evacuation exercise.

In practise the Summer Floods of 2014 gave a clear indication of the capacity of the Escape Routes. In particular Canvey Way became blocked, as per usual. This in turn actually stopped the Emergency Services, in this case the Environment Agency, from attending the Drainage Pumps that were either malfunctioning or had lost electrical power!

The Environment Agency reported to ECC “The flood water on the Island made conditions difficult for our engineers to move between pumping stations, this in turn made the response to the ongoing problems at the pumping stations more challenging.”

Essex County Council concluded;

” As such, the impact on flood risk of any new proposals for development (on Canvey Island) or alterations to permeable land, for example the paving of gardens, needs to be considered very carefully and impermeable surfaces avoided where possible. .”

Many moons ago our local authority made an effort to communicate to each household, measures to be taken by Residents should a Flood occur, this has long since ceased!

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The 2005 Buncefield incident is relative to Canvey Island. Canvey’s 2 Hazardous Industrial Sites in liaison with Essex County Council have their own Emergency Plans. That  only certain limited information is shared with just the absolute closest of neighbouring residents, highlights the lack of Preparedness of the vast majority of Islanders. The potential for the whole of Canvey to be badly affected by an “accident” at either Hazardous Site exists.

The Hertford Police updated Buncefield Residents;

“Whilst this operation is ongoing there will be increased settlement of dust and soot particles as the temperature cools under the plume of smoke over the Hemel Hempstead area. We would remind residents of messages relayed yesterday that these dust and soot particles are an irritant which can cause coughing, irritation to the eyes and nausea – particularly to elderly, those with existing respiratory problems and young people. Wherever possible, people in the Hemel Hempstead area should continue to ‘go in, stay in and tune in’ to media bulletins and avoid all unnecessary journeys.

Those people who work in the area were also asked to make contact with their own companies and not to go anywhere near the area until advised it was safe to do so.

Warnings were also issued through the media that slowing or stopping to film the ongoing incident on mobile phones or other devices was not only a possible danger to the safety of road users but was also likely to constitute a criminal offence.

At this time, the advice remains to people in the affected area to stay indoors, close windows and watch/listen to news bulletins for updates. This advice is especially relevant to people who have some form of respiratory condition such as asthma or bronchitis.”

It is apparent that there is a strong case for an open and transparent engagement with Canvey Residents, so that it is clear what actual At Risk Register, dangers exist and the responses required of Residents. Being unaware is a Recipe for Panic!

“In COMAH, there is a requirement to share information between
site operators and Category 1 and 2 responders in order to fulfil the requirements
of the duty for risk assessment, warning and informing the public and the
preparation of on-site and off-site emergency plans.”

The argument that keeping Residents in the Dark so as to protect property  prices and encourage further development, is a Reckless Policy!

We are reminded that Castle Point has an ageing population, many Residents can be considered At Risk. There is a need for an At Risk Register. There is a need for an Able to Assist Register.

An Informed Community, can be better Prepared to React and Respond correctly and. those able, be in a position to assist.

However the Castle Point policy; “that continued development is necessary in order that the settlement of Canvey can continue to thrive economically and socially” appears to ignore any possibility that any incident or “accident” could endanger Residents and property, or that there is adequate resources on standby ready to respond to any eventuality without Residents assistance.

Meanwhile Castle Point council have published their new Emergency Response Plan.

We have added a link to the document HERE.

The chances of Canvey Island Flooding during the next 1 in 316 year event, may not be in 316 years time!

Of late on Canvey Island social media websites, it has been noted how some contributors have expressed their view that the island faces a flooding threat from Rainfall, rather than from a Tidal breach or over-topping.

Indeed some have even gone as far as stating that it is Scare-mongering to even suggest the possibility that a threat from Tidal flooding even exists. For this post we will ignore Tidal flooding, leaving those wishing to keep their heads in the sand, and concentrate on Surface Water Flooding.

Following the 2014 Summer Flooding on Canvey Island and the ensuing Flood Investigation Reports, it was recommended that the terminology to indicate the threat of flooding should be altered. That is the existing 1 in 30 year, 1 in 100 year etc possibility of flooding, should be updated so that a more appropriate, more readily understood explanation of the possibility of a flood event is available.

Three years on and it appears that little has changed. This leaves homeowners and businesses oblivious to potential dangers and consequently ill-prepared.

This also leads local authorities into money saving complacency, and having to be reminded of their maintenance responsibilities.

Drain 4.04.17

There are concerns that monies from central government is granted but not strictly allocated to maintenance intended, councils preferring to place grants into central funds.

Some scepticism eludes from the ECC Flood Investigation where maintenance funds were apparently used, and yet the work carried out had little effect on preventing flooding in the following months.

Extracts from the ECC Investigation into the Canvey Island 2014 reveals;

In the period of time between 13:40 and 18:00 one million cubic metres of water fell on the island, which equates to almost the full capacity of Wembley Stadium.

This event was unprecedented,                                                                                                                       and the return period for this rainfall event is estimated at 1 in 316 years or 0.3% chance of it occurring in any given year.

Rainfall on the island may flow a substantial distance before reaching the pumps, through infrastructure owned or managed by a large number of different organisations and individuals and in some cases without a clear understanding of ownership. Any constriction on flow either due to blockage or insufficient capacity for the rainfall event can affect the effective operation of the entire drainage system.

As a result of the relatively densely populated urban areas and large areas of impermeable surfaces the island is especially susceptible to intense rainfall events which result in flash flooding. In combination with the flat topography of the island this means that Canvey is particularly dependent on the designed drainage infrastructure to mitigate flood risk.

Following the longest sustained period of wet weather on record over the winter months, Essex County Council released an additional £1m of emergency revenue funding to deal with highway related flooding.

In mid-February 2014 Castle Point Borough Council put forward its Top 5 flooding sites to Essex County Council, 4 of which were on Canvey Island:

Canvey Seafront area, Lottem Road area, North Avenue area, Town Centre area.

Extensive cleansing, CCTV surveys and jetting of the highways assets was undertaken at all of these locations and where necessary repair works were programmed.  

Arising from these works in the Canvey Seafront Area a larger Surface Water Alleviation Scheme (SWAS) has been identified and put forward for funding (circa £100,000). 

Generally, the drainage system at this location is very flat and prone to heavy silting.

Gullies, catch pits and associated pipework on Canvey Island are cleansed annually as part of the cyclical annual gulley cleanse.                                                                                                                      

There are a total of 5,767 highway and footway gullies in Canvey. 

In 2013/14 5,672 gullies were attended and of these 5,298 (91.8%) were cleansed.

On a personal level, my area of Canvey is amongst the unfortunate 8.2%.

However, returning to the issue of updating the terminology to indicate the threat of flooding should be altered. That is the existing 1 in 30 year, 1 in 100 year etc possibility of flooding, should be updated so that a more appropriate, more readily understood explanation of the possibility of a flood event.

It has been 3 years since the 2014 Canvey Island summer flooding and it appears no new system of flood possibility measurement has emerged.

Meanwhile following the flooding in Houston USA, the FiveThirtyEight blog reveals similar concerns regarding Flood Risk measurement terminology is a talking point across the Atlantic.

The FiveThirtyEight Blog post can be read HERE.

 

 

Essex County Council Community Resilience Plans + Persons at Risk Register = Canvey Island, Do it Yourself!

Essex County Council website appear keen that residents and Parish councils should compile their own Community Resilience Plans.

Following the example of the failure of Essex County Council, Castle Point Council and the Environment Agency to respond adequately during the 2014 summer Flooding on Canvey Island, perhaps ECC have a point!

However as a group, we have long suggested that a local Persons at Risk Register should be compiled.

The logistics of forming such a Register is, no doubt, a daunting prospect, however  opportunities are available, either during the 10 year Census or the annual mailing of the Council Tax demands, when an extra questionnaire could be distributed.

Responses could be compiled to give an idea of the numbers and locations of those people less able and most in need of assistance during an Emergency on Canvey.

With the high number of population residing on Canvey Island, and the possibility of an Emergency situation arising from either the 2 Hazardous Industrial sites, Surface Water Flooding or Tidal Flooding, any Persons at Risk Register would prove to be an asset in the right hands!

Essex County Council suggest that this is not about doing the job of the Emergency Services or Local Authorities, nor should it be, given the Local Authorities abject failure during 2014!

However this level of buck passing onto local communities misses a couple of points. Local Authorities and associated agencies are either paid for, or elected by, the same local communities. Individual actions should not take the place of the joint action force that is expected to be better prepared and be better able to carry out a planned and practiced for emergency operation to protect residents.

It may be viewed by some that, should such local community information data base be collated by resident groups, the personal information required could breach confidentiality limits.

So on the one hand we have Local Authority agency partners who have still Lessons to be Learned and failing us, and on the other hand an ageing population.

Whilst looking out for the frail, elderly and less able in our neighbourhoods should be a natural course to undertake,  something on the scale suggested should be organised on a far larger scale by an authority with better resources.

Still at least Canvey has one of the closer communities compared with some parts of the Country, a First Responders group and a Town Council, which should mean that once this initiative is exposed as simply a compliance paper exercise by ECC to fulfil their obligations, should anything untoward occur, given the three potential sources of Emergency on the Island, help may be at hand!

Essex County Council have posted on their website;

Why should my community have an Emergency Plan? 

Emergencies are rare, but they can happen.  In the last few years, Essex has experienced severe winter weather, flooding, travel disruption, fuel shortages and a flu outbreak.  Challenges like these can affect our daily lives.

The good news is that communities can prepare themselves for emergencies and it can make a big difference to how people can cope.  When we talk about communities, it can be any group of people, a parish or ward, area or any other group of people.

More resilient communities:

  • Are aware of the risks that may affect them and how vulnerable they are to those risks
  • Use their existing skills, knowledge and resources to prepare for, and deal with, the consequences of an emergency
  • Understand who are the most vulnerable people within their community, who may need extra assistance
  • Can work together to complement the work of the emergency services and Local Authorities before, during and after an emergency

This isn’t about doing the job of the emergency services and Local Authorities.  It’s about supporting your community, and those in it, by making sensible preparations and using the skills and knowledge that the community has.

Castle Point Borough Council’s Emergency Advice can be found HERE.

Canvey Island, the Development “Special Case” and Castle Point Council Failings!

Of late there have been reasons enough to query the sense in planning to over populate Canvey Island!

Following the “disputed” moratorium of housing development on Canvey, blamed upon the Environment Agency, a successful bid for Canvey Island to be viewed as a “Special Case” was launched.

Below follows the Castle Point committee meeting minutes whereby this cautious approach was over-turned and afterwards comes comment on the possibility of people investing in new properties with the danger of experiencing extremely high flood risk premiums or even finding themselves unable to secure flood risk cover at all.

We conclude with some Planning guidance that may suggest that development on Flood Zones and indeed in the Green Belt could, indeed should, be avoided.

We hope you find this locally enlightening.

Castle Point Borough Council decision to remove restriction of developing the Zone 3 flood plain of Canvey Island.

PLANNING COMMITTEE MINUTES
6TH FEBRUARY 2007
PRESENT:
Councillors Smith (Vice-Chairman who chaired the meeting), Anderson, Cole, Cross, Dixie, E. Egan, Mrs Goodwin, R.C. Howard, Riley and B.S. Wood
Councillors Mrs Challis Mrs B. Egan, Ladzrie and Mrs Liddiard
Apologies for absence were received from Councillors Blackwell, Mrs Iles, Sharp and Mrs J.Govier.
73. PLANNING POLICY STATEMENT 25: DEVELOPMENT & FLOOD RISK
The Committee was informed and discussed the new amended national policy on development and flood risk set out in Planning Policy Statement 25, published in December 2006 which contained new and amended planning policies to mitigate and avoid the impact of flooding through good planning and flood risk management.
The Committee had previously commented on the consultation on the draft PPS 25 at the meeting on 7.2.2006.
The report before the Committee described the structure of PPS 25 which contained five sections covering background; key planning objectives; decision making principles; risk based approach and responsibilities; supported by a further eight annexes.
Members considered the implications for Castle Point arising from PPS25. The new PPS would have a particular bearing on the work for the Local Development Frame work and on the consideration of planning applications.
In terms of planning policy work, a strategic flood risk assessment had been prepared for Thames Gateway South Essex authorities and was to be published by Spring 2007. This would help inform the preparation of the Core Strategy by identifying broad locations within Castle Point and other authorities that would be appropriate locations for development.
In development control and for the purposes of PPS25, Canvey Island was located in Flood Zone 3 (High Probability), because the PPS ignored the presence of existing defences (acknowledged to be some of the most comprehensive in the country). Accordingly the requirement for flood risk assessments to accompany planning applications had also been in place for some time and in particular the application of both the sequential test and the exceptions test.
Planning Committee – 6th February 2007
This initially caused difficulties, particularly for smaller scale development, because of the uncertainty over requirements for these assessments and their relevance and applicability to such schemes. However experience had suggested that through discussion with the Environment Agency, developers, agents and landowners were now clearer about, first the requirements of the these tests, but more importantly, secondly, how to carry out development whilst at the same time mitigating the risk associated with flooding through careful design at the application stage.
Resolved –
1. That the Committee notes the policy guidance and advice of PPS 25.
2. That the Committee have regard to the guidance and advice in the preparation of the Local Development Documents and in the consideration of relevant planning applications, in order to achieve the Council’s community priorities and deliver sustainable development.
Chairman.

However the Insurance Industry does not share the Councils optimism
The short term solution Flood Re is a scheme funded by a levy on insurers that reinsures their customers’ flood risk, allowing them to offer flood insurance to those homes at risk at a more affordable price.
One of the most important aspects of Flood Re is that it provides time for insurers, the government and homeowners to address deficiencies in planning policy, invest in flood defences and improve the resilience of housing stock. The scheme is intended to be operational for 25 years, during which time there will be a role for central and local government, the insurance industry, environmental organisations, housing providers and homeowners in tackling flood risk. After this 25 year period, the Flood Re scheme assumes that improvements in flood resilience, as well as more sophisticated and readily available flood data will leave the insurance industry in a position to offer more affordable cover in a risk-reflective free market.
Properties built since 2009 are not eligible for Flood Re, which in theory should introduce pressure on planners to fully consider flood risk before new homes are built. However there remains a challenge in ensuring that a new property’s flood risk is properly communicated both to the buyer and the insurance industry, so that both parties can avoid any shocks further down the line.
As well as providing a period of breathing space for industry and policymakers, Flood Re also intends to provide a point of focus for the next 25 years, to continue the debate about addressing the root of the environmental and planning issues. But the inescapable realities of climate change, coupled with a seeming lack of a long-term approach to investment in flood defence measures means that the success of these ambitious plans is far from guaranteed.

Planning Guidance tells us that when :

Applying the Sequential Test in the preparation of a Local Plan;
“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”.
The latest Castle Point Local Plan failed the Duty to Cooperate requirement. The Examining Planning Inspector noted in his failure Report:

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

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

However, notwithstanding the lengthy and detailed engagement across south Essex there is no formal mechanism in place to distribute unmet housing need.

The problem is that this is once again only guidance and we have often been reminded by CPBC planning officers of this fact when they deliberate on planning proposal for Canvey Island.
It would seem that any guidance that has not been fulfilled can be ignored, as far as Canvey Island is concerned, as it is only for consideration purposes.