Tag Archives: Thorney Bay

Dates, Canvey Islanders won’t even Notice! Thorney Bay’s, on its way!

Canvey Islanders, it is said, haven’t the nous to have a cynical thought cross their little minds.

Firstly, following the Election announcement on the very last day prior to the period of Purdah commencing, the Jotmans Farm Appeal Inquiry was Rejected by the then Secretary of State, thereby saving important mainland Green Belt from development.

Secondly, tomorrow, 6.6.2017, just 2 Days prior to the General Election, castle point council development committee will decide the Recommended Approval “first phase” of the Thorney Bay vast green field development, on Canvey Island.

Thorney Bay Beach Camp, Canvey Island, Essex

copyright Jason Hawkes

This so called first phase at Thorney Bay amounts to 113 new dwellings.

The development committee Agenda paperwork indicates officers advise :

It is not considered necessary for Members to visit the site prior to determination of the application.

This despite :

To the north of the site is the Local Wildlife Site (LoWS) Thorneyfleet Creek, which comprises a water body with Common Reed and rough grassland; beyond this is residential development. To the east is Public Open Space, in the form of a grassed area and children’s play space. To the south and west is the wider expanse of the Campsite. A water treatment works lies to the west of the wider site and beyond this is the Calor gas terminal. To the south is the Canvey Island Sea Defence, beyond which is the River Thames.

Of the Health and Safety Executive’s comment;

..more than 10% of the housing development area lies within the (Calor Gas Hazardous) middle zone….and HSE Advised Against Granting Planning Permission.

The HSE then go onto excuse the proposed development layout, stipulating that castle point council must not in future use the self regulating facility, instead be referring any future development directly to the HSE!

The Case Officer comment, which will no doubt be pointed out to the planning committee members in the Agenda Paper states; 

Health and Safety Executive  No objection.

As far as potential flooding is concerned, especially as the site is directly reliant on the Canvey Sea wall Defences;

Environment Agency  No objection: following the receipt of a revised FRA, subject to conditions and the satisfaction of the LPA that the proposal will be safe for its lifetime

It should also be noted, should the are become flooded yet again that responsibility has been relieved of the Leal Local Flood Authority (Essex CC.);

It is the applicant’s responsibility to check that they are complying with common law if the drainage scheme proposes to discharge into an off-site ditch/pipe. The applicant should seek consent where appropriate from other downstream riparian landowners. 
The Ministerial Statement made on 18th December 2014 (ref. HCWS161) states that the final decision regarding the viability and reasonableness of maintenance requirements lies with the LPA. It is not within the scope of the LLFA to comment on the overall viability of a scheme.

But of course the Rumours emanating from CPBC is that Thorney Bay will become a Park Home site, So None of these Rules Will Apply!

1,600 static caravans could quite easily become 1,000+ Park Homes, and there is the next Local Plan’s 5 Year Housing Supply.

Let existing Canvey Island residents and future property owners be warned!

We make no apology for over-simplifying these issues but for anybody interested the webcast and recording should be available via;  https://castlepoint.gov.uk/webcasting

The meeting Agenda papers are available via; https://www.castlepoint.gov.uk/agendas-minutes-library

 

Thorney Bay, change of Use Over-Heard on the Canvey Grapevine! CPBC Local Plan issues?

It started as a Whisper, became a Rumour and has now reached Conjecture level on the Canvey Grapevine!

Thorney Bay, the apparent answer to the Castle Point Council’s Local Plan dreams, has become the subject of unconfirmed speculation. With the humiliating Withdrawal of the cpbc Core Strategy in 2011, it was considered “timely” by cpbc officers that Thorney Bay, despite it being sited within the Hazard range of Calor Gas and within a 3A Flood Zone, should come forward to provide a Housing Development of some 600 dwellings plus sheltered accommodation.

Thorney Bay then became the Backbone, the largest single development site, of Castle Point council’s daft Local Plan and surviving the GB sites cull to remain as the spine of the Local Plan2016, 5 year Housing Supply!

The Thorney Bay proposal passed in Principle by the cpbc development committee, whilst in the following months / years a 1st Phase proposal has gained Health and Safety Executive’s permission and is apparently overcoming the Flooding Objections to the fundamental requirements of the Environment Agency and the ecc Lead Local Flood Authority.

Now then; Listen very carefully, I shall say this only once!

A little Bird has told me, and I must say there is little foundation, so to speak, for this to be considered information, but it could be that the development may not be going much further!

To me this would not be a surprise, I would have thought a more likely idea would be for the developer to follow the Kings Park, and remove the static caravans and replace with Park Homes.

The build cost would be far less, the speed of development would be probably twice as quick and success of the venture equally, if not more so, financially successful as Kings Park!

What’s to lose?

Park Homes and Luxury Lodges can easily reach an asking price of £300,000, the site is opposite Thorney Bay Road, and residents would likely be of an age not too concerned with, the daily commute.

Now that the Canvey Bay Watch team have created such an attractive area of the promenade and beach front, this forms another selling point for potential Park Home buyers. I would have thought that the Canvey Bay Watch team should soon be knocking on the site owner’s door for financial support, should this development rumour come to fruition!

Thorney Bay 1

Photograph courtesy: Dave Harvey

The question for cpbc is whether these Park Homes should count towards the official Housing Supply.

On one hand these Park Homes “are suitable for residential use throughout the year and are built to last at least 50 years”! (Omar park and leisure homes). Although whether 50 years lifespan is considered permanent is challengeable, however, their success is, and there are people desiring to own them.

The Planning Inspector examining the Glebelands, Thundersley, Appeal did not consider the numbers at Kings Park should qualify for inclusion in building numbers, but that may have been due to cpbc being unable to clarify how many caravans were replaced by Park Homes.

We do know that of the caravans at Thorney Bay the Inspector concluded;

“But that does not necessarily mean that the Households now occupying caravans would have chosen that type of accommodation, in preference to bricks and mortar.”

Well, “bricks and mortar” these Park Homes ain’t! But the appeal of Park Home life is generally popular across the UK, so if people are choosing to buy into this type of accommodation, then there is an argument for these dwellings to be included into the Canvey Island Housing Supply count.

With our “Broken Housing Market” leading to the apparent need to revisit Pre-Fabricated Housing, these Park Homes may well have some scope.

Whether or not any Affordable Home supply can be squeezed into the equation will be upto the negotiating abilities of cpbc, so we won’t hold our breath on that one!

What could be expected is for some Canvey Island “bricks and mortar” dwellings to become available, for local young families hoping to get on the property ladder, as older Canvey residents move into the Park Homes.

It may be doubtful , should the development come into fruition, whether the Housing Need in the mainland part of the Borough be part satisfied, as it will be difficult to argue that this type of dwelling satisfies the cross market “bricks and mortar” Housing Need. In fact it probably increases the pressure on mainland site supply.

I remind you this is only speculation.

As a reference, below, I include part of the text of the cpbc Report on Residential use of Caravan and Park Home Sites 2013.

“It is clear from both Census data and from Council Tax data that an increase in the availability of caravans for residential use resulted in an increased housing supply of the order of 800 homes in Castle Point in the period from 2001 to 2011. This increase was largely as a result of the change of use of Kings Park and Thorney Bay Caravan Parks from holiday use to residential use.”

“To date, the Council has only included those caravans registering for Council Tax at Kings Park within the housing figures for the period 2001 to 2011. However, given that caravans at Thorney Bay were included as homes within the Census 2011 outcomes, and this will be reflected in population and household data moving forward, it is appropriate that the housing supply figures for the period 2001 to 2011 are appropriately adjusted to include these homes also.”

“The change of use of static caravans from holiday accommodation to residential accommodation has made a significant contribution to housing provision over the last decade (2001 to 2011). Approximately, 800 additional caravans moved into permanent residential use over this time period, primarily on the Kings Park and Thorney Bay sites. This is supported by evidence from the Census and from Council Tax records.”

“However, whilst some of this provision has contributed positively towards the community, in particular at Kings Park, the nature of the provision at Thorney Bay has had negative socioeconomic consequences both for the surrounding community and for the vulnerable families who have found themselves living at the site.”

“Due to these issues there is support for proposals to redevelop a significant proportion of the site for traditional homes. However, it is the intention of the owner to retain a smaller caravan park of 300 caravans for residential use towards the west of the existing site.”

“Assuming that the proposals to redevelop this site as proposed for traditional housing are delivered in full over the next 10 years, then it is unlikely that the number of households living in caravans in Castle Point will increase further between 2011 and 2021. Indeed, as a result of the development of traditional housing over this period, it is expected that the proportion of households living in caravans will reduce.”

“However, should the Thorney Bay site not be redeveloped as proposed, then there is the potential for a further 800 caravans moving from transient use into permanent residential use. This will increase further the number of households living in caravans, and the associated socio-economic issues arising from this. It is therefore imperative that the Council work alongside the site owners to encourage and facilitate the redevelopment of this site in an appropriate timeframe.”

Video copyright BBC

Thorney Question of Over-developing a Small Island in Castle Point!

Given that there is a possibility Canvey Island may suffer another Tidal Flood, given that we may again suffer from Surface Water Flooding as in 2013 and 2014, given that there may be another leak of LPG from Calor Gas, given that OIKOS have been granted permission by CPBC to increase activities in the importation, storage and blending of butane, and however small the risks, should not the Distribution of Housing Growth as imposed by Castle Point Borough Council (cpbc) be called into serious Question? *

Already there are over 38,500 residents on Canvey Island. If there were to be a major incident from just one of these four sources, an Evacuation of the Island, given the population level, the lack of access / egress routes and there being No Means of Warning, would be an impossibility. Is it time to cap the population level? We believe it is!

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Rather than accepting these “dangers” the powers that be at cpbc, appear to have their eyes and ears covered to blot out the concerns of the population on Canvey Island exposed to possible incidents in the desire to offset Housing and Business development away from the controlling mainland part of the Borough. Little wonder there is an active group hoping to convince the Boundary Commission to leave the Borough’s borders alone!

The denial of Climate Change, the absolute faith in our sea defence, the faith in the “hard work” undertaken to “maintain” the Island’s drainage system and the assurances from the two Top Tier COMAH sites, amount to little more than roll off the tongue Platitudes!

We stand accused of scare-mongering, then so be it!

We call it living in the Real World and “facing” realities. Fore-warned is Fore-armed.

Canvey’s highway infrastructure is restrictive, all routes converging at Waterside Roundabout, meaning evacuation is impossible and our limited Fire and Rescue cover means response times for assistance are likely to be prolonged.*

Green Belt is protected in planning terms by the Very Special Circumstances needed before the consideration of any development proposal.

Consider that, against a development proposal within a Flood Risk Zone and within the Consultation Distance of a Major Hazard site!

This is what requires not only for planning considerations, but also leading council members and officers to consider their consciences, with the proposal to develop 113 dwellings at Thorney Bay, Canvey Island.

This is only the first phase of a major development consisting of “approximately 600 dwellings” plus “Park Homes.”

The cpbc planning portal indicates that the developer may have overcome, to cpbc’s satisfaction, the requirements of the HSE, the Environment Agency and Essex County Council, the surface water drainage experts.

However these agencies lifting of Objections should not be seen as them giving their Approval!

In fact their concerns indicate that they Do Not Rule Out the Possibility of one or other Incidents occurring in the Future!

Within their comments they give very distinct warnings and concerns and indicate quite clearly the final decision and the Responsibility is Castle Point council’s ALONE!

Below are a few of the consultee agencies points of concern over the Thorney Bay proposal and further below are links to some previous incidents etc of some interest.

The Environment Agency state;

Our role is to provide you with our assessment of the risk for matters within our remit so that you can make an informed decision

“The FRA (flood risk assessment) proposes no detriment in off-site flood hazard for the design and extreme floods and manages this via a proposed embankment, subject to condition.”  Approval of the design of the proposed embankment is therefore necessary as a pre commencement condition, as the embankment is essential to safeguard against the offsite impacts. Without the construction of the embankment off site impacts would be seen

Provided you consider the development meets the requirements set out in the NPPF, including that it is safe for its lifetime and does not increase the risk of flood risk off site, we request that the following conditions are appended to any permission granted. Without these conditions our objection will be maintained.

Flood Risk Responsibilities for your Council    

We have not considered the following issues as part of this planning application as they are not within our direct remit; nevertheless these are all very important considerations for managing flood risk for this development, and determining the safety and acceptability of the proposal. Prior to deciding this application you should give due consideration to the issues below. It may be that you need to consult relevant experts outside your planning team.     

Safety of the building 

 Safety of People (including the provision and adequacy of an emergency plan, temporary refuge and  rescue or evacuation arrangements) 

Flood recovery measures (including flood proofing and other building level resistance and resilience measures) 

Whether insurance can be gained or not

Sustainability of the development – we advise you consider the sustainability of the development over its lifetime.

Your attention is brought to the proposed Roscommon Way Extension that is likely to pass immediately to the south of this proposed development site. Consideration is required of residual tidal flood risk at a master planning level to evaluate if further proposed phases of the Thorney Bay caravan park development could become less deliverable, unless suitable mitigation measures are identified and designed, with regards to breach characteristics – mainly depth, time to inundation and hazard ratings. Future proposed Flood Risk Vulnerability Classification will need to be considered alongside the residual tidal flood risks to ensure a sequential approach to future site layout is maintained.

 

ECC Lead Local Flood Authority position;

Having reviewed the Flood Risk Assessment and the associated documents which accompanied the planning application, do not object to the granting of planning permission.

Condition 1

 No works shall take place until a detailed surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development, has been submitted to and approved in writing by the local planning authority. The scheme should include but not be limited to:

  • Final modelling and calculations for all areas of the drainage system.
  • A final drainage plan which details exceedance and conveyance routes, FFL and ground levels, and location and sizing of any drainage features.

Reason:

  • To prevent flooding by ensuring the satisfactory storage of/disposal of surface water from the site.
  • To ensure the effective operation of SuDS features over the lifetime of the development.                 
  • To provide mitigation of any environmental harm which may be caused to the local water environment                                                                                                                                                            
  • Failure to provide the above required information before commencement of works may result in a system being installed that is not sufficient to deal with surface water occurring during rainfall events and may lead to increased flood risk and pollution hazard from the site.

Condition 2

 No works shall take place until a scheme to minimise the risk of offsite flooding caused by surface water run-off and groundwater during construction works and prevent pollution has been submitted to, and approved in writing by, the local planning authority.

Reason

 The National Planning Policy Framework paragraph 103 and paragraph 109 state that local planning authorities should ensure development does not increase flood risk elsewhere and does not contribute to water pollution.

 Construction may lead to excess water being discharged from the site. If dewatering takes place to allow for construction to take place below groundwater level, this will cause additional water to be discharged. Furthermore the removal of topsoils during construction may limit the ability of the site to intercept rainfall and may lead to increased runoff rates

Health and Safety Executive state;

More than 10%of the housing development lies within the middle zone, – through the HSE Planning Advice Web App advised Against the granting of Planning Permission.

However, having given more detailed consideration, HSE has concluded that it is appropriate for HSE to provide case-specific advice on this proposal outside of the codified planning methodology provided.

The layout indicates that a total of 30 dwellings at a housing density of 38 dwellings per hectare within the middle zone.

HSE’s advice is that significant housing should be prevented from being built in the inner zone and only a limited number of houses at a low density.

The overall objective is to maintain the separation of incompatible development from the Major Hazard.

HSE would advise Against any planning application which seeks to locate any additional dwellings within the middle zone of Calor Gas Ltd.

Instead of using the HSE Planning Advice Web App, Castle Point Borough Council should therefore consult HSE directly for advice on any future planning applications which propose further residential development at Thorney Bay Park within the middle zone of Calor Gas Ltd.

*Below are links to;

*Reduction in Essex Fire and Rescue Service cover view HERE

*Calor Gas Leak court decision view HERE

*OIKOS permission granted view HERE

Editor. It should be pointed out that any emphasis included in the text is the author’s.

 

Time to brief our MP? Canvey Island at the forefront of Flooding Issues, whilst CPBC covers up?

The National Flood Forum tweeted

“A great opportunity to get communities’ flooding issues debated. Time to brief your MP and ask them to participate.”

This was the Forum’s reaction to an announcement by The House of Commons Environment, Food and Rural Affairs Committee:-

We’ve secured a debate in the Chamber on 27 Feb, pending the House’s agreement tonight, with on our flooding Reports

Regarding the now regular Flooding Events that occur in the UK, much has been spoken, reported and recorded. Monies have been promised and Budgets have been set.

Nothing matches the Flooding Prevention approach and outlay committed in the Netherlands.

However locally in Castle Point, the situation appears worse still.

img_0802

There exists what may be a false sense of security concerning the perceived infallibility of the Sea Defences. The seeds of apathy have manifested from residents being comforted by the Defences being the very “best in the Country”!

The Environment Agency’s view regarding the Canvey Sea Defences is;

” Although Canvey Island is defended to a high standard of protection, it is at risk should there be a flood defence failure. This residual flood risk should be considered, as although the likelihood of it occurring is low, the consequences should it happen would be very high.”

Climate Change and Rising Sea Levels mean that the Sea Defences will require improvements to the current standards before the year 2100.

In February 2015 a Commons Select Committee conceded;

“The Environment, Food and Rural Affairs Committee queries Government plans to attract £600 million from external funders to bolster flood defences. In its report on Defra Performance in 2013-14, the cross-party Committee cites low levels of private funding attracted to date as a cause for concern about ambitious future plans.”

This matter was tentatively raised, and disputed by the applicant, during the Thorney Bay Application in Principle to redevelop the Caravan Park. A sum of around £100,000 was suggested as being appropriate contribution towards the necessary future Sea Defence Improvements by the applicant.

Since then, enquiries by the Canvey Green Belt Campaign group have revealed that Castle Point Council officers concede they have no mechanism in place for the collection of such Funds. Consequently no request towards the necessary external funding has been made by cpbc during the consideration of the application for the First Phase of the Thorney Bay development!

This further undermines the attempts by Defra and the Government to implement the Aspirations of the TE2100 (Thames Estuary) Plans for Canvey Island.

The Surface Water Flooding of Canvey Island during 2013 and 2014 were severe enough to warrant the Government Office for Science to undertake a Peer review of Essex County Council’s report on the Canvey Island flooding in July 2014.

The Government Office for Science Peer Review can be found HERE.

The Essex County Council Report into Canvey Island Flooding 2014 can be found HERE.

The Environment Agency consider the Canvey Island Drainage System as being “complicated”.

It is reliant on Gravity, as the Island is so flat, for water to reach the Pumps that are installed to transfer surface water to the Thames Estuary.

These pumps will not cope with the levels of water should there be Tidal Flooding, and failed during the 2014 Flooding event, requiring improvements to the mechanisms.

Maintenance is a continual requirement to Drains and Ditches. The Environment Agency and Essex County Highways division are affected by ongoing budget constraints, meaning Maintenance may be insufficient at any particular time.

These issue were all revealed during the report and enquiry following the 2014 flooding.

Alongside the Essex County Council Report and the Government Office for Science Peer Review, Castle Point Council’s Scrutiny Committee held a series of meetings during 2014 and earl 2015, to investigate the effects, the impact, the response and the causes of the Canvey Island Surface Water Flooding event.

The Castle Point Council Scrutiny Committee’s Report into the Canvey Island Flooding of 2014 remains Unpublished!

The Castle Point Council Webcasts of the Scrutiny Committee meetings are now unavailable!

Neither the Essex County Council Report into the Canvey Island Flooding of 2014, nor the Government Office for Science Peer Review are included within the cpbc Local Plan2016 Evidence Base! 

The Canvey Island Integrated Urban Drainage Study, is included in the cpbc Local Plan2016 Evidence Base in the form of a desk top published aspirational leaflet!

No Fund gathering mechanism is in place to collect the required External Funding for the future improvements of the Canvey Sea Defences.

In response to the National Flood Forum’s suggestion “Time to brief your MP and ask them to participate,” there appears plenty of concerns for our Local representatives to be lobbying our MP Rebecca Harris to participate over!

“Dear John” Letter from the HSE to Castle Point Council spells a loss of Trust over Thorney Bay!

“WOULD NOT ADVISE AGAINST” Is a phrase that is akin to music to Castle Point Planners ears!

So often does it extinguish any questioning by planning committee members of the extra conditional advice from the HSE, or the Environment Agency, or the Lead Local Flood Authority, when the committee consider Canvey planning applications!

At the Risk of being accused of Scare-mongering, and unlike some that “run with the fox AND hunt with the hounds”,  we prefer to refer to our approach to development as being Cautious, when we refer to Canvey’s constraint issues.

The proposal for the first phase of the Thorney Bay Housing development, cpbc planning application No: 14/0620/FUL, to sit alongside existing caravans is progressing, albeit in an apparently unusual sequence. Given the obvious issue of the neighbouring Calor, Top Tier Comah site, one would have thought that Castle point planners would have made early use of the Health and Safety Executive’s online planning advice app.

It appears however that despite cpbc receiving the planning proposal on the 6th November 2014, no such enquiry was made to the HSE, until the 12th January 2017!

Whilst an initial use of the HSE planning app was made for the original “proposal in principle,” cpbc planning application No: CPT/707/11/OUT, of 600 dwellings plus residential care homes, lodged with cpbc as long ago as 2011, this resulted in an acceptance that 10%, or 60, of the total number of dwellings could be developed within what is labelled the hazardous “middle zone”.

The more “recent” application, for 113 dwellings, sought to use a proportion of the 60 dwellings allowed, sited in the “middle zone,” BUT at a much higher proportion, in relation to the latest planning application, of over 26% !

Rather surprisingly this did not appear to occur to OUR local authority that they might just possibly feel they should refer this percentage level to the HSE!

The developer may indicate the future development phases will have a much lower level of percentage dwellings in the hazardous “middle zone”.

They MAY also find in future these development phases prove unviable without similar high percentage rates, 26%, within the “middle zone,” and having set a precedent within the first phase who could argue?

This seeks higher density development across the whole site, something that would suit developer and the cpbc Local Plan authors equally!

It is somewhat reassuring that the Health and Safety Executive appear to have lost faith in castle point council and with their policy approach towards increasing new residents risk to the exposure to the Hazardous Site.

The HSE have dictated to cpbc that they no longer can take advantage of the HSE’s online Planning Advice App, they have decreed that in future, NOT ONLY ALL future Thorney Bay planning applications which propose development in the “middle zone” must be referred directly to the HSE, but that the 30 dwellings proposed within the current application, is the TOTAL number they will permit!

It appears that Castle Point Council have, at least where the HSE is concerned, used the “Canvey is a Special Case” card once too often!

For those with a more sceptical attitude, we suggest the same may also have led to the problems at Buncefield which led to the events recorded in this resident’s video recording below.

Hindsight can be a wonderful thing, but in the meantime Caution may be the better option and it will be interesting to learn how the cpbc Local Plan Inspector views this approach, should the Plan reach the Examination stage and of course to observe the cpbc development committee’s consideration of the proposal.

 Grateful thanks go to Ian Silverstein for use of his video.

Thorney Bay – Game Changer for Castle Point Housing Provision?

 

Thorney Bay Beach Camp, Canvey Island, Essex

copyright Jason Hawkes

“Clause 124 of the Housing and Planning Act 2016, which came into force on 12 July 2016, recognises residential caravans as having a role in contributing towards the supply of housing in a given area.

In a significant step change from previous planning guidance, it means local housing authorities will need to start forward planning for the provision of park homes – increasing the prospects that new park home applications will be given planning approval.

The Government’s online Planning Practice Guidance (PPG), which sets out the methodology for assessing housing need, is now expected to be updated in line with Clause 124, to specifically identify park homes as an additional type of housing that needs to be considered and planned for.

This is a significant change for the park homes sector and it could have a positive impact on numerous sites across England when applying for planning permission for new residential caravans.

However, this change is set to boost the status of park homes within National Planning Policy, as reflected in the NPPF, which requires Local Planning Authorities to produce Local Plans that will deliver the full, objectively assessed needs for market and affordable housing in their housing market area.

For the first time, residential caravans have been identified as contributing towards housing supply!”

Mr Ian Butter, a well known development consultant in the Castle Point area, produced a document stating;

“Just over half the residents interviewed would stay in their mobile homes even if  they had a chance to move to a bricks and mortar home
• Financial reasons were most important in choosing to live in a mobile home.  Some respondents could afford to buy a mobile home when they could afford  nothing else. Others – former owner/occupiers – could buy a mobile home and  retain a capital sum for income supplement without the need for a  mortgage.
• Retirement, ill-health and family change provided the spur for many to move  from a bricks and mortar house too large or unsuitable for their needs  and too big or expensive to keep clean and maintained.

Park Homes are well designed and compact, ideal for first-time buyers and more particularly attractive to the semi-retired, retired and the elderly
Park Home Estates provide a secure, managed environment
The homes provide good value for money and come fully furnished and equipped to individual taste
Mortgage facilities are available                                                                                                        They can appreciate in value akin to traditional property
Park Homes can be designed and adapted to suit almost any personal choices and are readily adaptable for disabled occupation
The environmental standards in new homes is very high, resulting in modest running costs, and sound sustainability credentials
Maintenance costs are also generally much lower than bricks and mortar”

Castle Point council have a less consistent approach to the inclusion of “park homes” in their housing supply figures depending on where the figures are being used. During development appeals they may suggest inclusion whilst the appellant may suggest exclusion.

CPBC’s position in September 2013 states;

“It is clear from both Census data and from Council Tax data that an increase in the availability of caravans for residential use resulted in an increased housing supply of the order of 800 homes in Castle Point in the period from 2001 to 2011. This increase was largely as a result of the change of use of Kings Park and Thorney Bay Caravan Parks from holiday use to residential use. To date, the Council has only included those caravans registering for Council Tax at Kings Park within the housing figures for the period 2001 to 2011. However, given that caravans at Thorney Bay were included as homes within the Census 2011 outcomes, and this will be reflected in population and household data moving forward, it is appropriate that the housing supply figures for the period 2001 to 2011 are appropriately adjusted to include these homes also.

However, should the Thorney Bay site not be redeveloped as proposed (bricks and mortar dwellings), then there is the potential for a further 800 caravans moving from transient use into permanent residential use.”

Whether or not, as in the case of those “park homes” at Thorney Bay, Planning Guidance would actively seek to site static caravans in a Flood Risk Zone 3 or within the close vicinity of a Top Tier COMAH site may be another matter.

Nevertheless, it is reasonable to expect in the light of this new initiative that, with over 1,000 of these units having been installed over recent years and in the process having increased the population of CANVEY ISLAND accordingly, that the Island’s housing supply numbers should reflect this development.

These facts must be conveyed to the cpbc Local Plan 2016 Examining Inspector, when he considers the housing supply record of Castle Point as a whole and CANVEY ISLAND in particular.

The Castle Point Borough Council planning Devil is in the Detail!

The devil is in the detail, is an idiom that Castle Point Council appear to rely on where development approvals on Canvey Island are concerned!

Far too often development proposal comments by consultees are taken at face value in the support of approval recommendations of the “professional” officers.

Rarely do development Committee members challenge the points of recommendation, simply because of a lack of alternative information.

Within proposal consideration for Calor and Oikos will often be the Health and Safety Executive comment; “Do not Advise Against”.

Within a recent appeal inquiry in Oxford a Do not advise against comment was made by the HSE in regard to a development near a Hazardous site.

However the local authority, UNLIKE Castle Point felt they should seek independent advice, rather than rely on untrained officers taking the HSE at their exact word. The advisor to the Oxford council considered that;

Do not advise against is not the same as saying planning permission must be granted. 

Overall the HSE methodology is designed to identify sites where the HSE feels obliged to advise against planning permission.

However, their only other advice category of do not advise against is not equivalent to supporting the application being granted.

As already established it is quite legitimate for a local planning authority to take a different view on the merits of granting planning permission, so long as the HSE’s advice has been taken into account.

That the HSE disputed some of the advisors comments, was not disputed, what is relevant is that the local authority had attempted to seek objective advice that may not be available amongst local authority officers.

The development in question, is in a less significant Flood Risk Area than that of Canvey Island.

The local authority in Oxford have a shortfall in housing land and under estimated their Objectively Assessed housing need, as is likely to be found in the case of Castle Point’s local plan 2016.

Despite this and the fact that the site in question was for a great deal fewer dwellings than in the case of Thorney Bay, the Oxford local authority turned down the application.

Castle Point of course have approved in principle outline permission for 600 dwellings, a residential institution plus the retention of static caravans and included these numbers within their daft New Local Plan and Local Plan 2016!

This despite the developer having relied on quoting the CPBC’s previous consideration: “The most recent Strategic Housing Land Availability Assessment (SHLAA) (2011)  indicates a potential range for dwelling units for the site between 378 and 595”

All based upon them achieving a “do not advise against” response from the HSE.

The Environment Agency acknowledge an agreement with Castle Point council in which Canvey is to be treated as a Special Case where Flood Risk and housing development needs for the whole Borough is concerned!

Canvey representatives really do need to start reading the SMALL PRINT where planning proposals are concerned!

  Footnote: Neither of the local Parish nor Town councils concerned in the Oxford case have given any indication that they intend to produce a Neighbourhood plan.  No evidence was submitted of any preliminary works in this regard.