Tag Archives: tidal flooding

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.

Advertisements

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!

This slideshow requires JavaScript.

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.

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.

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!

This slideshow requires JavaScript.

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!

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

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

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

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

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

 

sea wall damage

Previous damage acts as reminder of the Tidal power.

 

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

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

The EA warns;

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

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

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

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

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

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

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

Neither Tidal nor Surface Water Flood Risk a Constraint on Development, where Castle Point Council are concerned!

The issue of potential Flooding remains a Hot Topic. That is as it should be, however as we have seen within Castle Point Council it only acts as a Development Constraint verbally, rather than effectively.

The responsibility on Flood Risk should fall squarely on the shoulders of council members, but other interests and “fear” of scaremongering, in effect mean that Flood Risk as a Constraint on Development is disregarded.

Floods 2014 pic via Police Helicopter

View of Canvey Island flooding from Police Helicopter July 2014

The Environment Agency adopt a position where residents safety over the lifetime of a new development is left to council members, Canvey Island and mainland residents Representatives.

The EA consider;

“The site is currently protected by flood defences so is not at risk of flooding in the present-day 0.0% (1 in 1000) annual probability flood event. The defences will continue to offer protection over the lifetime of the development, provided that the TE2100 policy is followed and the defences are raised in line with climate change, which is dependent on future funding.” 

The Island’s Flood Risk Assessment confirms over topping will be a concern prior to the year 2100!

There are no guarantees of this future funding and residents may be surprised to know that much of this funding must be raised locally. Councillors should be in a position to inform us of the sources of this funding and of the avenues in place for the collection of these monies, if they are confident that the sea defences will receive the necessary improvements so as to have confidence any new builds that they approve, will be safe over its Lifetime!

The EA give further warning;

“Although Canvey Island is defended to a high standard of protection, it is at risk should there be a flood defence failure” 

Of course the official position of cpbc appears to be that as long as there is space provided for safe refuge areas above the ground floor, development is acceptable.

A somewhat contradictory position in respect that if Canvey Island could not Flood, the safe refuge requirement would be un-necessary.

Government and Defra continue to fumble about giving residents no security whilst planners and developers take advantage of the lack of a clear position.

The BBC Report;

The Commons environment committee said ministers were not addressing what it called the fragmented, inefficient and ineffective flood management.

Areas of concern include flood impact home insurance, building rules and local authority planning decisions.

The government rejected the criticism, saying it had accepted many previous suggestions on flooding from the MPs.

The committee’s comments are the latest in a running tussle between MPs and the environment department Defra.

 The MPs admit that flooding has risen up the government’s priority list, and say “considerable work” on flooding is being done across Whitehall. But they complain that ministers are still ignoring reasonable demands.

Jim Fitzpatrick MP, acting chair of the Environment, Food and Rural Affairs Committee (Efra), said: “People living in areas of flood risk need to be reassured that the government is acting to improve our disjointed flood management system.

“Defra has failed to give sufficient justification for its rejection of our recommendations for important new measures.”

Continued development also increases pressure on Canvey Island’s drainage system, already capable of failure through misuse and lack of maintenance. Housing and Business development means Roads, Parking areas and hard impermeable surfaces intensify this issue as development approvals continue unabated.

This move to develop more and more areas of grass land on Canvey must be considered in the light of it inevitably increasing the likelihood of Surface Water Flooding, a warning of this issue is contained in a Research paper by Dr David Kelly. Its relevance to Canvey Island should be considered Striking!

It should be remembered that, whilst the sea defences have some ability to stop the Tide from over topping, they have absolutely no effect in stopping the Tidal Water from penetrating the ground from beneath, and causing flooding and a High Water Table by that means!

Impact of paved front gardens on current and future urban flooding” Research Paper by Dr D.A.Kelly

The proliferation of paved gardens is putting the UK’s towns and cities at greater risk of flooding and, by 2080, the UK’s urban drainage system could be overwhelmed by ‘runoff’ equivalent to the volume of up to 100 Olympic-sized swimming pools.  

The potential impact that paved gardens could have on urban flooding in Edinburgh, Exeter, Manchester and London by 2050 and 2080 was examined by Dr David Kelly, associate professor in Heriot-Watt’s Water Academy. 

Many gardens in the UK have been paved by homeowners who want low maintenance gardens or off-street parking. Covering traditional gardens with hard paving, and the subsequent loss of green vegetation, reduces the amount of rainfall that can be dealt with naturally and significantly increases the rate and volume of runoff flowing to surface water drainage systems. 

Dr Kelly applied projected rainfall intensities for each of the four UK cities to simulated front gardens that reflect the trends for paving. 

Calculating the runoff contribution from new and existing paved gardens will help planners and policy makers identify areas of risk in their town and city – and decide whether to call for homeowners to depave. Additionally, data of runoff from individual paved gardens could highlight the need for behaviour change, and help encourage homeowners to take action themselves by depaving their gardens and enhancing green vegetation.

Dr Kelly, assistant professor in Heriot-Watt University’s Water Institute said: “Domestic front gardens cover almost 30% of our urban space and play a vital role in managing surface water runoff in towns and cities. 

“Existing urban drainage systems will be inadequate to cope with the level of increased runoff from paved front gardens. With runoff from all impermeable surfaces, including paved front gardens, likely to increase in future due to urban densification, the risk of urban flooding will increase unless substantial efforts are made to minimise runoff.”

Homeowners and policymakers need to focus on depaving gardens across the UK.

Dr Kelly’s research showed that the collective runoff by the 2080s from front gardens alone is expected to increase by substantial amounts during extreme storm events due to climate change. 

“In Edinburgh, considering only gardens that are currently at least three-quarters paved, during just one storm, runoff could increase to 29,000m3 across the city, equivalent to 12 Olympic swimming pools, by 2080.”  

“In London, the volume of runoff could increase up to as much as 278,000m3 (equivalent to 100 Olympic swimming pools). ” 

“But, if all of these gardens were depaved and had zero impermeable cover, then the runoff could almost be eliminated, particularly if combined with enhanced green vegetation solutions.”

 D.A.Kelly’s research paper; “Impact of paved front gardens on current and future urban flooding” can be found HERE

The full BBC Environment Parliamentary Report can be found HERE.