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CASTLE POINT BOROUGH COUNCIL LOCAL DEVELOPMENT FRAMEWORK (LDF) NOTICE OF THE PUBLICATION OF THE CASTLE POI NT BOROUGH LOCAL DEVELOPMENT FRAMEWORK CORE STRATEGY (FINAL PUBLICATION DOCUMENT) Planning and Compulsory Purchase Act 2004 Regulation 27 of the Town and County Planning (Local Development) (England) (Amendments) Regulations 2008 Castle Point Borough Council has prepared a Core Strategy Final Publication Document (DPD) as part of its Local Development Framework which it proposes to submit to the Secretary of State under Section 30 of the above Act. The Core Strategy is the main overarching document of the Castle Point Local Development Framework. The Final Publication Document sets out the Council’s strategy for development in the borough up until 2026 and will determine how our employment, housing and infrastructure requirements will be achieved. The Core Strategy Final Publication Document (DPD) and accompanying documents have been published in order for representations to be made prior to the submission of the Core Strategy to the Secretary of State. The period for representations to be made is from 9am on Friday 13th November until 5pm on Monday 11th January 2010. Representations received during the period will be considered alongside the submitted DPD, which will be examined by an independent Planning Inspectorate. The purpose of the examination is to consider whether the LDF Core Strategy complies with the legal requirements and is ‘sound’ against the tests of soundness. The Core Strategy Final Publication Document (DPD) and accompanying documents can be viewed along with a statement of how to make representations within the Local Development Framework section of the Council’s website at http://limehouse.castlepoint.co.uk/portal and, during normal opening hours, at the following locations:

Council Offices, Mon-Thu: 8.45am - 5.15pm Kiln Road, Benfleet Fri: 8.45am - 4.15pm

Council Cash Office, Mon- Fri: 9.00am - 1.30pm Sydervelt Road, Canvey Island

South Benfleet Library, Mon: 2.00pm - 6.00pm 264 High Road, Benfleet Tue: 9.00am - 1.00pm Wed: 9.00am - 7.00pm Fri - Sat: 9.00am - 5.00pm

Canvey Library, Mon - Tue: 9.00am - 6.00pm High Street, Canvey Island Wed - Thu: 9.00am - 5.00pm Fri: 9.00am - 6.00pm Sat: 9.00am - 5.00pm Sun: 11.00am - 2.00pm

Tarpots Library, Mon: 9.00am - 2.00pm 127 London Road, Benfleet Tue: 9.00am - 5.00pm Thu: 9.00am - 6.00pm Fri: 1.00pm - 5.00pm Sat: 9.00am - 5.00pm

Hadleigh Library, Mon - Tue: 9.00am - 7.00pm 180 London Road, Hadleigh Thu - Fri: 9.00am - 7.00pm Sat: 9.00am - 5.00pm

Representations must be returned to Castle Point Borough Council by 5pm on Monday 11th January 2010. Representations should be made on the official representation form. They may be submitted in the following ways: • Online at http://limehouse.castlepoint.co.uk/portal • By e-mail to [email protected] or • In writing to the Corporate Policy, Castle Point Borough Council, Kiln Road, Benfleet, Essex, SS7 1TF. All representations will be made publicly available unless requested otherwise. The Council will notify all people making representations of the submission and adoption of the Core Strategy Final Publication Document DPD unless requested otherwise. 13th November 2009 Assistant Chief Executives Directorate Castle Point Borough Council Council Offices, Kiln Road, Thundersley, Benfleet, Essex SS7 1TF Tel: 01268 882200 Fax: 01268 882455 DX: 39603 Hadleigh Head of Planning East of England Regional Assembly Date: 11th November 2009 Flempton House Flempton Please Contact: Bury St Edmunds Amanda Raffaelli Suffolk Senior Planning Officer P28 6EG Email: [email protected] Tel: 01268 882384

Dear Sir/Madam,

Regulation 29 of The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 – Castle Point Borough Council Core Strategy conformity with Regional Spatial Strategy at pre-submission stage

Castle Point Borough Council has published its Core Strategy Final Publication Document for pre- submission consultation under Regulation 27 of The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008. The period for representations to be made is from 9am on Friday 13th November 2009 until 5pm on Monday 11th January 2010.

A copy of the document is enclosed. Other supporting documents are available to view via the Council’s website at www.castlepoint.gov.uk. Hard copies of the document are also available to view at the following inspection points:

Council Offices, Mon-Thu: 8:45am – 5:15pm Kiln Road Benfleet Fri: 8:45am – 4:15pm Council Cash Office, Mon- Fri: 9:00am – 1:30pm Sydervelt Road, Canvey Island South Benfleet Library, Mon: 2:00pm – 6:00pm 264 High Road, Benfleet Tue: 9:00am – 1:00pm Wed: 9:00am – 7:00pm Fri – Sat: 9:00am – 5:00pm Canvey Library Mon – Tue: 9:00am – 6:00pm High Street, Canvey Island Wed – Thu: 9:00am – 5:00pm Fri: 9:00am – 6:00pm Sat: 9:00am – 5:00pm Sun: 11:00am – 2:00pm Tarpots Library Mon: 9:00am – 2:00pm 127 London Road, Benfleet Tue: 9:00am – 5:00pm Thu: 9:00am – 6:00pm Fri: 1:00pm – 5:00pm Sat: 9:00am – 5:00pm Hadleigh Library Mon - Tue: 9:00am – 7:00pm 180 London Road, Hadleigh Thu – Fri: 9:00am – 7:00pm Sat: 9:00am – 5:00pm

All representations received during the consultation period will be considered alongside the submitted Core Strategy, which will examined by an independent Planning Inspector. The purpose

of the examination is to consider whether the Core Strategy complies with legal requirements and is “sound” when considered against the tests of soundness set out in PPS12.

Representations that are submitted to the Council that do not relate to soundness or legal compliance will still be passed on to the Planning Inspectorate but they are unlikely to be as effective. In order to ensure that representations contain all the information the Planning Inspectorate requires, it is recommended that the official representation form is used.

The quickest and easiest way to view the Core Strategy Final Publication Document and submit representation is online at http://castlepoint.limehouse.co.uk/portal

Representations can also be sent to:

• Email: [email protected] • In writing: Corporate Policy, Castle Point Borough Council, Kiln Road, Benfleet, SS7 1TF

The formal consultation period ends at 5.00pm on 11th January 2010. In accordance with Regulation 29 of The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 I hereby request for the opinion in writing of the East of England Regional Assembly as to the general conformity of the Core Strategy Final Publication Document with the Regional Spatial Strategy. I would be grateful if you could respond in accordance with the provisions of the Act.

Please do not hesitate to contact me if you have any queries about the contents of this letter and the enclosed documentation. I look forward to receiving your response by the 11th January 2010.

Yours faithfully,

Amanda Raffaelli Senior Planning Policy Officer

Castle Point Core Strategy Consultees – Regulation 27

The following groups have been sent a consultation notification letter regarding the Core Strategy:

¾ All residents and local resident groups who have previously responded to Core Strategy consultations;

¾ All businesses who have previously responded to Core Strategy consultations;

¾ All landowners/developers who have previously responded to Core Strategy consultations;

¾ All interest groups who have previously responded to Core Strategy consultations;

¾ Local service providers and partners who are members of the LSP but not identified as statutory consultees;

¾ All Statutory Consultees as identified in the Town and Country Planning (Local Development) (England) Regulations 2004 as amended. These are listed below:

• East of England Regional Assembly (Helen De La Rue) • East of England Development Agency (Natalie Blaken) • Essex County Council (Roy Lewis) • Basildon District Council (Matthew Winslow) • Medway Council (Chief Planner) • Rochford District Council (Sam Hollingsworth) • Southend‐on‐Sea Borough Council (Matthew Thomas) • Thurrock Borough Council (Richard Hatter) • Canvey Island Town Council (Town Clerk) • Rayleigh Town Council (Town Clerk) • Port of London Authority (James Trimmer) • Natural England (Jonathan Bustard) • English Heritage (Katherine Fletcher) • Environment Agency (Carrie Williams) • Highways Authority (Chris Shaw) • Department for Transport – Railways (John Ashley) • Coal Authority (Chief Planner) • Mobile Operators Association on behalf of Mobile Operators • Essex Police Authority (Keith Garnish) • South East Essex Primary Care Trust (Ray Parker) • EDF Energy (Peter Bennett) • National Grid Gas • Anglian Water (Sue Bull) • Essex and Suffolk Water • Homes and Community Agency (Rob Moore, Dan Myers) • Kent County Council • South East England Regional Assembly

Additionally, whilst not listed in the regulations we have also consulted with the Health and Safety Executive, as there are two COMAH Sites in the Borough and a further COMAH site whose consultation zone enters into the borough area. Castle Point Borough Council Core Strategy Final Publication Document (DPD) Submission Stage Representation Form

In completing this representation form, you are providing a formal consultation response under Regulation 27 of the Town and Country Planning (Local Development)(England) Regulations 2008 with regard to the Castle Point Core Strategy Final Publication Document DPD.

Please complete separate copies of pages 3 and 4 of this form for each section, policy, table or diagram against which you wish to comment.

If you believe that a section, policy, table or diagram is unsound with regard to more than one test of soundness please provide a separate representation for each test.

The Tests of Soundness

Soundness is explained in PPS12 (Planning Policy Statement 12) in paragraphs 4.36 – 4.47, 4.51 and 5.52 and the boxed text. Specifically paragraph 5.52 states that to be sound a core strategy should be:

1) Justified PPS12 provides that to be ‘justified’ a DPD (in this case ‘The Core Strategy’) needs to be: • founded on a robust and credible evidence base involving: o evidence of participation of the local community and others having a stake in the area o research/fact finding – the choices made in the plan are backed up by facts • the most appropriate strategy when considered against reasonable alternatives

2) Effective PPS12 states that core strategies should be effective. This means: • Deliverable – embracing:

• Sound infrastructure delivery planning

• Having no regulatory or national planning barriers to delivery

• Delivery partners who are signed up to it • Coherence with the strategies of neighbouring authorities • Flexible • Able to be monitored

3) National Policy The DPD (In this case ‘The Core Strategy’) should be consistent with national policy. Where there is a departure, The LPA (Local Planning Authority) must provide clear and convincing reasoning to justify their approach.

Completed representation forms must be returned to the Council by 5pm on Monday 11th January 2010.

Email to: [email protected]

Post to: Corporate Policy, Castle Point Borough Council, Kiln Road, Benfleet, SS7 1TF

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Contact Details (only complete once)

Please provide contact details so that the Council and the Programme Officer can contact you with regard to your consultation response during the examination period.

Personal Details Agents Details (if applicable)

Title

First Name

Last Name

Job title (where relevant)

Organisation (where relevant)

Address Line 1

Address Line 2

Address Line 3

County

Postcode

Telephone No.

Email Address

Reference No. Do Not Complete Do Not Complete (for official use only)

You only need to complete this page once. If you wish to make more than one representation, attach additional copies of pages 3 and 4 to this part of the representation form.

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Rep Ref No:

For Official Use Only

Please identify the part of the Core Strategy to which this representation refers:

Section No. Policy No. Table No. Diagram No.

You must complete a separate representation as per pages 3 and 4 of this form for each section, policy, table or diagram on which you wish to comment.

Question 1: Previous Representations

a) Did you raise the matter that is the subject of your representation with the LPA earlier in the process of the preparation of the Core Strategy i.e. before it was approved for examination?

Yes… No…

b) If yes, please indicate the date of this submission and the reference number provided. (If you can’t remember exact information don’t worry, just a rough date will help us find you previous representations.)

c) If no, can you briefly explain why you did not do so?

Question 2: Soundness of the Core Strategy a) Do you consider the Core Strategy to be:

Sound (i.e. you support the Core Strategy) Unsound (i.e. you consider the Core Strategy should be changed)

b) If you consider the Core Strategy is unsound, please identify which test of soundness your representation relates to. (Please note you should complete separate pages 3 and 4 of this form for each test of soundness the Core Strategy fails.)

Justified (Please identify just one test for this representation) Effective Consistent with National Policy

c) Please give details of what change(s) you consider necessary to make the Core Strategy sound, having regard to the test you have identified above. You will need to say why this change will make the Core Strategy sound. Please be as concise and precise as possible. (see box on page 4)

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Answer for 2c

Question 3: Further Representations

a) Can your representation seeking a change be considered by written representations, or do you consider it necessary to participate at the oral part of the examination?

Written Representations Attend Examination

b) If you wish to participate at the oral part of the examination please outline why you consider this to be necessary:

Representation Submission Acknowledgement

I acknowledge that I am making a formal representation under Regulation 27 of the Town and Country Planning (Local Development)(England) Regulations 2008. I understand that my name (and organisation where applicable) and representation will be made publicly available during the public examination period of the Core Strategy in order to ensure that it is a fair and transparent process.

I agree with this statement and wish to submit the above representation for consideration

Signed……………………………………………………… Dated………………………………………..

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The Core Strategy Public Consultation The Council has prepared a plan setting out proposals for the future development of Castle Point 9am on 13th November until 9am on 11th January 2010

2,500 new jobs and 5,000 new homes Delivering community facilities, better streets, open spaces and transport, whilst protecting the natural environment and heritage

To have your say on whether the Council’s Core Strategy is ‘sound’: Visit www.castlepoint.gov.uk Phone the Council on: 01268 882200 Visit/write (official response form only) to the Council Offices at Kiln Road, Benfleet, SS7 1TF Visit your Local Library Core Strategy Final Publication Document (Regulation 27) Consultation Responses with Council Comments – Document Order

Table Key: Column 1 Representation ID

Column 2 Document Section

Column 3 Consultee Information

Column 4 Agent Information

Column 5 Sound or Unsound (S or U)

Column 6 Test of Soundness (E – Effective, J – Justified, N – Consistent with National Policy)

Column 7 Representation

Column 8 Examination or Written Representations (E or W)

Column 9 Reason for Examination

Column 10 Council’s Response to Representation

1 2 3 4 5 6 7 8 9 10

6 Core Strategy Final Paul Elliot S The Health & Safety Executive has no specific comments to make and we have noted the various No response necessary. Publication Document Health and Safety mention of policies in relation to the hazardous installations in Castle Point's administrative Executive boundary. 7 Core Strategy Final Mr Philip Hirst S BPA request that the rights of statutory consultation on all planning matters are maintained within our No response required. Publication Document BPA Limited pipeline Area of Interest or easement. 8 Core Strategy Final Miss Rachael Bust S Having reviewed your document, I confirm that we have no specific comments to make on this No response required. Publication Document The Coal Authority document at this stage. 20 Core Strategy Final Helen De La Rue U E Most agricultural land in Castle Point is classified as Grade 3 and below. The Core Strategy should E All land used for agricultural purposes is located in the Green Belt, and as Publication Document East of England support enhancing the quality of soils and agri-environment schemes. such there is a presumption against development. None of the proposed Regional Assembly Green Belt development sites are agricultural land and therefore existing agricultural land is protected from development. It is not considered that the improvement of soil resources is a strategic matter to be addressed in the Core Strategy.

It is the intention of the Council to address the specific and positive uses of the Green Belt and the landscape through the Benfleet, Hadleigh and Thundersley Plan and the Canvey Area Action Plan. The Core Strategy is considered sound as the issue raised is a matter of detail that will be addressed in another DPD/s. 26 Core Strategy Final Helen De La Rue U E The Castle Point Borough Council Core Strategy Further Preferred Options Consultation Document E No response required as issues are dealt with in correct place throughout Publication Document East of England is in general conformity with the East of England Plan. document. Regional Assembly The degree to which the Core Strategy is in conformity with the Plan is compromised by policy deficiencies on sustainable construction, energy efficiency, renewable energy targets, and waste management. In addition, there is no policy for conservation of agricultural lands and soil, and the Core Strategy does not appear to have addressed freight movement and the potential impacts from the development of the London Gateway Port. 33 Core Strategy Final Mrs H Howard U J The Core Strategy questionnaire was not distributed widely enough across the local community. In W The consultation questionnaire for the Core Strategy was distributed to all Publication Document particular, the areas that will be most impacted by house building on Canvey Island, i.e. The Dutch households in Castle Point using the household list from the electoral Village and Charfleets residential area. The questions were engineered to result in a response that register. It was distributed with an 8 sided A4 leaflet summarising the Core matched the proposals being put forward by CPBC. There was no alternative site offered to the local Strategy. It was posted in envelopes clearly market with the Council logo community who did receive the questionnaire, when a reasonable alternative ('The Triangle' West of and stating that important information was enclosed. The Council is Canvey Road) would have been, and still is a viable option. The response box was limited to 150 confident that the consultation was therefore wide reaching and extended words, which again on a matter of such importance, seems restrictive to full and balanced far beyond that required by the regulations. participation by all parties. The response back indicated clear dissatisfaction for additional housing on The Sustainability scoring for three areas considered initially for house building on Canvey Island Canvey Island - it is considered unlikely that the alternative location to the was not consistent. The three areas this relates to being, A) land East of Canvey Road, B) land West west of Canvey Road would have triggered fewer objections given that of Canvey Road 'The Triangle' and C) land west of Canvey Road 'Garden World'. All three sites sit most people were concerned with the impact on infrastructure and the loss within the same area, however the sustainability scoring for A) and C) was biased towards the of open space/green belt. Alternatives had been considered during earlier positives only, resulting in high scores, while B) scoring was biased towards the negatives only, rounds of consultation, with the sustainability assessment of sites itself resulting in low scores. When the truth is that all three sites when looked at impartially would have

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received similar scoring, and it could be argued that site C) and B) would both score higher than A). subject to consultation (August 2008).

The reasonable alternative has not been given fair consideration by CPBC, which resulted in it not The consultee believes that the evidence base for selecting the east of being offered as an alternative choice for the local community of Canvey Island to review and Canvey Road site over the west of Canvey Road (Triangle) Site as comment on in the Core Strategy questionnaire. unsound because they should have received similar scores. However, both the initial sustainability assessment and the review of the sustainability assessment (2009) found that there were issues with the West of Canvey Road (Triangle Sites) that made it less sustainable. Concerns include:

1) Ancient Landscape Designation.

2) Adjacent to Local Wildlife Site.

3) Used for agricultural purposes.

4) Separated from the remainder of the urban area by a busy road (community cohesion and access/road safety issues).

5) Significant and highly visual incursion into the Green Belt.

The East of Canvey Road site does not have these concerns. The west of Canvey Road Frontage meanwhile is previously developed land, and with the exception of point 4 is considered to not carry the same concerns as the Triangle land to the west.

As a result it is considered that the Core Strategy is justified in not including the West of Canvey Road (Triangle) Site for housing development. 34 Core Strategy Final Mr Daren Howard U J The sustainability scoring for 3 sites, 1. Land East of Canvey Road, 2. Land West of Canvey Road W The consultation questionnaire for the Core Strategy was distributed to all Publication Document (Garden World) and 3. Land West of Canvey Road ('The Triangle') was not impartial, it was households in Castle Point using the household list from the electoral subjective. All 3 sites sit within close proximity of each other, however the sustainability scoring register. It was distributed with an 8 sided A4 leaflet summarising the Core differed immensely between sites 1./2. and site 3. This is especially apparent when considering site Strategy. It was posted in envelopes clearly market with the Council logo 2. which sits within the whole of site 3. Also where site 1. is a complete Greenfield site, where as site and stating that important information was enclosed. The Council is 3. already has residential and business development already present on the site and further confident that the consultation was therefore wide reaching and extended development would have minimal impact on local residents. far beyond that required by the regulations.

This biased sustainability scoring resulted in the Core Strategy questionnaire offering no alternative The response back indicated clear dissatisfaction for additional housing on to the proposed development of the Land East of Canvey Road, which the local community are Canvey Island - it is considered unlikely that the alternative location to the opposed to. When a perfectly suitable, and could be argued more acceptable alternative is available west of Canvey Road would have triggered fewer objections given that ('The Triangle'), but was not made aware to the community, and if had been would have resulted in a most people were concerned with the impact on infrastructure and the loss different outcome. of open space/green belt. Alternatives had been considered during earlier rounds of consultation, with the sustainability assessment of sites itself subject to consultation (August 2008). The Sustainability scoring needs to be looked at independently, and questions asked how such a vast difference between sites 1./2. and site 3. came about and was justified. The consultee believes that the evidence base for selecting the east of Canvey Road site over the west of Canvey Road (Triangle) Site as The questionnaire was a last minute after thought, which CPBC didn't intend to ever hold, and only unsound because they should have received similar scores. However, both succumbed to organise it after considerable pressure was put upon them. It resembled junkmail, was the initial sustainability assessment and the review of the sustainability very limited in detail and space for responses, which summed up CPBC importance of the process, assessment (2009) found that there were issues with the West of Canvey and how much notice they were going to hold by it. Considering the number of years this Strategy Road (Triangle Sites) that made it less sustainable. Concerns include: has been in process, the impression given by the Councils handling of the local residents input to it is shown to be very poor. The impression given is that the Council had a plan they wanted implemented, and were just going through the motions where the community was concerned, as 1) Ancient Landscape Designation. they were for alternative sites as highlighted above. 2) Adjacent to Local Wildlife Site.

3) Used for agricultural purposes.

4) Separated from the remainder of the urban area by a busy road (community cohesion and access/road safety issues).

5) Significant and highly visual incursion into the Green Belt.

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the Triangle land to the west.

As a result it is considered that the Core Strategy is justified in not including the West of Canvey Road (Triangle) Site for housing development. 79 Core Strategy Final Mr Richard Inman S We recommend you review the entire document once more, before publication, and take the W Minor amendments proposed to deal with editorial issues. Publication Document GO-East opportunity to apply some quality assurance to the editorial.

In summary, we think the proposed Core Strategy is thorough and detailed. It relates well to the East of England Plan. You have adopted much of the advice and guidance made by my colleagues on earlier drafts. We are pleased that you commissioned an independent assessment of the Core Strategy's soundness. Similarly, we are pleased to see the comprehensive evidence put forward in support of the Core Strategy, and the Sustainability Appraisal prepared by Baker Associates.

The unique circumstances of Canvey Island are challenging. You should satisfy yourself that the Core Strategy proposals are acceptable to the Environment Agency. If you feel an exploratory meeting would be useful, we will be happy to broker a discussion. 125 Core Strategy Final Mr Richard Inman S The MAFF Agricultural Land Classification maps suggest there is little or no higher grade agricultural W All land used for agricultural purposes is located in the Green Belt, and as Publication Document GO-East land (Grades I, II and III) within Castle Point borough. The maps do not distinguish between Grades such there is a presumption against development. None of the proposed III and IIIa. Green Belt development sites are Agricultural land.

130 Core Strategy Final Mr Richard Inman U E Glossary of terms would be useful - to include: LOTS; SEMS; LIFT; PCT; SEEVIC; BSF; CPRC; W Glossary to be prepared. Publication Document GO-East CPBC; SPA; lpppd; BREEAM;

141 Core Strategy Final Mr Simon Hart S E As a member of Castle Points Daws Heath No response required. Publication Document Road Residents, who live in an area which has now been removed from the published Core

Strategy as a source of Greenbelt land to support the forced housing quota's, I wish to ensure that the people of Daws Heath and Castle Point who have fought for it removal are represented.

This part of Castle Points Greenbelt has been recognised as some of the Boroughs most important due to its position, as a green barrier separating villages and Boroughs and preventing Urban Sprawl. Most Councillors agree and this was also the outcome of the special PDG Group who made recommendations for the final Core Strategy document that this Greenbelt land North of Daws Heath road is true Greenbelt by definition.

There has been massive pressure from the developer wanting to build houses on this Greenbelt location North of Daws Heath road using the Thames gateway project as a means of converting Greenbelt into a housing estate, despite Councillors and residents from all over the Borough objecting to it, and to this date developers have met with Castle Point Officers for pre application meetings and have continued their predevelopment preparation by undertaking wildlife and road surveys to speed up any future applications.

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Housing quotas have been set far too high so forcing some housing development to be built on Castle Points Greenbelt and as the forward of this document states Castle Point is a great place to live and everyone who Lives, Works or Represent Castle Point should fight to save this image. 288 Core Strategy Final Dr Philip Pearson U E The need to ensure that renewable energy projects are appropriately sited W PPS22 is clear that proposals for specific renewable energy schemes Publication Document RSPB should only be included in planning policy where there is known interest from the energy industry. This is not the case in Castle Point. The RSPB is supportive of renewable energy projects, providing that adverse impacts upon wildlife are avoided by appropriate siting and design. Renewables offer an opportunity to modify or reverse the deleterious changes associated with climate change arising from an over-reliance upon fossil Equally PPS22 is clear that policies restricting renewable energy schemes fuels. should also not be included in planning policy documents.

The available evidence suggests that renewables, notably wind energy, pose three main problems As a result, the Core Strategy includes policies CP2 and DC15 both of for birds: disturbance, habitat loss or damage, and collision. Birds may be scared away by which expect the impact on the natural environment to be taken into construction noise, vehicle movements, or the presence of operating turbines. Additionally account when considering applications for development. Renewable construction may physically destroy bird's feeding, breeding or roosting sites. There is also the risk energy schemes would need to meet this requirement and therefore the that birds may fly into new structures, especially turbines, and be killed or injured; storms or Core Strategy is considered sound and effective in respect of the issue conditions of poor visibility will increase the likelihood of this occurring. Consequently, given the raised by this representation. important bird populations that the area supports, any renewable energy project must be carefully assessed to not cause an adverse effect to SPAs. We strongly recommend that the policy or supporting text clearly state that adverse effects to Natura 2000 sites must be avoided and any projects that cannot avoid an adverse effect will not be permitted. 291 Core Strategy Final Mr Johnathan S Overall, Natural England considers that the Core Strategy as informed by supporting documents W No response required. Publication Document Bustard (including Habitats Regulations Assessment) is both legal and sound as far as our remit is NATURAL concerned (biodiversity, landscape, access and recreation). Notwithstanding this assessment, we ENGLAND consider it appropriate to make the following comments, and believe that the Core Strategy could be further improved by occasional rewording for the sake of clarity. We also note that certain other plans and projects within the Local Development Framework will also be subject to their own detailed assessments, particularly the proposed Habitats Regulations Assessment for the Canvey, and Benfleet Hadleigh and Thundersley Area Action Plans. This also applies to projects covered by policy CP3 ‘Delivering Sustainable Transport Infrastructure.'

Natural England is pleased that many of our previously suggested changes have been incorporated within the Core Strategy Final Publication Document (ref. our consultation response to the Proposed Publication Document dated 23 March 2009), and we also note that the findings of the Habitats Regulations Assessment have influenced the final document. 331 Core Strategy Final Mr Roy Lewis U E The London 2012 Olympic Games Mountain Biking Event E Essex County Council would wish to attend the Minor Amendments have been made as suggested to ensure that the Publication Document Essex County oral part of the examination to further elaborate Olympic opportunity is correctly referenced throughout the document. Council its representations on the Core Strategy; to The references to the London 2012 Olympic Games Mountain Biking Event within the Core Strategy provide the wider sub-regional/ regional context are supported. The event and its legacy would provide recreational, employment and other benefits for matters included within the Core Strategy; within the Borough within the plan period. Essex County Council supports the encouragement of and to provide technical assistance on matters opportunities for outdoor recreation at Hadleigh Farm. In partnership with The Salvation Army and in relating to delivery of County Council services. consultation with the local community, the County Council is working to build a sustainable legacy plan which maximises the social and physical activity legacy from the event.

The London 2012 Mountain Biking Event will provide opportunities for local job creation in relation to the visitor services supporting the event outside of the venue. In addition the profile of the event provides opportunities to highlight investment opportunities both locally and in the wider Thames Gateway therefore supporting regeneration and economic development. In the longer term the legacy from the event has the potential to strengthen the local visitor economy through enhancing the opportunities for outdoor recreation and attracting more visitors to the Borough.

On a technical point, however, the name of the approved venue for the London 2012 Olympic Games Mountain Biking Event is Hadleigh Farm and not Hadleigh Country Park/Hadleigh Castle Country Park. Whilst the Country Park will be affected by the event, the venue itself will mainly be on The Salvation Army land, Hadleigh Farm, to the east of the Country Park. The Salvation Army is a partner in the delivery of the event and its legacy. The document should be amended to ensure that,

• the correct name of the venue is used; • references to "the Salvation Army" are corrected to reflect the organisation's official title, The Salvation Army; and, • references to the "Olympic mountain biking venue" are refined to reflect the London 2012 Olympic Games mountain biking venue.

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Set out below are suggested amendments to reflect the above points,

• Table 2, A Portrait of Castle Point; Leisure and Recreation, Characteristic - the second sentence of the third paragraph should be deleted and replaced by the following text, ‘Hadleigh Farm, together with a part of Hadleigh Country Park, is the venue for the cross country mountain biking event for the London 2012 Olympic Games, and will become world renowned during the plan period.'

• Paragraph 4.3 - the fourth paragraph of the spatial vision should be amended so that its opening statement reads, ‘There will be new recreational opportunities; Hadleigh Farm will be a first class Olympic standard mountain biking venue for the London 2012 Olympic Games ...'

• Paragraph 5.20 - the final two sentences should be deleted and replaced by the following text, ‘In Hadleigh, Hadleigh Farm will host the London 2012 Olympic Mountain Biking Event. The hosting of the event will include improvements to the Country Park and the event will provide opportunities to create a legacy of enhanced leisure and recreational opportunities in the area, in partnership with The Salvation Army.'

• Policy SS2, Table 4, Benfleet Hadleigh and Thundersley, Sustainable Growth and Environmental Conservation - the second bullet should be deleted and replaced by the following text, ‘Beyond those locations Green Belt will be maintained and protected. Sites of ecological importance will be protected and enhanced and opportunities for recreation will be encouraged, particularly in relation to the legacy that will be created surrounding the London 2012 Olympic Games Mountain Biking Event at Hadleigh Farm."

• Paragraphs 6.15, 6.16, and 6.17 - the text of the paragraphs should be revised to acknowledge that Essex County Council is committed to ensuring that the plans for the London 2012 Olympic Games event take full regard of all natural habitats and wildlife and as such all plans will be informed by an environmental impact assessment and developed in consultation with all statutory consultees.

• Table 6 - the first bullet for Benfleet, Hadleigh and Thundersley should be deleted and replaced by the following text, ‘Development of Hadleigh Farm as the London 2012 Olympic Games Mountain Biking Venue'.

• Policy CP2 - paragraph 1, bullet 6, should be deleted and replaced by the following text, ‘Development of Hadleigh Farm as the London 2012 Olympic Games mountain biking venue with a recreation legacy,'.

• Paragraph 6.48 - the final sentence should be deleted and replaced by the following text, 'The mountain biking event for the 2012 Olympics at Hadleigh Farm will create additional jobs related to leisure and recreation in Hadleigh'.

• Table 10, final item - the text in respect of ‘Project' and ‘Delivery Authority' should be deleted and replaced by the following text, • o Project - Hadleigh Farm London 2012 Olympic Games Mountain Biking Venue • o Delivery Authority - Essex County Council in Partnership with The Salvation Army and Castle Point Borough Council.

355 Core Strategy Final Cllr Martin Tucker U J Castle Point Borough Council's failure to appropriately distribute the needs of the borough has lead E As elected representatives of Castle Point With regard to commercial development on Canvey Island, the Island is Publication Document Canvey Island to the proposed delivery of an unsustainable proportion of new housing development on Canvey Borough Council residents, and with multiple served by two single carriageway roads that provide access to the Island at Independent Party Island. representations made for consideration, CIIP Waterside Farm. The road from Waterside Farm to the existing and would like to participate at the oral part of the proposed industrial area is dual carriageway. There are approved plans to examination to justify and clarify the document extend the road network in this location to the south of the industrial area, Canvey Island has many problems to solve, none of which have been addressed in the CS. CPBC submitted in response to the Core Strategy. improving access and allowing for long-term employment land to be has decided to place all of the future commercial development on an island with very limited access developed. The industrial area is therefore well served by the road network. to main roads and no onward route. Furthermore, the levels of unemployment and potential economic activity are greater on Canvey Island than on the mainland. Placing commercial It is accepted that housing development on brownfield sites and in town centres enables sustainable development close to where people live provides the opportunity for people growth; however, proposed development on green belt land is caused purely by a lack of good to work close to where they live, consistent with PPS1 and PPG13. research and community engagement. For Castle Point to fulfil its role within the sub-region, it is required to house its residents, and remain a green area - at the centre - of a network of green With regard to Green Belt development, the SHLAA, underpinned by a spaces. To replace green space with housing is not only unsustainable, but unsuitable for Castle thorough street level survey of the urban area, has revealed that there is Point and the areas beyond its limits. The CS proposal to develop green belt land before brownfield insufficient capacity in the urban area to accommodate the housing Page 5 of 222

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land is unjustified. requirement. As a result, the Council has had to look towards land beyond the urban area to meet its housing supply. The urban area is tightly bound by the Metropolitan Green Belt, and as such the remainder of the housing The apparent and recognised risk of major flood occurrence has been disregarded by the simple and requirement has to be met in the Green Belt. The decision to locate expedient conclusion of designing developments that have escape plans, i.e. access to a first floor development in the Green Belt is therefore underpinned by evidence and is location. This is an unacceptable attitude to the safety and well-being of the community. therefore justified in this regard.

CPBC with its flippant dismissal of the Hickfort plan, and the exclusion of Thorney Bay Park in the It is recognised that the local community (both Canvey and the Mainland) CS vision, are just two examples of unsound planning resulting from the general failure to fully do not support development of Greenfield Sites. However, there are no engage with the local community and produce an evidence base with which to begin creating a reasonable alternatives to this as the capacity of the urban area has been vision for Castle Point. The evidence base for this Core Strategy appears to have been created and fully included. As a result, the Council has taken efforts to identify manipulated to suit a vision that is not only unsustainable, but completely unsuitable for its development locations that minimise the extent of the Green Belt required constituents. for development, and minimise the impact on the strategic functions of the Green Belt. The Core Strategy has therefore taken an approach that is both justified and effective to dealing with delivering the remaining housing needs in the Green Belt.

Throughout the plan period Green Belt land is identified for delivery alongside previously developed land. The trajectory for this delivery is based on the reasonable likelihood of previously developed land coming forward for development as identified in the SHLAA. This has enabled the need for Green Belt land to be identified, and then scheduled into the Housing Trajectory accordingly. Green Belt land is required early in the plan period due to under-delivery to date, and the time required to get regeneration programmes off the ground during the early part of the plan, considering the current economic conditions. The housing trajectory is therefore based on evidence and considered sound.

With regard to flood risk, the Council contains a policy giving detailed consideration to the issues for Canvey Island. An emergency plan is a key element of the policies requirements and goes far beyond upper floor development. The distribution identified in the Core Strategy has been subject to a sequential test as per the requirements of PPS25, and found to be sequentially appropriate. The Environment Agency was consulted in the preparation of this assessment and their comments built in. As a result the Core Strategy is justified in terms of its consideration of flood risk.

With regard to the 'Hickfort' proposals, the initial Regulation 25 consultation on the Core Strategy undertaken in the Spring of 2006 set out a large urban extension as a spatial development option. This was rejected through consultation by statutory consultees and residents alike. It was considered to be unsustainable and raised concerns with regard to highways and access. The sustainability assessment of sites, prepared later to respond to the requests of GO-East for greater locational specificity found that the site was unsustainable due to its poor relation with the existing urban area and the need for people to travel on key trunk roads in order to access the area. Furthermore, the proposal sought to use an area of Green Belt far in excess of that needed to meet local needs following development in the urban area. As a result, the Hickfort proposal has been given appropriate consideration through consultation, and the Core Strategy is justified in excluding it from inclusion in the spatial distribution of development as a result of the outcomes of this consultation, and as a result of the evidence on its sustainability impacts.

With regard to Thorney Bay Park, the difficulties in delivering change on this site are recognised in policy CP9. It has not therefore been dismissed as described by this consultee, but dealt with as appropriate to the constraints operating on the site. The Core Strategy is therefore justified in respect of dealing with Thorney Bay. 9 2 Mrs Patricia Gunn U E I do not believe that the Core Strategy will be effective for the following reasons: W Essex County Council has indicated its support for the Core Strategy and Influences on the Core many of the proposals included within it including development of Strategy opportunities surrounding the Olympics, and improvement to the A13 1) I do not believe that one of the partners (Essex County Council) has the best interests of Castle between Sadlers Farm and the Tarpots. They have concerns about Point at heart as they have had ample opportunity to help resolve the issues of a third road off securing funding for a third road off of Canvey Island, but have not Canvey Island and to solve the problem of the road through Tarpots. The Leader of ECC appears to withdrawn support for the Council's position on this matter. As a result, be on record as saying that Canvey should not try to encourage tourism through leisure but should Essex County Council is on board with the Core Strategy, and it is concentrate on building more homes. THIS IS NOT WHAT CANVEY NEEDS!! therefore effective in this regard.

2) We need to encourage tourism for employment purposes so that the people of Canvey have the Policy CP6 identifies the potential for job provision in leisure, recreation opportunity to work on the Island. We also need to encourage people to visit the island but whatever and tourism at Canvey Seafront and throughout the Borough more is done will not succeed if people cannot easily get on or off the island if it is constantly jammed by generally. The Core Strategy is therefore effective in terms of addressing Page 6 of 222

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traffic because too many people have to go off the island for work. tourism as a form of employment in Castle Point.

3) I think that the Primary Care Trust has had quite a lot of success with the little they have done on The South Essex Primary Care Trust has identified a programme of the island BUT it is not enough as Canvey desperately needs its own hospital, especially one with an improvements in their Strategic Plan in order to meet the needs of Canvey A&E. This will not work unless ECC realise that lack of proper roads on and off Canvey is absolutely Island. This does not include the provision of A&E services, as the services necessary. at Basildon and Southend are considered adequate to meet the needs of the Island. The Core Strategy has given effective coverage to the needs of the Health Care Trusts. 136 Regional Policy Mr Jonathan U J Much of the potential development discussed in the document is based on the presumption that W With regard to the need to provide 4,000 homes in Castle Point in the Context Pinnock 4000 additional homes will need to be build in the borough. It doesn't appear that this assumption period 2001 to 2021, Anglia Polytechnic University produced forecasts in has been sufficiently challenged or thought through. Council officers and councillors have told me 2001 to inform the East of England Plan. This forecast suggested that that they are unable to challenge this requirement. A little common sense and local experience 3,800 homes would be required in Castle Point during the period 2001 to would show that for various reasons (e.g. the road and public transport infrastructure) cannot support 2021, aligning well with the 4,000 home requirement set out in the East of such an imposition. The borough is in the unfortunate position of being the location where a major England Plan. arterial road (the A13) from London which carries a large volume of traffic (especially at peak hours) encounters two roundabouts (Sadler's farm and Tarpots) and a set of traffic lights within a very short New forecasts prepared using population data in 2006 suggest that the distance of each other, whilst also reducing to a single lane. The first roundabout encountered also population of Castle Point will increase throughout the plan period with the feeds Canvey Island via another single lane carriageway which is regularly highly congested, population of the Borough exceeding increasing to around 98,000 by 2026. backing up to the roundabout.

This population increase is expected to arise from people living longer and To encourage even more traffic and further congestion (which has little or nil chance of resolution) from internal migration. The Strategic Housing Market Assessment resulting from 4000 additional homes is complete folly and unfair on local residents and businesses identifies that internal migration is largely from Basildon and London to the who need the ability to get to and from work. west.

The assumption that 4000 extra homes are required will also (according to the report) require Property prices and wages are typically higher in London than in Castle building on green belt land in the borough. This is unacceptable and undesirable. Point. As a result, people moving into Castle Point from these areas are able to compete more effectively for market housing than local people, particularly those on local wages. As a result, it is important to maintain a balance between supply and demand, if affordability is not to become an issue.

On this basis, it is considered that the Core Strategy is justified in proposing to deliver the 4,000 additional homes identified in the East of England Plan for the period 2001 to 2021.

It is recognised that new development has the potential to impact on infrastructure. As such, the Core Strategy identifies infrastructure requirements in policies CP1 to CP4. The consultee assumes that the number of peak time commuters will increase as a result of new housing. However, the Employment Study suggests that despite housing growth the number of economically active people will decrease, potentially reducing the level of peak time commuters.

With regard to the provision of housing on Green Belt land, the SHLAA, underpinned by a street level survey, revealed that there is insufficient capacity in the urban area to accommodate the 4,000 homes required. The Green Belt is tightly bound around the urban area and as a result, it is necessary to identify some Green Belt land in order to meet the housing requirement. The use of Green Belt land is therefore justified by the evidence in the SHLAA to ensure the effective delivery of the housing requirement. 186 Local Policy Context Miss Carrie Williams U E Under the sub-heading "Other Council Policies and Strategies" we note that there is no mention of W We would prefer to submit written With regard to the SFRA and Watercycle Study, they are both The Environment the Strategic Flood Risk Assessment (SFRA) or Water Cycle Study Scoping Reports competed in representations, however we would be happy to assessments and not policies or strategies. Therefore, it is not appropriate Agency 2009 by Scott Wilson. Due to the significant risk that flooding poses to Castle Point Borough, we feel attend the EiP at the Inspector's (or Council's) to mention them in this section. Issues for Castle Point are dealt with the in that these documents would play a major role in influencing the Core Strategy and should therefore request. the Spatial Portrait. the findings and implications of these documents should be highlighted in this section. The further detailed studies to be carried out in the future will equally impact upon the future review of this With regard to the Thames Estuary 2100 Plan consultation. Addition text document. Also, we note that the completed 2006 Thames Gateway South Essex SFRA has not has been included as a Minor amendment. This also picks up on the recent been included in this section. publication of the Thames River Basin Management Plan.

In addition, under the sub-heading "Other Partners Policies and Strategies" there is no mention of The Thames River Basin Management Plan has been added to Table 30. the Thames Estuary 2100 consultation plan. Again, due to the significant risk that flooding poses to the Borough, we would expect this plan to have a major influence on the Core Strategy and its findings and implications should be highlighted in this section.

We note that these document are included in Appendix C, therefore without the changes proposed above, we would consider the Core Strategy to fail the test of effectiveness because it is not internally consistent.

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333 Local Policy Context Mr Roy Lewis U J Social Care - Paragraph 2.16 should note the following social care strategies of Essex County E Essex County Council would wish to attend the Minor Amendment at page 9 and the inclusion of additional documents in Essex County Council - Commissioning Strategy; Homes for Older People Strategy, Housing for Disabled People oral part of the examination to further elaborate Table 30. Council Strategy, and Supporting People Strategy. The strategies should also be referenced in Appendix C. its representations on the Core Strategy; to provide the wider sub-regional/ regional context for matters included within the Core Strategy; and to provide technical assistance on matters relating to delivery of County Council services. 343 Table 1 Mr George Whatley U J SECTION 2 E In order to expand on this submission as This representation refers to a number of matters that have arisen through Public Involvement in Canvey Green Belt necessary. As representatives of the Canvey the process of preparing the core strategy. It demonstrates that the council the Core Strategy Campaign Greenbelt Campaign, and following our has had continuing discussions with members of the local community on Community Involvement 2.17 Referendum which clearly indicated the Canvey about issues arising from the preparation of the core strategy and concerns of the community of Canvey Island. that there has been a high level of community involvement in the Table 1 preparation of the core strategy.

Evidence Base cannot be Justified as either Robust or Credible, therefore should not be considered The council has been required to consider development in the green belt sustainable. on Canvey because of the lack of capacity in the urban area to meet needs generated on Canvey. However the core strategy does not propose a new influx of residents within the HSE consultation zones around either of the The Canvey Greenbelt Campaign involvement in the process. two hazardous installations. The core strategy addresses issues relating to sustainable urban drainage systems on Canvey. The issues of flood risk The publication "Planning for the Future" January 2009 is an eight page glossy "booklet" and emergency planning are dealt with elsewhere in responses to the summarising the Core Strategy Document. It states the Council's wishes to hear the views of representations received. residents and businesses in the Borough on the document. A total of 40,000 "booklets" and accompanying questionnaires were distributed by post. The general perception was that the The council has not proposed that the long term policy for south Canvey "booklet" understated the impact of proposed development on this part of the Borough, the questions will resolve the need to meet housing and employment needs else where were contradictory and answers were open to misinterpretation. on Canvey. The council recognises the need to work with landowners and other parties over the long term to deliver its aspirations for a mix of uses A total of 2,500 completed questionnaires were received by the Council. A response of just 6%. on south Canvey that would assist in making the island a more sustainable community over the longer term. The poor response was justifiably explained by residents as a) Apathy, b) Mistrust in how answers would be interpreted, or c) the Borough Council's failure to communicate with residents. For these reasons the council does not accept that the representation makes the core strategy unsound. The compilers of the survey made the assumption that, because 94% failed to respond, by not responding, they must "implicitly agree with the findings"!

To challenge this theory the Canvey Greenbelt Campaign Group was formed and decided to conduct a Referendum. Knowing how little green space is remaining within the Canvey Island road network we decided to ballot Islanders, from within all wards, with the question:-

"SHOULD THERE BE ANY FURTHER DEVELOPMENT OF CANVEY GREENBELT LAND?"

With spaces to answer either Yes or No and to sign or initial each ballot paper. Over a two-week period, volunteers called on resident's homes. 6,534 signed votes were recorded, all cast into sealed jars.

A total of 6,437 voted NO to more development on greenbelt land. 56 voted Yes, with 41 spoiled papers.

A 99.13% resident vote against Castle Point Borough Council's Canvey development plans.

The count was adjudicated and recorded by County Councillor R.Howard, Councillor D.Blackwell, ex Mayor D.Williams and resident G.Whatley. The result was registered in Parliament by M.P. Bob Spink.

It was also lodged with the Borough Council via the Chief Executive. The voting slips are safely stored for re-checking.

From this Referendum event a delegation from the Canvey Greenbelt Campaign Group were invited to meet with the Council's SPDG Risk task group made up of three Mainland Councillors, together the Chief Executive, Consultant Planning Officer and the Head of Regeneration and Homes.

We expressed our concerns regarding:-

Loss of valuable local greenbelt.

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hazard zone of two COMAH sites.

The risk of localised surface water flooding from new development onto neighbouring estates, knowing that Sustainable Urban Drainage System is inappropriate on Canvey Island.

The implications of more development should the sea defences ever fail.

The lack of a "suitable for purpose" emergency plan.

The probability that the emergency services would be overstretched in the event of a major industrial accident, be it by a Vapour Cloud Explosion, or protracted multi tank fire and explosion incident, given the close proximity of vulnerable residents.

And in the event of a North Sea surge these Emergency Services being first deployed further along the East coast therefore severely stretched.

The lack of an evacuation plan for both of these scenarios.

The compounded implications of having only one access and egress point at Waterside roundabout.

All of which we were told was going to be given further consideration in the light of these issues not being part of the site selection process.

We enquired why the proposed Core Strategy document should suggest that Canvey housing should, in isolation, be linked with Basildon and yet Hadleigh, Benfleet and Thundersley should be linked with Southend housing. This was treated as an irrelevance. We now realise that by isolating Canvey, Borough leaders can show a need to provide housing for "a distinctly different community" and that "it is not appropriate to deliver new homes to meet the needs of the residents of Canvey Island in Benfleet, Hadleigh or Thundersley". This we find wholly objectionable, although it highlights, to outsiders, how the Mainland Councillors and Officers consider the residents of this part of the Borough.

There is evidence to prove that people are quite comfortable entering and also relocating throughout all parts of the Borough.

The Council delegation requested a second meeting to allow them time to consider our concerns.

The second meeting commenced with a Presentation on the development of the RSPB site on West Canvey Marsh, without disclosing to us that the land will more than likely be claimed by the Thames 2100 Project. This Project sets out proposals for the future flood management of the Thames Estuary, including this very area. Whilst Officers claimed the marsh will be retained as green belt for Canvey Island, the probability is it will be flooded, whether in ten or twenty or more years time, so as to alleviate climate change influenced higher tides with a realigned concrete sea wall thus reducing Canvey's land mass and greenbelt. The Council Group, knowing that we had no knowledge of the Thames Estuary 2100 proposals, allowed us to carry on pointing out that this was already open ground previously refused planning permission for Oil Installation development fiercely contested by Canvey Residents some years ago. For them to suggest that they were providing a facility for Canvey, without consultation, as compensation for the loss of green belt was disgraceful. We pointed out some very basic issues with the RSPB country park. Firstly that its outlook being over shadowed by the Oil Refineries at Coryton and the mounds of Pitsea tip are not ideal setting for a picnic. Access will only be by car because of the inaccessibility and the need to cross a busy dual carriageway. The site is not family-friendly, as it will not offer freedom to children due to unprotected dykes, ditches and drainage gullies. We were then engaged in comment regarding the Town Centre regeneration, agreeing that it had been allowed to deteriorate through lack of investment and regular maintenance. What we were not told was that the funding for any regeneration would have to come from developer's contributions. The resulting developments leading to over population and the loss of school playing fields, none of which were later declared or shown at the ensuing public presentation venue.

When pressed to respond to our concerns made in the first meeting no answers or challenges were forthcoming.

The Council delegation made an admission that the council could not afford to maintain Waterside Farm Sports Centre nor the Paddocks Civic Centre without the income from new development. We felt that the monies for regular maintenance should be found from routine annual Council funding.

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To break the deadlock the Planning Officer recorded what items could be agreed upon. This included, no development on greenbelt, a new access road, the two COMAH sites removed, a regenerated town centre and then they suggested the possibility of a marina!

We were then offered an opportunity to put on a Presentation to the full Special Policy and Development Group.

A draft document, incorporating these agreements, was promised to us, by the Chief Executive, and would be available to us prior to the Presentation meeting.

This offer being independently witnessed.

We understood at this stage, that rather than giving over existing Canvey greenbelt to development, agreement had been reached on the necessity to firstly remove the risks presented by the COMAH sites, thus in itself releasing additional land for green belt and recreational use whilst removing some of the requirement for emergency response needed in the event of an industrial accident, although still leaving flooding and improved access and egress issues needing to be resolved.

No Draft Document ever materialised.

We therefore lost all trust, and felt that this process would not resolve our concerns.

We were simply being used to provide evidence for the planning inspectorate that consultation had been duly undertaken, leading us to take the response that further official consultation with the Council and its Officers would not resolve any of our issues.

We were left with no alternative but to make clear our intentions to direct our presentation directly to the Planning Inspectorate.

The Presentation, made in public, was to comprise of our ten-minute presentation followed by a further twenty minute window, to allow for questioning from the Councillors.

We attempted in the time to cover all of our previous concerns so that the Council's full Special Policy and Development Group was aware of the problems facing Canvey Islanders.

Not one Councillor, nor Officer, provided one piece of sound evidence that allayed or challenged any of the individual concerns we expressed.

Following the Presentation the Task Group, covering the Greenbelt issues, requested further documented, Canvey greenbelt specific, evidence prior to the Final Findings Meeting of the Special Policy and Development Group, falsely implying the Council were intending to respond to residents' opinion.

This we duly provided and it is recorded in the minutes of the Final Findings Meeting.

The Core Strategy was debated at a Full Council Meeting at which we noted that individual Councillors, who voted in support of adopting the Document, did so using the terms "reluctantly", "unpalatable" and "unsustainable". Voting went, disappointingly, strictly along Political Party lines. A DVD of the proceedings to highlight these points is attached at the rear of this submission.

Unfortunately neither our Referendum result, the concerns of Canvey residents, our five hours of meetings with the Risk Task Group, or our Presentation have had the slightest influence on the Core Strategy Document.

Our conclusion is that our invitation to meet with the Risk Task Group was simply to fulfil the necessity to show public involvement and to assess the "risk" the Canvey Greenbelt Campaign Group posed to the publication of the Core Strategy Document.

The process has neither been transparent or open.

There are neither the finances in place, nor the power of authority in place to improve the safety, and well-being of Canvey Island residents by the removal of these hazards. There has never been any intention for these companies to close down the COMAH sites, having previously declared their clear

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intention to the Council, via their representations, to continue future production.

For the Council to give Canvey residents the impression that there was an intention for this to be achieved within the life time of the Core Strategy as compensation for the loss of existing green belt facilities and as justification, for exposing additional occupants in the short term, before suitable emergency systems to deal with the existing population has been developed, requires explanation.

Whilst there are so many unresolved issues, Water Management Bill, Calor Gas Investigation and forth coming Prosecution, the Thames 2100 final report, inadequate access/egress provision, we contend that the development of more homes on Canvey Island, whilst there are areas available on the far less densely populated three Mainland towns is neither justified nor sustainable.

Evidence base

Canvey Greenbelt Campaign Referendum Official signed Result Certificate.

Referendum Ballot papers stored and available on request.

DVD of the Council Core Strategy adoption Meeting.

Cs topic paper 4 380 Table 1 Mr U J SECTION 2 E In order to expand on this submission as This representation refers to a number of matters that have arisen through Public Involvement in necessary. As representatives of the Canvey the process of preparing the core strategy. It demonstrates that the council the Core Strategy George Greenbelt Campaign, and following our has had continuing discussions with members of the local community on Community Involvement 2.17 Referendum which clearly indicated the Canvey about issues arising from the preparation of the core strategy and Whatley concerns of the community of Canvey Island. that there has been a high level of community involvement in the Canvey Green Belt Table 1 preparation of the core strategy. Campaign Evidence Base cannot be Justified as either Robust or Credible, therefore should not be considered The council has been required to consider development in the green belt sustainable. on Canvey because of the lack of capacity in the urban area to meet needs generated on Canvey. However the core strategy does not propose a new influx of residents within the HSE consultation zones around either of the The Canvey Greenbelt Campaign involvement in the process. two hazardous installations. The core strategy addresses issues relating to sustainable urban drainage systems on Canvey. The issues of flood risk The publication "Planning for the Future" January 2009 is an eight page glossy "booklet" and emergency planning are dealt with elsewhere in responses to the summarising the Core Strategy Document. It states the Council's wishes to hear the views of representations received. residents and businesses in the Borough on the document. A total of 40,000 "booklets" and accompanying questionnaires were distributed by post. The general perception was that the The council has not proposed that the long term policy for south Canvey "booklet" understated the impact of proposed development on this part of the Borough, the questions will resolve the need to meet housing and employment needs were contradictory and answers were open to misinterpretation. elsewhere Canvey. The council recognises the need to work with landowners and other parties over the long term to deliver its aspirations A total of 2,500 completed questionnaires were received by the Council. A response of just 6%. for a mix of uses on south Canvey that would assist in making the island a more sustainable community over the longer term. The poor response was justifiably explained by residents as a) Apathy, b) Mistrust in how answers would be interpreted, or c) the Borough Council's failure to communicate with residents. For these reasons the council does not accept that the representation makes the core strategy unsound. The compilers of the survey made the assumption that, because 94% failed to respond, by not responding, they must "implicitly agree with the findings"!

"SHOULD THERE BE ANY FURTHER DEVELOPMENT OF CANVEY GREENBELT LAND?"

A total of 6,437 voted NO to more development on greenbelt land. 56 voted Yes, with 41 spoiled papers.

A 99.13% resident vote against Castle Point Borough Council's Canvey development plans.

The count was adjudicated and recorded by County Councillor R.Howard, Councillor D.Blackwell, ex Page 11 of 222

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Mayor D.Williams and resident G.Whatley. The result was registered in Parliament by M.P. Bob Spink.

It was also lodged with the Borough Council via the Chief Executive. The voting slips are safely stored for re-checking.

We expressed our concerns regarding:-

Loss of valuable local greenbelt.

The Council planning to increase Societal risk by introducing a new influx of residents within the hazard zone of two COMAH sites.

The risk of localised surface water flooding from new development onto neighbouring estates, knowing that Sustainable Urban Drainage System is inappropriate on Canvey Island.

The implications of more development should the sea defences ever fail.

The lack of a "suitable for purpose" emergency plan.

And in the event of a North Sea surge these Emergency Services being first deployed further along the East coast therefore severely stretched.

The lack of an evacuation plan for both of these scenarios.

The compounded implications of having only one access and egress point at Waterside roundabout.

All of which we were told was going to be given further consideration in the light of these issues not being part of the site selection process.

There is evidence to prove that people are quite comfortable entering and also relocating throughout all parts of the Borough.

The Council delegation requested a second meeting to allow them time to consider our concerns.

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picnic. Access will only be by car because of the inaccessibility and the need to cross a busy dual carriageway. The site is not family-friendly, as it will not offer freedom to children due to unprotected dykes, ditches and drainage gullies. We were then engaged in comment regarding the Town Centre regeneration, agreeing that it had been allowed to deteriorate through lack of investment and regular maintenance. What we were not told was that the funding for any regeneration would have to come from developer's contributions. The resulting developments leading to over population and the loss of school playing fields, none of which were later declared or shown at the ensuing public presentation venue.

When pressed to respond to our concerns made in the first meeting no answers or challenges were forthcoming.

We were then offered an opportunity to put on a Presentation to the full Special Policy and Development Group.

A draft document, incorporating these agreements, was promised to us, by the Chief Executive, and would be available to us prior to the Presentation meeting.

This offer being independently witnessed.

No Draft Document ever materialised.

We therefore lost all trust, and felt that this process would not resolve our concerns.

We were left with no alternative but to make clear our intentions to direct our presentation directly to the Planning Inspectorate.

The Presentation, made in public, was to comprise of our ten-minute presentation followed by a further twenty minute window, to allow for questioning from the Councillors.

We attempted in the time to cover all of our previous concerns so that the Council's full Special Policy and Development Group was aware of the problems facing Canvey Islanders.

Not one Councillor, nor Officer, provided one piece of sound evidence that allayed or challenged any of the individual concerns we expressed.

This we duly provided and it is recorded in the minutes of the Final Findings Meeting.

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DVD of the proceedings to highlight these points is attached at the rear of this submission.

The process has neither been transparent or open.

Evidence base

Canvey Greenbelt Campaign Referendum Official signed Result Certificate.

Referendum Ballot papers stored and available on request.

DVD of the Council Core Strategy adoption Meeting.

Cs topic paper 4 381 Table 1 Mr Steve Swains U J SECTION 2 E In order to expand on this submission as This representation refers to a number of matters that have arisen through Public Involvement in Canvey Green Belt necessary. As representatives of the Canvey the process of preparing the core strategy. It demonstrates that the council the Core Strategy Campaign Greenbelt Campaign, and following our has had continuing discussions with members of the local community on Community Involvement 2.17 Referendum which clearly indicated the Canvey about issues arising from the preparation of the core strategy and concerns of the community of Canvey Island. that there has been a high level of community involvement in the Table 1 preparation of the core strategy.

Evidence Base cannot be Justified as either Robust or Credible, therefore should not be considered The council has been required to consider development in the green belt sustainable. on Canvey because of the lack of capacity in the urban area to meet needs generated on Canvey. However the core strategy does not propose a new influx of residents within the HSE consultation zones around either of the The Canvey Greenbelt Campaign involvement in the process. two hazardous installations. The core strategy addresses issues relating to sustainable urban drainage systems on Canvey. The issues of flood risk The publication "Planning for the Future" January 2009 is an eight page glossy "booklet" and emergency planning are dealt with elsewhere in responses to the summarising the Core Strategy Document. It states the Council's wishes to hear the views of representations received. residents and businesses in the Borough on the document. A total of 40,000 "booklets" and accompanying questionnaires were distributed by post. The general perception was that the The council has not proposed that the long term policy for south Canvey "booklet" understated the impact of proposed development on this part of the Borough, the questions will resolve the need to meet housing and employment needs elsewhere on were contradictory and answers were open to misinterpretation. Canvey. The council recognises the need to work with landowners and other parties over the long term to deliver its aspirations for a mix of uses A total of 2,500 completed questionnaires were received by the Council. A response of just 6%. on south Canvey that would assist in making the island a more sustainable community over the longer term. The poor response was justifiably explained by residents as a) Apathy, b) Mistrust in how answers would be interpreted, or c) the Borough Council's failure to communicate with residents. For these reasons the council does not accept that the representation makes the core strategy unsound. The compilers of the survey made the assumption that, because 94% failed to respond, by not responding, they must "implicitly agree with the findings"!

To challenge this theory the Canvey Greenbelt Campaign Group was formed and decided to

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conduct a Referendum. Knowing how little green space is remaining within the Canvey Island road network we decided to ballot Islanders, from within all wards, with the question:-

"SHOULD THERE BE ANY FURTHER DEVELOPMENT OF CANVEY GREENBELT LAND?"

A total of 6,437 voted NO to more development on greenbelt land. 56 voted Yes, with 41 spoiled papers.

A 99.13% resident vote against Castle Point Borough Council's Canvey development plans.

The count was adjudicated and recorded by County Councillor R.Howard, Councillor D.Blackwell, ex Mayor D.Williams and resident G.Whatley. The result was registered in Parliament by M.P. Bob Spink.

It was also lodged with the Borough Council via the Chief Executive. The voting slips are safely stored for re-checking.

We expressed our concerns regarding:-

Loss of valuable local greenbelt.

The Council planning to increase Societal risk by introducing a new influx of residents within the hazard zone of two COMAH sites.

The risk of localised surface water flooding from new development onto neighbouring estates, knowing that Sustainable Urban Drainage System is inappropriate on Canvey Island.

The implications of more development should the sea defences ever fail.

The lack of a "suitable for purpose" emergency plan.

And in the event of a North Sea surge these Emergency Services being first deployed further along the East coast therefore severely stretched.

The lack of an evacuation plan for both of these scenarios.

The compounded implications of having only one access and egress point at Waterside roundabout.

All of which we were told was going to be given further consideration in the light of these issues not being part of the site selection process.

There is evidence to prove that people are quite comfortable entering and also relocating throughout

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all parts of the Borough.

The Council delegation requested a second meeting to allow them time to consider our concerns.

When pressed to respond to our concerns made in the first meeting no answers or challenges were forthcoming.

We were then offered an opportunity to put on a Presentation to the full Special Policy and Development Group.

A draft document, incorporating these agreements, was promised to us, by the Chief Executive, and would be available to us prior to the Presentation meeting.

This offer being independently witnessed.

No Draft Document ever materialised.

We therefore lost all trust, and felt that this process would not resolve our concerns.

We were left with no alternative but to make clear our intentions to direct our presentation directly to the Planning Inspectorate.

The Presentation, made in public, was to comprise of our ten-minute presentation followed by a further twenty minute window, to allow for questioning from the Councillors.

We attempted in the time to cover all of our previous concerns so that the Council's full Special

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Policy and Development Group was aware of the problems facing Canvey Islanders.

Not one Councillor, nor Officer, provided one piece of sound evidence that allayed or challenged any of the individual concerns we expressed.

This we duly provided and it is recorded in the minutes of the Final Findings Meeting.

The process has neither been transparent or open.

Evidence base

Canvey Greenbelt Campaign Referendum Official signed Result Certificate.

Referendum Ballot papers stored and available on request.

DVD of the Council Core Strategy adoption Meeting.

Cs topic paper 4 268 Sustainability Ms KATHARINE U J The report does not identify the possible impact on cultural heritage assets of the Olympic mountain W Proposals for the Olympic event are well advanced, and it is understood Appraisal and FLETCHER biking facility, although the potential for impact on natural environmental assets is referred to. This that the County Council's historic advisors and English Nature are involved Strategic ENGLISH shortcoming in the assessment would not, however, be material if the detailed scheme results in no in this work. It is unlikely that the Core Strategy, or indeed its sustainability Environmental HERITAGE significant impacts for the historic environment. The evidence base is not yet complete in this appraisal would be able to influence the outcomes of this work as it is Assessment respect, and discussions are on-going. We hope that the detailed proposals and environmental running ahead. Therefore the Sustainability Appraisal of the Core Strategy impact assessment will demonstrate that significant impacts to the scheduled sites in the vicinity of is sufficiently detailed on this matter and the Core Strategy is considered the development have been avoided. sound.

The SA report does not identify any cultural heritage impact for the development site in policy SS2, East of Canvey Road. The feasibility of development being brought forward without significant adverse impact to the scheduled site should be examined and the evidence provided to inform the Core Strategy proposals prior to submission. 285 Habitats Regulations Dr Philip Pearson U E Good strategic planning considers options that avoid ecological damage at the strategic W The HRA has been prepared in consultation with Natural England. They Assessment and RSPB level, which is the main benefit offered by "strategic" Habitats Regulations Assessment Page 17 of 222

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Appropriate (HRA). The Core Strategy establishes the planning framework for the Borough, specifying are satisfied with the level of detail in the HRA. Assessment what the other Local Development Framework (LDF) documents must deliver. It is essential at this point to be confident that this overall framework is deliverable. In a number of policies, It is recognised that detailed assessment of some projects has been left such as Policy CP 3, a full assessment of the impact of policies and projects is deferred to until later documents. This is because it is unclear as to the details of these allocation documents, for example the Canvey Island Area Action Plan (AAP), or to project- projects. For example, there are various options proposed for a third route level. This deferral of assessment of potential impacts on Natura 2000 sites however creates off of Canvey Island - Terry Farrell is working on proposals for a Lower uncertainty over the delivery of key aspects of the plan, calling its soundness into question. Thames Crossing, whilst a private interest Metrotidal are also putting Based on the spatial information provided in support of the Core Strategy and those of together proposals for a road and rail link across the Thames. Until a route neighbouring Councils, we believe that sufficient information exists to predict the effects of is clear, it would be difficult to determine the impact of a third road on proposed policies with reasonable certainty and to therefore undertake a thorough HRA of European Sites. the Core Strategy at this strategic level. As we have previously highlighted, waiting until the AAP is being produced is unacceptable, as it is possible that no options exist that would avoid an impact upon the SPA. In such circumstances it is almost inevitable that the scheme The Council is therefore satisfied that the HRA is sufficiently thorough for a would have to be dropped from the Plan. To avoid uncertainty about delivery, the areas and Core Strategy. types of development need to be identified in the Core Strategy and subject to as thorough a HRA as possible at this stage. We would be happy to meet with you to discuss this issue further. 37 A Robust Evidence Mr Martin Twigg U E We do not believe the evidence base is sound. You are relying on a Housing Needs Survey carried E The council does not accept that its evidence base is not robust. The Base Fox Land and out in 2002 and an Urban Capacity Study from 2004. Your evidence has not been subject to Urban Capacity Study and the SHLAA have both been the subject of very Property Limited sufficient public scrutiny and your SHLAA has not met the minimum core requirements as issued by detailed work to ensure that the capacity of the urban area is both DCLG (July 2007). We have already commented on the inadequacies of the SHLAA and trust that deliverable and maximised. our comments of 25 th January 2009 have been taken into account, and will be taken into account as part of these representations. The Canvey Sustainable Regeneration Report and the Hadleigh Capacity Study have been made available on the council’s website. Both the Requests have been made to release information on the process and identification of sites relied on Manor and Point industrial sites have been the subject of detailed in the urban area including Canvey/Hadleigh Town Centres, unimplemented planning permissions discussions with landowners and are deliverable in due course. The council and the main route capacity study. You have identified Manor and Point Industrial Sites as part of has prepared a sequential test in respect of development in the flood plain your housing supply without any transparent sustainability assessments or shown whether they are in conjunction with the EA which addresses the requirements of PPS25. deliverable/ developable or available. No assessment of brownfield sites viability has been released. Housing allocations remain in Areas of Flood Zone 3 contrary to PPG25 and without agreement from The council does not therefore accept that the core strategy is unsound for the Environment Agency where no consents have been issued owing to the moratorium for the last the reasons given. two years. 30 Table 2 McCarthy & Stone, Mr Matthew Shellum U Ef Table 2A identifies that the population of the Borough is ageing with the proportion of people over W Essex County Council have recently published a strategy for the delivery of A Portrait of Castle Retirement The Planning fe the age of 65 set to increase to 28% by 2021. It acknowledges under the Homes section that there is accommodation for older people. A minor amendment is proposed to list Point Lifestyles Ltd. Bureau Ltd. cti a need for a more diverse mix of housing including those for older people. However, there is nothing this in the evidence section. ve within the respective Partners and Projects column that identifies what the Council are planning to do to deliver older person's accommodation. For a Core Strategy to be effective it needs to be The purpose of the Spatial Portrait is to identify issues and opportunities to deliverable there is nothing within this table or Core Strategy that identifies how the identified be addressed and captured in the Core Strategy. If there are no clear housing needs of older people will be delivered in the plan period, and for that reason it is unsound. partners or projects at the portrait stage this does not mean that the Core Strategy is unsound. Policy SS2 clearly identifies a Greenfield site for the provision of accommodation for older people. Meanwhile, policy CP8 seeks the provision of older peoples accommodation in the mix of housing delivered. The specific mix for larger sites will be determined in the Canvey Area Action Plan and the Benfleet, Hadleigh and Thundersley Plan, allowing for sites for older people to be clearly identified. The Core Strategy is therefore considered sound with regard to its effectiveness in delivering older peoples accommodation. 80 Table 2 Mr Richard Inman U E We welcome recognition that safe access and egress from Canvey Island, in the event of flooding, is W The Spatial Portrait sets out issues and opportunities only. To reference A Portrait of Castle GO-East a major concern given the aim of increasing housing numbers (and consequently the number of policy CP5 would be inconsistent with the style of this section, as no other Point residents) on the Island. Policy CP5, later in the document goes some way towards explaining how policies are referenced. this will be addressed. We suggest you include a reference to CP5 at this point. 167 Table 2 Mr JAMES U J The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The HSE recognise that the presence of these installations pose a risk to A Portrait of Castle TRIMMER Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the residents and businesses on the island because they require the authority Point PORT OF LONDON and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove to consult them in respect of development within the consultation zone AUTHORITY adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey around the installations. The council recognises that these installations are integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should controlled by the HSE but this control does not extinguish the risk to the cargo per annum. properly be discussed at the examination. The community. It is for these reasons that the HSE has previously advised PLA, as landowner of one of the terminals and against the granting of planning permission at these sites and within the as the Statutory Port Authority for the port within consultation zone referred to above. The council's strategy seeks to reduce The PLA contends that Table 2 (and more particularly the Flood Management and the Waterfront which the terminals operate, contends that it risk to residents and businesses in the borough in the light of incidents at feature) is not justified and that the Core Strategy is therefore unsound. No robust evidence is should participate in any such discussion. these sites and elsewhere in the UK. adduced to substantiate the claim that the terminals pose any safety risk; indeed the Core Strategy explicitly recognises that the terminals are properly regulated by the Health and Safety Executive. There is no robust evidence to suggest that the expansion and/or change in the materials handled, stored and distributed from the terminals would result in any long-term safety concerns. No robust evidence is adduced to substantiate the claim that access to the foreshore is in any way limited by the presence of the terminals.

The Thames Gateway South Essex Waterfront Strategy recognises that both the cargo-handling terminals in Castle Point are key waterfront dependent assets, and that their future development should be supported. Furthermore, no robust evidence is adduced to substantiate the claim that the

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approach taken represents the most appropriate strategy when considered against the reasonable alternatives, and in particular the continuation of cargo-handling at the terminals.

The PLA contends that only the deletion of this element of Table 2 and its replacement with an approach which provides for the continuation of the current cargo-handling uses at the terminals will remedy these deficiencies and make the Core Strategy sound. 168 Table 2 Mr U E The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The council does not oppose the use of the PLA land for mixed uses A Portrait of Castle Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the including part of the site for cargo handling. However, the council believes Point JAMES and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove that the use of the land for the storage of hazardous substances is not adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey appropriate in the longer term, particularly in the light of the TRIMMER integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should 'Recommendations on land use planning and the control of societal risk PORT OF LONDON cargo per annum. properly be discussed at the examination. The around major hazardous installations' report issued by the Buncefield Major AUTHORITY PLA, as landowner of one of the terminals and Incident Investigation Board. The council cannot therefore agree with the as the Statutory Port Authority for the port within deletion of this element of Table 2 and the continuation of current cargo The PLA contends that Table 2 (and more particularly the Flood Management and the Waterfront which the terminals operate, contends that it handling uses at these terminals as proposed. feature) is not effective and that the Core Strategy is therefore unsound. should participate in any such discussion.

The PLA acquired its landholdings in Canvey Island over seventy years ago. It is operational land for the purposes of the Planning Acts. The PLA remains fully committed to the utilisation of the Oikos site for cargo-handling. It has no intention of disposing any or all of the site for alternative development throughout the plan period.

The Council is aware of the PLA's position in relation to the long-term future of the Oikos site, and the approach promulgated within Table 2 is clearly not deliverable. As such, it fails the test at Paragraph 4.45 of PPS12 and, the PLA would contend, the Core Strategy is therefore unsound.

The PLA contends that only the deletion of this element of Table 2 and its replacement with an approach which provides for the continuation of the current cargo-handling uses at the terminals will remedy these deficiencies and make the Core Strategy sound. 188 Table 2 Oikos Storage Mr Philip Rowell U J This representation should be read in conjunction with all the other representations E This matter, along with the other representations The council cannot accept the suggested amendments to Table 2 because A Portrait of Castle Limited Adams Hendry submitted by Oikos on the Core Strategy Final Publication Document. submitted by Oikos on the Core Strategy, relate of the hazardous nature of the materials stored at the Oikos site. The Point Consulting Ltd to a facility of some significance. The issues council's strategy seeks the long term redevelopment of these sites which raised relate to the long term future of this will facilitate the provision of alternatives to Canvey Island as a site for the Fundamental to Oikos' objections to the Core Strategy is a misunderstanding of the role and strategic facility. The intentions of the Council storage of hazardous materials such as those currently stored at Oikos and significance of the Oikos facility in land use terms. Reference within Table 2: A Portrait of Castle and Oikos are so fundamentally opposed that Calor. Point is made to the facility being a hazardous installation. However, no recognition is given to the the most appropriate course of action is to fact that the Oikos facility is located on port operational land (as defined by the Planning Acts) of the debate the issues at the Examination in Public. Port of London and that the facility forms a key strategic port facility within the Port of London.

The Port of London is identified by Government through its Delivering a Sustainable Transport System (November 2008) documentation as one of the country's key international gateways and a component of the transport infrastructure that, collectively with the other identified elements, is critical to the functioning of the transport system as a whole and to the economic success of the nation.

The Oikos facility is a long term strategic location. Its nationally strategic importance is as a long term facility for the import and onward distribution of oil and fuel products within the Port of London. Its significance is explained by the fact that it is an independently operated marine fed oil storage facility that benefits from the rare combination of having deep water access close to commercial shipping lanes (via the deep water access channel of the River Thames) and connections to both the nationally significant UK Oil Pipeline (UKOP) and the Government Pipeline and Storage System (GPSS). These pipelines provide aviation fuel to Heathrow, Gatwick and Stansted, as well as MoD airfields. The site is also a key component of the national distribution network for road transport fuels.

The Draft Overarching National Policy Statement for Energy (EN‐1) (2009) makes it clear that the UK needs to ensure that it has safe and secure supplies of the oil products it requires, and that sufficient fuel and infrastructure capacity is necessary to avoid socially unacceptable levels of interruption to physical supply and excessive costs to the economy from unexpectedly high or volatile prices. It is further made clear that these requirements can be met by sufficient, diverse and reliable supplies of fuel, with adequate capacity to import, produce, store and distribute these supplies to customers. This in turn is then identified as highlighting the need for reliable infrastructure including pipelines and import terminals, such as the Oikos facility. The importance of the GPSS and UKOP national pipeline networks, as an efficient and robust distribution system throughout the UK, is also recognised by Government in the draft national policy statement.

The Port of London Authority is understood to regard the facility as a very important part of port operations on the Thames. The Core Strategy in Table 2 in respect of describing the waterfront of

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Castle Point should therefore reflect the above role and status of the Oikos facility.

Furthermore, there is no evidence that the Oikos facility ‘further limits' access to the foreshore of the River Thames. Public access is available along the edge of the River adjacent to the Oikos facility.

Oikos support the identification in Table 2 that the Council need to engage with the landowners of the ‘Hazardous Installations'. However, such engagement should also be, in respect of the Oikos facility, with the long term operators of the Terminal (Oikos) as well as the landowner (the Port of London Authority). Any long term strategy should be based around the fact that the Oikos facility is a strategic port facility and that the only justifiable and effective option through the lifetime of the core strategy is the continuation of its current primary use.

Suggested amendments

The fourth paragraph of text in the ‘Characteristic' row of Table 2 under the feature ‘Flood Management and the Waterfront' should be deleted and replaced with.

"The waterfront area to the south of Canvey Island contains two notable installations, the Oikos Storage facility and the Calor Gas facility. The Oikos installation is a strategic port facility within the nationally significant Port of London and plays a key role in regional and national fuel supply ".

The corresponding entry in the ‘Partners and Projects' column of the Table should be deleted and replaced with.

"The Council need to engage with the land owners and operators of the strategic port facility that is the Oikos installation to ensure a long term strategy is in place for its future operation" 189 Table 2 Miss Carrie Williams U J Under the table heading of "Flood Management and the Waterfront" you state that maintenance of W We would prefer written representations, but will Minor Amendment to table 2 at page 18. A Portrait of Castle The Environment the flood defences is programmed until 2100 as part of the Thames Estuary (TE) 2100 Plan. This is happily attend the EiP at the Inspector's (or Point Agency not the case. The TE2100 Plan is providing a flood risk management strategy for the whole of the Council's) request. Thames Estuary, to include recommendations regarding maintenance and improvement programmes to the engineered defences. The final decisions on these programmes will be made by Defra and funding streams, at this time, are not guaranteed. 203 Table 2 Goldencircle Ltd Mr Haydn Payne S J W No response required. A Portrait of Castle Alliance Planning Point 212 Table 2 Calor Gas Limited Mr Geoff Bullock U J Also Effective E The representations involve issues that would The HSE recognise that the presence of these installations pose a risk to A Portrait of Castle RPS Planning benefit from being presented orally at residents and businesses on the island because they require the authority Point examination. to consult them in respect of development within the consultation zone Section 3 - Spatial Portrait of Castle Point, Table Page 19, ‘Flood Management and the around the installations. The council recognises that these installations are Waterfront' controlled by the HSE but this control does not extinguish the risk to the community. It is for these reasons that the HSE has previously advised Calor strongly objects to the suggestion within the Table on Page 19 under ‘Flood Management and against the granting of planning permission at these sites and within the the Waterfront' that the existing LPG Terminal poses a "safety risk to residents of the Island". This consultation zone referred to above. The council's strategy seeks to reduce assertion is not founded on a robust or credible evidence base. The LPG Terminal is strictly risk to residents and businesses in the borough in the light of incidents at regulated under legislation known as the Control of Major Accident Hazard (COMAH) Regulations. these sites and elsewhere in the UK. The Calor LPG operation has a very good safety record and the Site has a long history of safe operation for gas-related uses. Furthermore, any proposals to change or expand the operations at Notwithstanding the Calor safety record there has been one incident since the Site would need to satisfy the relevant regulatory authorities, including the Health & Safety 2006 which required an HSE investigation. The respondent refers to the Executive (HSE) and the Environment Agency (EA). site being acceptably safe without clarifying the use of this term particularly in the light of the recommendations of the Board which investigated the Calor also wish to provide clarification with regard to the HSE's position on the 2006 applications to Buncefield incident. develop a combined LPG and LNG operation at the Site given the reference in the Table to the HSE being unable to support these proposals. Calor are committed to working closely with the HSE (and The council has held meetings with senior management of Calor since the LPA) in respect of any future proposals for a combined LPG and LNG facility at the site. Calor 2008 in order to engage with the company about the future of the would seek to consult closely with the HSE on any such proposals to ensure that the operations operations at this site and would intend to continue with this activity over would be acceptably safe. Since the previous applications were advanced, Calor has undertaken the lifetime of the plan to ensure that the strategy is delivered. further detailed work, which confirms that a combined LPG and LNG facility could be operated safely at the Site. Indeed, Calor would not be prepared to advance any proposals at the Site if it did not consider that these would be acceptably safe.

The Table also refers to the need for the LPA to engage with the landowners of the "Hazardous Installations", which includes the Calor LPG Terminal, to identify a long term strategy for the location. To date the LPA has made only limited contact with Calor regarding the future of the LPG Terminal, and despite clear statements from Calor that the Terminal will not be available for alternative uses over the LDF period or in the longer term, the LPA has continued to make references within the Core Strategy to the redevelopment of the Site for alternative uses. In short, we do not believe that the LPA has engaged sufficiently with the relevant landowners and does not have their support to re-use the sites for alternative uses either now, or in the longer term. As such, there is no evidence that this Page 20 of 222

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element of the strategy is deliverable. 222 Table 2 Miss Sally Fordham U N As noted in previous representations made to the Core Strategy Proposed Publication Document in E We believe it is necessary to attend the oral part The Petroplus site is not within the administrative area of Castle Point and A Portrait of Castle Petroplus Refining Drivers Jonus March 2009, the Coryton Oil Refinery Complex plays the role of an international, national, and of the examination as the Coryton Oil Refinery therefore is not included within the Core Strategy. The council recognises Point and Marketing regional gateway, and our client Petroplus wishes that this role is explicitly recognised and explicitly complex plays the role of an international, the presence of the Petroplus refinery which is in Thurrock and the Limited (Petroplus) protected in the Castle Point Core Strategy in Section 3 of the document. national and regional gateway. Petroplus wishes consultation zones around that refinery. However, the core strategy does for this role to be explicitly recognised and not include any proposals which affect that refinery. explicitly protected in the Castle Point Core Petroplus believe that the current Core Strategy is not consistent with National Planning Policy which Strategy. recognises the importance of uses such as petro-chemical activity and the proper consideration of the relationship between such uses and proposed new development in close proximity.

Further to this, for over 30 years, the Operators of Coryton Refinery Complex have consistently supported the protection of a ‘Buffer Zone' around the Petro-Chemical Complex, and this has been both accepted and supported by Inspectors and Secretaries of State. The Operators have made it part of Company Policy to retain land outside of its operations, and reserve holdings as a buffer, held on health and safety grounds, between the refinery and built up areas surrounding the complex.

Based on these comments, our client Petroplus considers that Castle Point Borough Council should make reference to the Coryton Oil Refinery Complex, which is located in close proximity to the Borough. Further to this, we believe that a buffer should also be adopted surrounding the zone to the east of the Petro-Chemical Complex. 250 Table 2 WM Morrisons Cara Ware S Morrisons supports the following aspects of the Core Strategy Spatial Portrait: W No response required. A Portrait of Castle Supermarket Plc Peacock and Smith Point (a) the provision of jobs in the town centres and the clear consequential acknowledgement that retail development supports employment;

(b) the concern that the town centres lose a substantial proportion of expenditure to regional centres which has implications for environmental quality and investment;

(c) the master plan being commissioned by the Regeneration Partnership for Hadleigh Town Centre. 332 Table 2 Mr Roy Lewis U J Early Years and Childcare facilities and provision - Early Years and Childcare facilities are an E Essex County Council would wish to attend the Minor amendments proposed as suggested by Essex County Council. A Portrait of Castle Essex County important and essential aspect of the provision of a full range of educational and learning facilities. oral part of the examination to further elaborate Point Council The Core Strategy fails to fully acknowledge the requirement for such facilities to support sustainable its representations on the Core Strategy; to community development. Accordingly, the Core Strategy should be amended to make appropriate provide the wider sub-regional/ regional context reference to provision of Early Years and Childcare facilities, in addition to that already included in for matters included within the Core Strategy; the document and in the comments above, by inserting appropriate text in, and to provide technical assistance on matters relating to delivery of County Council services.

• Table 2, Education Facilities Characteristic - with the Essex County Council ‘Childcare Sufficiency Assessment' providing the portrait that would be required. • Appendix C - the evidence base should include ‘ECC Childcare Sufficiency Assessment'

339 Table 2 Cllr Martin Tucker U J Table 2: A Portrait of Castle Point, Local People, p.12 E As elected representatives of Castle Point With regard to the split between the towns in Castle Point, it is agreed that A Portrait of Castle Canvey Island Borough Council residents, and with multiple there are four settlements in the Borough. Point Independent Party representations made for consideration, CIIP The CS suggests that the population of Castle Point is divided into two distinct areas - the mainland would like to participate at the oral part of the towns (Benfleet, Thundersley and Hadleigh) and Canvey Island. Dividing the borough into these two Canvey has a population of around 40,000 people. The remaining examination to justify and clarify the document distinct areas and producing a spatial plan based on this premise has lead to the proposal of a mainland towns of Benfleet, Hadleigh and Thundersley have a combined submitted in response to the Core Strategy. majority of development being placed on a flood plain (Flood Risk Zone 3). It is more appropriate to population of around 48,000. suggest that there are four main towns in Castle Point - one of which is located completely in a Flood Risk Zone 3. The statement is misleading and unjustified. The mainland towns are clearly distinct from Canvey in terms of landscape character, socio-economic conditions and residents identity of place. Socio- Table 2: A Portrait of Castle Point, Role in the sub-region, p.13 economic conditions in particular give rise to the need for additional homes, jobs and community facilities on Canvey Island that are distinct to the needs of the mainland towns. The CS suggests that ‘Castle Point has a complimentary role to play by supporting [Basildon and Southend] in two respects' - ‘as a residential area' and a ‘green area'. Although this is agreed, there is not enough detail that reinforces the borough's role as a labour pool for not only Basildon and The mainland towns, whilst separated by swathes of Green Belt land are Southend, but London as well. more similar in identity, with similar socio-economic conditions. Deprivation is generally less severe in the mainland towns, and exist in pockets in each of the towns. In their Castle Point Employment Study Report (2006), commissioned by CPBC, Roger Tym and Partners make the following statements: The distinction made between Canvey and the Mainland is therefore considered appropriate, as it recognises the distinct differences of Canvey. 8.9 It is in the interests of Castle Point residents to ensure that development in Basildon and Southend is a success. Given the economic dependence of Castle Point on the economic viability of neighbouring employment areas of Basildon and Southend, we suggest that the interests of Castle With regard to the need to recognise the role Castle Point plays in labour Point residents are well served by resurgent jobs and employment markets in Southend and supply, a minor amendment is proposed to Table 2 on page 13.

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Basildon. Castle Point should ensure that its strategies work well within this broad remit.

8.10 We suggest that Castle Point is best seen as part of a mini-conurbation dominated by Southend in the East and Basildon in the West. This mini-conurbation is, in turn, firmly within the London orbit. Castle point's role within this mini-conurbation is to provide workers for these three economic centres. This is implicitly recognised in the Planning Inspector's deletion of the mention of Castle Point as a "business hub" in the original draft Regional Spatial Strategy.

It is very important to reinforce this point as it has significant implication on the spatial planning of Castle Point.

10 4 Mrs Patricia Gunn U E Nowhere in the spatial vision is the mention of the MUCH NEEDED road off Canvey. If the Canvey W The vision sets out a what Castle Point will look like in 2026, including the Vision, Aims and Way was built properly in the first place (i.e. a dual carriageway) and extended through to either improvement of local road infrastructure. Whilst the Council supports the Objectives Thurrock or Stanford (or even to the Five bells roundabout) there not be the need to spend a fortune provision of a third road off of Canvey Island, as set out in policy CP3, at the Sadlers Farm roundabout. Until this is done parts 4.1 - 4.3 are a pipe dream. there is a recognition that a) this is not the only project that will improve local congestion issues; and b) there are uncertainties regarding the funding and routing of such a route that would make it unrealistic to highlight it in the vision. As a result, the vision as it currently stands without specific reference to a third road is considered deliverable and therefore effective and sound. 13 4 Helen De La Rue S J The Council's strong approach to sustainability is supported. E No response required. Vision, Aims and East of England Objectives Regional Assembly 169 4 Mr JAMES U J The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The HSE recognise that the presence of these installations pose a risk to Vision, Aims and TRIMMER Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the residents and businesses on the island because they require the authority Objectives PORT OF LONDON and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove to consult them in respect of development within the consultation zone AUTHORITY adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey around the installations. The council recognises that these installations are integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should controlled by the HSE but this control does not extinguish the risk to the cargo per annum. properly be discussed at the examination. The community. It is for these reasons that the HSE has previously advised PLA, as landowner of one of the terminals and against the granting of planning permission at these sites and within the as the Statutory Port Authority for the port within consultation zone referred to above. The council's strategy seeks to reduce The PLA contends that Section 4 (and more particularly the final paragraph of the spatial vision at which the terminals operate, contends that it risk to residents and businesses in the borough in the light of incidents at Paragraph 4.3) is not justified and that the Core Strategy is therefore unsound. No robust evidence is should participate in any such discussion. these sites and elsewhere in the UK. adduced to substantiate the claim that the terminals pose any safety risk and that any expansion and/or change in the materials handled, stored and distributed from the terminals would result in any long-term safety concerns. There is no robust evidence to suggest that any alternative comparable There is therefore clear evidence that the strategy would result in the sites have been identified and/or secured for the proposed relocation of the two cargo-handling reduction of risk and address long term safety concerns of residents and terminals. No robust evidence is adduced to substantiate the various claim that the benefits of any businesses on Canvey. The approach would therefore facilitate the proposed future redevelopment of the terminals would, in any way, be realised. redevelopment of these sites for a range of uses that would make Canvey a more sustainable community and assist in delivering the spatial vision. Furthermore, no robust evidence is adduced to substantiate the claim that the approach taken represents the most appropriate strategy when considered against the reasonable alternatives, and in particular the continuation of cargo-handling at the terminals.

The PLA contends that only the deletion of this element of the spatial vision and its replacement with an approach which provides for the continuation of the current cargo-handling uses at the terminals will remedy these deficiencies and make the Core Strategy sound. 170 4 Mr JAMES U E The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The council does not oppose the use of the PLA land for mixed uses Vision, Aims and TRIMMER Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the including part of the site for cargo handling. However, the council believes Objectives PORT OF LONDON and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove that the use of the land for the storage of hazardous substances is not AUTHORITY adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey appropriate in the longer term, particularly in the light of the integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should 'Recommendations on land use planning and the control of societal risk cargo per annum. properly be discussed at the examination. The around major hazardous installations' report issued by the Buncefield Major PLA, as landowner of one of the terminals and Incident Investigation Board. The council would point out that the major as the Statutory Port Authority for the port within part of the land owned by the PLA is not used for cargo handling and that The PLA contends that Section 4 (and more particularly the final paragraph of the spatial vision at which the terminals operate, contends that it its use for such purposes would have significant environmental implications Paragraph 4.3) is not effective and that the Core Strategy is therefore unsound. The PLA acquired its should participate in any such discussion. for Canvey Island as a whole. The council would therefore wish to work landholdings in Canvey Island over seventy years ago. It is operational land for the purposes of the with the landowners to ensure that the long term future of the land would Planning Acts. The PLA remains fully committed to the utilisation of the Oikos site for cargo- accommodate the reasonable expectations of the PLA and the handling. It has no intention of disposing any or all of the site for alternative development throughout community on Canvey Island. The council believes that the strategy is the plan period. deliverable in the longer term and would wish to work with the landowners to achieve this. It therefore believes that the Core Strategy is sound. The Council is aware of the PLA's position in relation to the long-term future of the Oikos site, and the approach promulgated within the spatial vision is clearly not deliverable. As such, it fails the test at Paragraph 4.45 of PPS12 and, the PLA would contend, the Core Strategy is therefore unsound.

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171 4 Mr JAMES U N The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The council does not agree that the spatial vision is inconsistent with Vision, Aims and TRIMMER Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the national policy. It is aware of the draft Overarching National Policy Objectives PORT OF LONDON and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove Statement for Energy (EN1) and believes that Canvey Island is not a AUTHORITY adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey suitable location in the long term for the storage and distribution of gas and integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should petroleum products for reasons set out in the Statement. The statement cargo per annum. properly be discussed at the examination. The imposes a requirement on the Infrastructure Planning Commission to have PLA, as landowner of one of the terminals and undertaken an assessment of alternative locations for these forms of as the Statutory Port Authority for the port within development. The council does not accept that Canvey is a suitable The PLA contends that Section 4 (and more particularly the final paragraph of the spatial vision at which the terminals operate, contends that it location for such development in the longer term. Paragraph 4.3) is not consistent with national policy and that the Core Strategy is therefore unsound. should participate in any such discussion. Both the Oikos and Calor terminals are strategically important to the national and regional economies, handling petroleum products which are close to major centres of demand and which can The council would point out that policies T10 and T11 of the RSS indicate distributed sustainably by pipeline; to both the UK Oil Pipeline (UKOP) and Government Pipeline and a preference for land based transport to be by rail rather than road. Storage System (GPSS) from the Oikos Terminal and to the Coryton Refinery in Thurrock from the However these sites do not have rail access and such provision could not Calor Terminal. The draft Overarching National Policy Statement for Energy(EN1) notes that the UK be easily achieved. must ensure that it has access to safe and secure supplies of oil and gas. For these reasons the council maintains that the Core Strategy is sound Such an approach requires well located import terminals with access to pipeline distribution and consistent with national and regional policy. networks. The draft National Policy Statement for Ports notes that ports have a vital role in the import and export of energy supplies and furthermore that ensuring the security of energy supplies into UK ports is an important consideration.

The PLA would further contend that the Council's approach within the Core Strategy is not consistent with the published RSS, and in particular Policies T10 (Freight Movement) and T11 (Access to Ports).

The PLA contends that only the deletion of this paragraph of the spatial vision and its replacement with an approach which provides for the continuation of the current cargo-handling uses at the terminals will remedy these deficiencies and make the Core Strategy sound. 191 4 Mrs Irene Thomas U J Not robust and credible - W With regard to development on Canvey, the proposed development Vision, Aims and locations have been subject to a sequential test as per PPS25. The Objectives proposed locations set out in the Core Strategy were found to be No further houses should be built on Canvey Island as it is classified a flood risk zone 3 area sequentially appropriate and therefore consistent with PPS25. especially when an alternative area exists.

With regard to the referendum, it is recognised that there are concerns The residents of Canvey votes almost 100% against the building on Canvey in a referendum of more about further development on Canvey Island. Previous consultation carried than 6450 Canvey residents. out in Spring 2006 identified that residents in Thundersley were resistant to development in North West Thundersley, and consultation in the summer The residents of the Chase are against any further dwellings being built as it would affect the wild life of 2008 revealed that residents in Daws Heath were resistant to and add to the traffic problems. development in that location also. It is considered that Green Belt development will evoke a reaction from nearby residents in almost any location in which it is proposed and that therefore the best response the A reasonable alternative - Council can take to the issue is to limit the overall quantum of development proposed in Green Belt locations as far as is reasonably possible. Relocate the existing manor trading complex to the north Benfleet area adjacent to the A130 roundabout; also construct more commercial premises in the same area, thus giving more job The consultee suggests that an urban extension to the North West of opportunities. All new commercial/industrial structures would be much more eco friendly thus helping Thundersley is a reasonable alternative. This was considered as part of the to reduce our carbon footprint. All traffic associated with the existing manor trading and all new initial issues and options consultation in the Spring of 2006. It was found commercial traffic will have direct access to the A130 roundabout/major trunk roads thus relieving that this location was undesirable to statutory consultees and residents existing traffic trouble spots and health hazards etc. On the existing manor trading area new, alike. The site, as set out in the Sustainability Assessment of Sites is including affordable eco friendly homes can be built benefiting all. unsustainable, as it is remote from the existing urban area, and would result in additional movements on the A130. The Highways Authority have objected to this proposed location due to its impacts on the strategic road network. Furthermore, the proposed area of development is far greater than that required to meet housing requirements beyond the urban capacity. This would result in a loss of Green Belt far in excess of the Core Strategy proposals. As such the decision to exclude this location from the Core Strategy is justified, and consistent with national policy. 194 4 Mrs Irene Thomas U N National Policy W With regard to development on Canvey, the proposed development Vision, Aims and locations have been subject to a sequential test as per PPS25. The Objectives proposed locations set out in the Core Strategy were found to be Against National Policy - Canvey Island is within Flood Zone 3 and any new development on Canvey sequentially appropriate and therefore consistent with PPS25. would go against the Environment Agency Guidance lines when alterative areas in Castle Point are available e.g. the land adjacent to the A130 as used in the Manor Regenerations & development Company Ltd. proposal and as identified by the Council's Special Policy Development Group. The private members bill has not been passed and does not therefore form part of national legislation. Against National Policy - Also it would go against MP Bob Spink's private members bill which if passed would prevent new developments on flood plains. The Health and Safety Executive have not raised an objection to the Core Strategy.

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Against National Policy - Also I believe it would against "Health & Safety" in general. therefore considered to be consistent with national policy.

196 4 Mrs Irene Thomas U E Not deliverable because Canvey Island is within Flood Zone 3 and thus no new development of W With regard to development on Canvey, the proposed development Vision, Aims and houses should be considered. Also the cost of building on a flood plain may be an unattractive locations have been subject to a sequential test as per PPS25. The Objectives venture for any developments particularly in this financial economic climate, thus this could result in proposed locations set out in the Core Strategy were found to be a shortfall of the given quota for Castle Point. sequentially appropriate and therefore consistent with PPS25. None of the sites proposed are in the functional flood plain as the entire island is substantially defended from flooding. Developers with land interests on Not Sound Infrastructure the residents and businesses of Canvey Island experience terrible traffic Canvey are currently working on proposals for Canvey Island that include problems every day now. Any new proposed developments would add drastically to the existing daily flood mitigation measures, suggesting that the costs are not prohibitive and traffic chaos and further obstruct evacuation in an emergency. Also it could drive existing businesses that the proposed sites are deliverable. The Core Strategy is therefore away from Canvey to other areas. Also surface water is already a problem, any new developments effective with regard to this matter. would only add to the problem.

With regard to infrastructure, policies CP1 to CP4 address the provision of Violate Planning barriers Canvey Island is a flood plain (Flood Zone 3) any new development of infrastructure to resolve existing issues and support new development. houses would go against the Environment Agency guide lines. Also against the wishes of virtually Traffic models indicate that whilst peak time movements on Canvey can be 100% of Canvey residents. greater, overall there is capacity in Canvey's road network. The Roscommon Way extension and improvements to Sadlers Farm will help to Flexible by developing the are adjacent to the A130 as identified by the Special Policy Development relieve congestion points. With regard to surface water, problems exist group and used in the Manor Regeneration Proposal, then this proposal could be extended at any mainly in areas where drains are not adopted. New developments will be time and thus is flexible and can be monitored. expected to be served by adoptable drainage systems, and manage surface water on site (CP4). This will help to ensure that new development does not contribute towards surface water problems. A Surface Water Management Plan is proposed in policy CP4 to deal with existing issues.

With regard to local objection to development, it is recognised that there are concerns about further development on Canvey Island. Previous consultation carried out in Spring 2006 identified that residents in Thundersley were resistant to development in North West Thundersley, and consultation in the summer of 2008 revealed that residents in Daws Heath were resistant to development in that location also. It is considered that Green Belt development will evoke a reaction from nearby residents in almost any location in which it is proposed and that therefore the best response the Council can take to the issue is to limit the overall quantum of development proposed in Green Belt locations as far as is reasonably possible.

The consultee suggests that an urban extension to the North West of Thundersley is a reasonable alternative. This was considered as part of the initial issues and options consultation in the Spring of 2006. It was found that this location was undesirable to statutory consultees and residents alike. The site, as set out in the Sustainability Assessment of Sites is unsustainable, as it is remote from the existing urban area, and would result in additional movements on the A130. The Highways Authority have objected to this proposed location due to its impacts on the strategic road network. Furthermore, the proposed area of development is far greater than that required to meet housing requirements beyond the urban capacity. This would result in a loss of Green Belt far in excess of the Core Strategy proposals. As such the decision to exclude this location from the Core Strategy is justified, and consistent with national policy. 199 4 Mr Bruce Paterson U J I would like to lodge my objection regarding the totally unjust & biased scoring system that the Castle E In every planning application I have proposed to 396 to 408 London Road was assessed against the Sustainability Criteria Vision, Aims and Point Council planning officers applied to the 38 sites in the Core Strategy Preferred Options Report C.P.B.C. in relation to this site, all but 2 have set out in the Sustainability Assessment of Sites on the Urban Periphery Objectives 2007. This scoring system is totally unjust and unfair, and in particular the score applied to my site at been refused on the grounds the land lies within (2008). This found the site to be relatively unsustainable. Following a 396 London Road, Benfleet (appendix C 36) in comparison to equivalent sites within the 38 selected the green belt. In 25 years of owning this site revision of the methodology to weight some criteria more important than sites in the borough. For example they stated that our site is a "prominent wooded green belt this is the first opportunity I would have of others (based on public consultation results), the site scored relatively location”,” wood site with landscape character" which it clearly is not. appealing my case before an Inspector. Who better in terms of sustainability. would have the authority to exclude this land from within the green belt. "This site is too remote to provide benefits to the wider community" Is there any piece of land within However, the site is located in the Metropolitan Green Belt in a location that the borough that is to remote? is important for preventing urban sprawl and the coalescence of place. The This is extremely important as if I am refused landowner has made several applications for the redevelopment of this this opportunity to put my case before the site, and for its further use for Car Sales. These applications have been "Access to the public transport but remote from facilities & services" This site is exactly .8 of mile inspector it could be a further 25 years before refused on Green Belt terms and where appealed the Planning Inspector from the council offices. another opportunity arises. has supported the Council's position that the Green Belt in this location is of strategic importance (App: CPT/553/98/FUL/VAR/C). The site is "Removed from the town centres, but likely to pass through them if leaving the borough". It is only a currently subject of enforcement action for failure to recognise the ten minute walk to main Tarpots shopping centre. decisions of these previous applications.

Comparing these comments with the criteria set for all the 38 chosen sites it is clear and obvious that It is recognised that there are objections to other sites in the Green Belt. the scores set for 396 London Road, Benfleet (appendix C 36), has been applied unjustly, unfairly, However, it is considered that whilst this site does not look pretty, it is in the Page 24 of 222

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and totally in a negative bias, and completely inconsistent with the criteria set. Green Belt and does perform a strategic function. As a result, the Council is of the view that the exclusion of this site from the Core Strategy is justified and consistent with national policy. 204 4 Mr Bruce Paterson U J Policy SS2 E In every planning application I have proposed to 396 to 408 London Road was assessed against the Sustainability Criteria Vision, Aims and C.P.B.C. in relation to this site, all but 2 have set out in the Sustainability Assessment of Sites on the Urban Periphery Objectives been refused on the grounds the land lies within (2008). This found the site to be relatively unsustainable. Following a The criteria applied to these policies SS1 & SS2 are totally, unsound, unjust & unfair, and the green belt. In 25 years of owning this site revision of the methodology to weight some criteria more important than inconsistent with the criteria set. In particular this council has chosen green belt sites that are against this is the first opportunity I would have of others (based on public consultation results), the site scored relatively the public interest to be developed, whilst they have ignored more suitable sites that have no public appealing my case before an Inspector. Who better in terms of sustainability. objection, I would like to draw the inspectors attention to 2 sites in particular being the land East of would have the authority to exclude this land Rayleigh Road, Benfleet (Appendix C 1), which has had nothing but public protests and objection yet from within the green belt. my own site at 396 London Road, Benfleet (appendix C 36) which has a petition of over 1500 However, the site is located in the Metropolitan Green Belt in a location that signatures in favour of development has been overlooked. is important for preventing urban sprawl and the coalescence of place. The This is extremely important as if I am refused landowner has made several applications for the redevelopment of this this opportunity to put my case before the site, and for its further use for Car Sales. These applications have been The unsound criteria applied to al 28 chosen sites is inconsistent, unjust and in most cases totally inspector it could be a further 25 years before refused on Green Belt terms and where appealed the Planning Inspector biased. And as such I wish to appeal the inclusion of the land at 396 London Road, Benfleet, being another opportunity arises. has supported the Council's position that the Green Belt in this location is kept within the Green Belt. of strategic importance (App: CPT/553/98/FUL/VAR/C). The site is currently subject of enforcement action for failure to recognise the decisions of these previous applications.

It is recognised that there are objections to other sites in the Green Belt. However, it is considered that whilst this site does not look pretty, it is in the Green Belt and does perform a strategic function. As a result, the Council is of the view that the exclusion of this site from the Core Strategy is justified and consistent with national policy. 213 4 Calor Gas Limited Mr Geoff Bullock U J Also Effective and consistent with national policy E The representations involve issues that would The council recognises that the Calor Terminal is regulated by the HSE Vision, Aims and RPS Planning benefit from being presented orally at under the COMAH Regulations. However the effect of that regulatory Objectives examination. regime is not to extinguish all risks to life and property for residents and Section 4 - Vision, Aims and Objectives, final paragraph Page 22 ‘The Spatial Vision' and businesses on Canvey Island and in the wider area. Table Page 24, ‘Make Castle Point a safer, healthier place to live'

The council also appreciates the significance of the LPG terminal to Calor's Calor strongly objects to the final paragraph of the proposed ‘Spatial Vision' for Castle Point' on core business. Page 22 and Aim 5 ‘Make Castle Point a safer, healthier place to live' and Objective 2 under Aim 5, in the Table on Page 24. These state that the LPA will seek the removal of the Calor and Oikos operations from the Borough and secure the sites for "safe and sustainable redevelopment for new The council's approach takes a long term view of the sustainability of the uses" also that "Further expansion of the hazardous uses in this location will be resisted". location of this site and the adjoining land in close proximity to the residential and business community on Canvey Island. Calor's objection is based upon the fact that the Spatial Vision for Castle Point and Aim 5/Objective 2 do not take account of the following: The councils approach is also in conformity with the draft overarching NPS which envisages a transition to a low carbon economy after 2020. The council does not preclude the future use of the land for the handling of non • i) The LPG Terminal is regulated under the COMAH (Control of Major Accident Hazards) hazardous cargo in the longer term. Regulations. Any proposals to change or expand the operations at the Terminal would need to satisfy both the HSE and the EA. It is therefore unreasonable to preclude future developments at the Site on the grounds of making Canvey Island a safer place as these The council is aware of the provisions of PPS12 and maintains that its will need to satisfy the stringent controls and standards that are imposed by COMAH, the approach looks forward to 2026 and beyond and represents a flexible way HSE and the EA. of dealing with changing circumstances over the longer term particularly in response to the need to adapt to carbon reduction.

ii) The LPG Terminal is a critical component of Calor's core business, supplying LPG to • The council has sought to work with landowners and key delivery agencies homes and businesses across the UK. Calor is the leading supplier of LPG in the UK, a and will continue to do so in the future. fuel upon which numerous businesses and homes depend. The continued operation of the Site for LPG purposes is therefore of national economic importance. Indeed, the Site is now of increased importance following the closure of Calor's LPG storage site and import terminal at Felixstowe in 2009.

• iii) Calor is committed to the continued operation of the LPG Terminal in the long term, irrespective of any future decision to expand the LPG operations or advance a LNG scheme at the Site. The LPG Terminal will not therefore be available for alternative uses over the LDF period or in the longer term. Calor has consistently informed the LPA that the Site is not available for alternative uses.

• iv) Government energy policy is clear in stating that the provision of additional gas supply and storage infrastructure (including LNG importation facilities) is in the national interest, given the rapid decline in UK gas reserves and the increased reliance of the country on imported gas. New gas infrastructure is needed to ensure secure supplies of gas to the UK; to provide resilience in the event of any supply disruptions; and to assist in maintaining stable gas prices. The urgent need for such infrastructure has recently been reaffirmed by the Government through the publication on 9 November 2009 of a series of draft National Policy Statements (NPSs) for consultation. The NPSs form part of the

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Government's new regime for dealing with Nationally Significant Infrastructure Projects (NSIPs). The draft Overarching Energy NPS (Part 3) sets out the need for new energy infrastructure, including gas supply infrastructure and pipelines. Paragraph 3.9.1 highlights that the UK remains highly dependent on natural gas for the foreseeable future. The draft NPS states that a range of infrastructure is required to ensure secure gas supplies, including new LNG importation facilities.

The LPG Terminal is one of only a limited number of sites within the UK, and in particular, the south- east, that provides deep-water access for shipping. As such, the Site is part of a finite resource. This deep-water access makes the Site potentially suitable for a LNG importation facility, combined with the large amount of brownfield land available for development, the relative proximity to the National Gas Transmission System (NTS) and also the fact that it is close to a major centre of gas demand. The technology specific energy NPS relating to gas supply infrastructure confirms that all of these factors are important in considering the location of a LNG facility. Even if the Site was not used for LNG, it would be suitable for other activities that depend on deep-water access, such as port-related operations.

Furthermore, Calor considers that in preparing the Core Strategy the LPA has not had sufficient regard to PPS12, which provides guidance on Local Spatial Planning and, in particular, the preparation of Core Strategies.

Paragraph 4.1 confirms that Core Strategies should include a ‘Delivery Strategy' setting out how the strategic objectives in the Core Strategy will be achieved. Paragraph 4.4 states that the Delivery Strategy should be central to the Core Strategy and needs to set out as far as practicable when, where and by whom actions will take place. It goes on to state that:

"It needs to be demonstrated that the agencies/partners necessary for its delivery have been involved in its preparation, and the resources required have been given due consideration and have a realistic prospect of being provided in the life of the strategy. If this is not the case, the strategy will be undeliverable". [our emphasis ]

The issue of delivery and engagement with ‘Delivery Stakeholders' is dealt with further at paragraphs 4.27 to 4.29 of PPS12. Paragraph 4.28 states that it is essential that the stakeholders key to the plan's delivery (paragraph 4.29 confirms that this includes major landowners) are engaged early in the production of the Core Strategy and:

" There is no point in proceeding with options for the Core Strategy which cannot be delivered as a result of failure to obtain the agreement of key delivery agencies . Stakeholders also need to be engaged earlier to avoid later and unexpected representations emerging at the end of the process which might render the plan unsound and lead to lengthy delays in the delivery of a robust planning framework for the area. Local authorities are strongly encouraged to seek out major landowners and developers and engage them fully in the generation and consideration of options. This should help ensure that the core strategy is deliverable ". [our emphasis]

Paragraph 4.45 of PPS12 considers delivery further and states that partners who are essential to the delivery of the plan, such as landowners and developers, should be signed up to it.

PPS12 sets out a test to enable Inspectors to determine whether a Core Strategy is ‘sound'. These (as confirmed above) are that the Core Strategy is justified; effective; and consistent with National Policy.

‘Justified' means that the document must be:

• founded on a robust and credible evidence base; and • the most appropriate strategy when considered against the reasonable alternatives.

Paragraph 4.37 of PPS12 confirms that the evidence base should contain two elements, which include ‘Participation' in the form of evidence of the views of the local community and others who have a stake in the future of the area; and ‘Research/fact finding', namely evidence that the choices made by the plan are supported by the background facts.

PPS12 confirms that ‘Effective' means that the document should be:

• deliverable; • flexible; and

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• able to be monitored.

With regard to deliverability, paragraph 4.45 of PPS12 states that evidence should include ensuring that partners (e.g. major landowners) who are essential to the delivery of the plan are signed up to it.

Having regard to the guidance set out in PPS12, Calor considers that the Spatial Vision, fails the test of ‘soundness' for a number of reasons.

• i) The proposals within the Core Strategy document for the redevelopment of the Calor LPG Terminal Site for alternative uses are not founded on a robust or credible evidence base. In particular, the document does not acknowledge that the existing LPG Terminal is a facility regulated and operated under the COMAH Regulations. The LPA has also disregarded previous representations from Calor that make clear that the Site is critical to its core business and is not available for alternative uses either now or in the longer term. Furthermore, the LPA has not entered into a significant dialogue with Calor during the preparation of the Core Strategy to discuss or establish the feasibility of redeveloping the Site. PPS12 is very clear in stating that LPAs should engage with key stakeholders, which includes major landowners; otherwise the plan will be unsound. • ii) There is no realistic prospect of the proposals in the Core Strategy for the redevelopment of the Site being delivered as the Site is not available and Calor is committed to its long term operation for LPG purposes, irrespective of any future decision to advance other proposals at the Site. PPS12 clearly states that it needs to be demonstrated that the stakeholders necessary for the delivery of the strategy are signed up to it and that there is a realistic prospect of the resources required being provided within the lifetime of the strategy. Calor has not agreed to the redevelopment of the Site or indicated that it would be prepared to make the site available. In addition, the LPA has not identified any interventions or funding to deliver the redevelopment of the site. In short, this element of the Core Strategy is not deliverable. • iii) The Core Strategy is not reflective of current or emerging National Policy in that it fails to recognise the national need that exists for additional gas storage infrastructure in the UK and the fact that Calor's LPG Terminal is a potentially suitable location for a LNG facility given its deepwater access, and its proximity to the NTS and markets.

In view of the above, Calor strongly urges the LPA to amend the Core Strategy document to recognise that Calor's LPG Terminal will not be available within the LDF period or in the longer-term and that it is a potentially suitable location for a LNG facility. 238 4 Mrs M WHITE U N Against National Policy: W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is Because Canvey Island is within Flood Zone 3 any new dwellings would go against the Environment therefore considered sound in this regard. Agency guide lines when alternative areas are available in Castle Point e.g. the land adjacent to the A130 as identified by the Council's Special Policy Development Group and as used in the Manor Regeneration & development Company Ltd. proposal. The consultee supports the inclusion on an urban extension to the North West of Thundersley in the Core Strategy. This was identified as a spatial option during consultation in the Spring 2006. Both statutory consultees and residents raised objections to this proposal. The Sustainability Assessment of Sites on the Urban Periphery found this site to be unsustainable, particularly as a result of its remoteness to the existing urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location. 239 4 Mrs M WHITE U J Not justified because: not robust and credible: W It is recognised that there are concerns about development on Canvey. Vision, Aims and However, as part of previous rounds of consultation the residents of Objectives Thundersley (Spring 2006) and the residents of Daws Heath (Summer I) The residents of Canvey voted almost 100% against the building on Canvey in a referendum of 2008) have also objected to development proposals affecting the Green more than 6450 Canvey Residents. Belt in their locality. It is clear from these consultation responses that there is a lack of appetite for Green Belt development in Castle Point. As a result, (ii) No further houses should be built on Canvey Island as it is classified a flood risk zone 3 area. the Core Strategy sets out proposals that minimise the loss of Green Belt to the quantum that is needed to meet local needs. The Core Strategy is considered justified in this approach. (iii) The Regional assembly finds the Core strategy "Unsound"

The proposed distribution set out in the Core Strategy has been subject to (iv) The chase has wild life implications and is against the wishes of the residents. a Sequential Test as per PPS25. This found that the distribution set out in the Core Strategy is sequentially appropriate. The Core Strategy is

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Not justifies because: a reasonable alternative: therefore considered sound in this regard.

(i) The Council's core strategy should adopt the Manor Regeneration & Development Company Ltd. The regional assembly did not find the proposed distribution unsound. proposal to relocate the existing manor trading to the area of existing plot lands to the north of the Their representations relate to matters that can be dealt with as minor estate directly opposite the A130 roundabout. The area identifies would also allow more amendments or through further policy development in later documents. The commercial/office buildings to be constructed giving job opportunities to local residents. Also the old Core Strategy was found to be in general conformity with the East of manor trading ban be cleaned up and houses built on its footprint including affordable housing. This England Plan and therefore sound in this regard. proposal would also remove the heavy good vehicle nightmare currently experienced by local residents. With regard to wildlife issues at the Chase, the quantum of development to the North of Kiln Road has been reduced to accommodate these concerns. This reduction was based on information submitted to support the planning application for this site. The Core Strategy is therefore sound in this regard.

The consultee supports the inclusion on an urban extension to the North West of Benfleet in the Core Strategy. This was identified as a spatial option during consultation in the Spring 2006. Both statutory consultees and residents raised objections to this proposal. The Sustainability Assessment of Sites on the Urban Periphery found this site to be unsustainable, particularly as a result of its remoteness to the existing urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location. 240 4 Mrs M WHITE U E Not Effective because: W With regard to development on Canvey, the proposed development Vision, Aims and locations have been subject to a sequential test as per PPS25. The Objectives proposed locations set out in the Core Strategy were found to be The proposed new houses on Canvey Island are within Flood Zone 3 and must not be built, sequentially appropriate and therefore consistent with PPS25. therefore it is Not deliverable.

With regard to infrastructure, policies CP1 to CP4 address the provision of The existing traffic problems on Canvey Island are terrible, any of the proposed development on infrastructure to resolve existing issues and support new development. Canvey would only add to the daily traffic chaos experienced by many e.g. residents businesses and Traffic models indicate that whilst peak time movements on Canvey can be visitors. Also it would greatly hinder evacuation in an emergency, therefore Not Sound greater, overall there is capacity in Canvey's road network. The Infrastructure. Roscommon Way extension and improvements to Sadlers Farm will help to relieve congestion points. With regard to surface water, problems exist Canvey already experiences major problems with surface water flooding, any new housing mainly in areas where drains are not adopted. New developments will be developments will only make matters worse, therefore Not Sound Infrastructure. expected to be served by adoptable drainage systems, and manage surface water on site (CP4). This will help to ensure that new development does not contribute towards surface water problems. A Surface Water Canvey Island is within Flood Zone 3 any new houses would go against the Environment Agency Management Plan is proposed in policy CP4 to deal with existing issues. Guide lines especially when there is a much better alternative (The Manor Regeneration Proposal incorporating the area adjacent to the A130), therefore Violate Planning barriers. With regard to local objection to development, it is recognised that there are concerns about further development on Canvey Island. Previous Almost 100% of Canvey Residents are against the proposed new development of houses, therefore consultation carried out in Spring 2006 identified that residents in Violate Planning barriers. Thundersley were resistant to development in North West Thundersley, and consultation in the summer of 2008 revealed that residents in Daws The land adjacent to the A130 should be used in conjunction with the old Manor trading area. Also Heath were resistant to development in that location also. It is considered the area adjacent to the A130 could be extended at a later date making it Flexible and all future that Green Belt development will evoke a reaction from nearby residents in works could be Monitored. almost any location in which it is proposed and that therefore the best response the Council can take to the issue is to limit the overall quantum of development proposed in Green Belt locations as far as is reasonably possible.

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242 4 Mr Gary White U N National Policy W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is Against National Policy - because Canvey Island is within Flood Zone 3 any building would go therefore considered sound in this regard. against the Environment Agency guide lines when alterative areas are available in Castle Point e.g. the land adjacent to the A130 as identified by the Council's Special Policy Development Group and as used in the Manor Regeneration & development Company Ltd. Proposal. The consultee supports the inclusion on an urban extension to the North West of Thundersley in the Core Strategy. This was identified as a spatial option during consultation in the Spring 2006. Both statutory consultees Also it would go against MP Bob Spink's private members bill which if passed would prevent new and residents raised objections to this proposal. The Sustainability developments on flood plains. Assessment of Sites on the Urban Periphery found this site to be unsustainable, particularly as a result of its remoteness to the existing urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location.

The private members bill has not been through due processes and is not yet legislation. It does not therefore carry weight at this time. 247 4 Mr Gary White U J NOT JUSTIFIED. W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is Not robust or credible and there is an alternative. therefore considered sound in this regard. With regard to the building costs associated with building on Canvey, several developers as pursuing • i) Canvey Island is classifies a flood risk zone 3 area and this no further houses should be proposals at a detailed stage, including a Housing Association. It is built on it. Especially when alternative areas are available within Castle point e.g. the area therefore considered viable to delivery housing, including policy proposed by the Manor Regeneration & Development Company Ltd. Which incorporates requirements for 35% affordable housing on Canvey. The Core strategy is the area as outlined in Appendix B - Findings of the Green Belt Task and Finishing Group. therefore considered deliverable in this regard. Page 2 of 3 - Item 5 sub section (a) states Areas that should be given further consideration are: The consultee supports the inclusion on an urban extension to the North • (a) Adjacent to the A130 in Benfleet as there is a substantial swathe of Green Belt in West of Thundersley in the Core Strategy. This was identified as a spatial Basildon District to fulfil a separation function. option during consultation in the Spring 2006. Both statutory consultees and residents raised objections to this proposal. The Sustainability Assessment of Sites on the Urban Periphery found this site to be This was a recommendation made by one of the Special Policy Development Groups made up of unsustainable, particularly as a result of its remoteness to the existing two Councillors and one Officer specifically set up by the Council to look at the Green Belt issues, urban area, and also because of accessibility issues. The Highways flooding the rejection of the previous Core Strategy. Why has this area been left out? Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green (ii) Any properties built on a Zone 3 area would cost much more than the same property build Belt land identified for development is far in excess of the land needed to elsewhere, this not affordable, rules state 35% need to be affordable. accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location. 249 4 Mr Gary White U E Not Effective because: W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is Not deliverable - The proposed dwellings on Canvey Island are within Flood Zone 3 therefore considered sound in this regard.

Not Sound Infrastructure - Existing infrastructure on Canvey Island is already overloaded and cannot With regard to infrastructure, the Core Strategy contains infrastructure cope at times e.g. surface water drainage, foul drainage, roads etc. Any new developments on policies CP1 to CP4. These seek to improve existing infrastructure and Canvey would only add to the existing terrible problems experienced by the residents and support additional needs arising from new infrastructure. Proposals to businesses, also many businesses could leave Canvey if the existing problems are escalated. improve congestion issues on Canvey are included in this including the extension of Roscommon Way and junction improvements at Sadlers Violate Planning Barriers - Canvey Island is labelled Flood Zone 3 and any new dwellings would go Farm. Whilst it is recognised that there can be greater levels of traffic flows against the Environment Agency recommendations. Also against the wishes of almost 100% of the at peak times, traffic models indicate that there is capacity within the Canvey residents and visitors to the island. existing road network on Canvey Island to accommodate the growth proposed. With regard to surface water, most of the existing problem arises from unadopted drainage systems. Policy CP4 requires new development Flexible - If the manor Regeneration & Development Company Ltd. Proposal for the land adjacent to to be supplied by adoptable drainage systems and include sustainable the A130 was approved it could be extended at a later date, thus flexible and able to be monitored. drainage management. New development should not therefore impact on existing problems. Existing problems will be addressed through the preparation of a surface water management plan (CP4). The core strategy is therefore considered effective with regard to the delivery of supporting infrastructure.

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2008) have also objected to development proposals affecting the Green Belt in their locality. It is clear from these consultation responses that there is a lack of appetite for Green Belt development in Castle Point. As a result, the Core Strategy sets out proposals that minimise the loss of Green Belt to the quantum that is needed to meet local needs. The Core Strategy is considered justified in this approach.

It is considered that all development proposals set out in the Core Strategy can be monitored. 254 4 Mr U J Not justified because: W It is recognised that there are concerns about development on Canvey. Vision, Aims and However, as part of previous rounds of consultation the residents of Objectives D Thundersley (Spring 2006) and the residents of Daws Heath (Summer (i) "not robust or credible because" in a referendum of more than 6400 Canvey residents, the 2008) have also objected to development proposals affecting the Green residents voted almost 100% against the building on Canvey. THOMAS Belt in their locality. It is clear from these consultation responses that there is a lack of appetite for Green Belt development in Castle Point. As a result, (ii) "not robust or credible because" No further houses should be built on Canvey Island as it is the Core Strategy sets out proposals that minimise the loss of Green Belt classified a flood risk zone 3 area. to the quantum that is needed to meet local needs. The Core Strategy is considered justified in this approach. "there is an alternative" e.g. the are as outlines in The Special Policy Development Group meeting dated the 9 th September 2009 Appendix B - Findings of the Green Belt Task and The proposed distribution set out in the Core Strategy has been subject to Finishing Group (page 2 of 3 Item 5 sub section (a) i.e...... Areas that should be given further a Sequential Test as per PPS25. This found that the distribution set out in consideration... (a) Adjacent to the A130 in Benfleet as there is a substantial swathe of Green Belt in the Core Strategy is sequentially appropriate. The Core Strategy is Basildon District to fulfil a separation function. therefore considered sound in this regard.

(iii) "not robust or credible because" The Chase (area adjacent to the Council Offices) Has nature The consultee supports the inclusion on an urban extension to the North conservation interests as outlines by the findings of the Green Belt Task and Finishing Group Paper. West of Thundersley in the Core Strategy. This was identified as a spatial Also it is very unpopular with the residents. option during consultation in the Spring 2006. Both statutory consultees and residents raised objections to this proposal. The Sustainability Assessment of Sites on the Urban Periphery found this site to be unsustainable, particularly as a result of its remoteness to the existing urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location.

It is recognised that there are wildlife interests affecting land to the North of Kiln Road. As a result, based on information submitted by the landowners, the Council has reduced the capacity of this site from 310 units to 250 to accommodate the wildlife concerns. The Core Strategy is therefore considered sound in including this site in the distribution. 260 4 Mr D THOMAS U N National Policy: W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is (i) "Against National Policy because" Canvey Island is within Flood Zone 3 any new dwellings would therefore considered sound in this regard. go against the Environment Agency guide lines when alternative areas are available in Castle Point. One such area (land adjacent to the A130) was identified by the Council's Special Policy Development Group and was used in the Manor Regeneration proposal. This proposal would benefit The consultee supports the inclusion on an urban extension to the North all e.g. clean up the old trading area and construct new eco friendly homes, remove the heavy goods West of Thundersley in the Core Strategy. This was identified as a spatial vehicles from residential areas, give access to heavy goods vehicles straight onto the A130 and option during consultation in the Spring 2006. Both statutory consultees adjacent major trunk roads, construct new eco friendly industrial/commercial premises giving extra and residents raised objections to this proposal. The Sustainability jobs and extra rates for the Council to use effectively etc. Assessment of Sites on the Urban Periphery found this site to be unsustainable, particularly as a result of its remoteness to the existing

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urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location.

Furthermore, the developer of the proposals for North West Thundersley, has not provided any information to support the claims that the new development would be eco-friendly in design. 269 4 Mr D THOMAS U J Not effective because: W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is • (i) "Not deliverable" because the proposed buildings on Canvey Island are within Flood therefore considered sound in this regard. Zone 3, and this must not be built. (ii) "Not Sound infrastructure" because of the existing traffic problems on Canvey Island, • With regard to infrastructure, the Core Strategy contains infrastructure any of the proposed development on Canvey would cause daily traffic chaos and hinder policies CP1 to CP4. These seek to improve existing infrastructure and evacuation in an emergency. Also prolonged traffic jams apart from causing frustration and support additional needs arising from new infrastructure. Proposals to its associated consequences, increases our carbon footprint (more fuel burnt etc.) improve congestion issues on Canvey are included in this including the • (iii) "Violate Planning Barriers" because Canvey Island is within Flood Zone 3 any extension of Roscommon Way and junction improvements at Sadlers buildings would go against the Environment Agency Guide lines, especially when there is Farm. Whilst it is recognised that there can be greater levels of traffic flows an ideal alternative the A130 Manor Regeneration Proposal. Also building on Canvey at peak times, traffic models indicate that there is capacity within the would go against the wishes of almost 100% of the Canvey residents as shown in a recent existing road network on Canvey Island to accommodate the growth Canvey referendum. proposed. With regard to surface water, most of the existing problem arises • (iv) "Flexible" By using the Manor Regeneration Proposal which incorporates the land from unadopted drainage systems. Policy CP4 requires new development adjacent to the A130, and which was identified by the Council's Special Policy to be supplied by adoptable drainage systems and include sustainable Development Group, could be extended at any time thus flexible. drainage management. New development should not therefore impact on • (v) "Monitored" The Manor Regeneration Proposal if extended can be monitored. existing problems. Existing problems will be addressed through the preparation of a surface water management plan (CP4). The core strategy is therefore considered effective with regard to the delivery of supporting infrastructure.

It is recognised that there are concerns about development on Canvey. However, as part of previous rounds of consultation the residents of Thundersley (Spring 2006) and the residents of Daws Heath (Summer 2008) have also objected to development proposals affecting the Green Belt in their locality. It is clear from these consultation responses that there is a lack of appetite for Green Belt development in Castle Point. As a result, the Core Strategy sets out proposals that minimise the loss of Green Belt to the quantum that is needed to meet local needs. The Core Strategy is considered justified in this approach.

It is considered that all the development proposals set out in the Core Strategy can be monitored. 294 4 Mr U J I have seen the document called the Core Strategy and I simply could not understand it. How do you W It is recognised that the Core Strategy deals with some quite complicated Vision, Aims and expect Elderly people to be able to read and understand such a difficult and complicated book. It matters, and therefore the consultation letter and consultation notice both Objectives T seems difficult for those who don't use the internet or email to make their views known. provided contact details for people to be able to phone up and ask questions about the Core Strategy, and request hard copies to be posted to Monks them. Furthermore, both the consultation letter and notice clearly stated It has been explained to me that one of the ideas you intend to impose on use is to build 250 houses that hard copies were available to view in local libraries and at the Council on green fields between Kiln Road and the Chase, next to Wensley Road. This is appalling quite Offices. It is considered that the consultation was accessible to those apart from burying one of those loveliest part of Thundersley under bricks and concrete. How on without access to the internet. Earth do you expect the people from these extra houses to be able to get onto the Kiln Road to drive

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to work or schools or the shops? With regard to development at Kiln Road, it is recognised that the area in this location is Greenfield land. The Core Strategy is supported by a SHLAA that has given careful consideration to the capacity of the urban The roads in this part of Thundersley are overcrowded and the traffic regularly comes to a standstill area. This found that there was insufficient capacity in the urban area to during the rush hours. To get out of this area cars have to travel either to Tarpots and Sadlers Farm , accommodate the quantum of development required to meet housing crawl through Hadleigh or queue up to get to Rayleigh Weir. Most families now seem to have at least needs. As a result, Greenfield land is required - the development location 2 cars each, so to add another 500 cars to this congestion is madness. to the North of Kiln Road is not within the Metropolitan Green Belt and was identified for long-term housing development in the 1998 Local Plan. A Please do not go ahead with this new housing estate in this lovely part of Thundersley. planning application for 150 units in this location is currently with the Council for consideration. Subject to contributions towards highways infrastructure nearby, the highways authority are satisfied that there is capacity in the local road network to accommodate growth in this location. The Core Strategy is therefore considered sound with regard to the matters raised in this representation. 296 4 Mr J Howard U J Participation by the local community was limited and fragmented, as shown by the distribution of the W The Core Strategy was subject to full and thorough consultation with Vision, Aims and questionnaire. An example being the proposed site for housing on land east of Canvey Road, residents in January to March 2009. The electoral register was used to Objectives residents of the Dutch Village and Charfleets should have all received questionnaires, the loss of this ensure that all residents were written to with a summary leaflet and Greenfield site and its development will have major impact to both communities. questionnaire. All respondents to this consultation were written to, alongside statutory consultees, with regard to the Regulation 27 consultation. The regulation 27 consultation was also advertised in the I would argue that the land east of Canvey Road, which was considered to be the most appropriate local press, in Viewpoint - the Council Newspaper distributed to all site for housing is wrong. A perfectly good alternative site land west of Canvey Road ‘The Triangle' households, and through press releases. The Council is therefore confident which is already partially developed would and should have been put to the local community for that the Consultation on the Core Strategy has been thorough. consideration, which could mean the green fields land east of Canvey Road would be saves for local use as is now. With regard to land to the West of Canvey Road, the consultee believes that it is a suitable alternative site to land to the East of Canvey Road. However, the Sustainability Assessment of Sites (Original and Review) found this location to be particularly unsustainable for the following reasons:

• Designated as an ancient landscape area; • Adjacent to a Local Wildlife Site; • Separated from the rest of the urban area by a busy dual carriageway - access, cohesion and road safety issues; • Used for agricultural purposes; • Visually open and therefore fulfils a strategic Green Belt function in terms of limiting urban sprawl and protecting the Countryside.

The site to the East of Canvey Road does not have these constraints and is therefore considered justified in its inclusion in the Core Strategy. It is not considered justified to include the West of Canvey Road (Triangle) Site in the Core Strategy. 298 4 Ms MICHELLE U N National Policy W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and THOMAS a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is Against National Policy - The Environment Agency is against any building of new dwellings in a therefore considered sound in this regard. Flood Zone 3 area. Land that could be used effectively is the land adjacent to the A130 which was identified by the Council's Special Policy Development Group and used in the Manor regeneration proposal which would benefit residents, businesses, the Local Council and the Government. This The consultee supports the inclusion on an urban extension to the North proposal would have practically no objections from residents, have no objections from the Wild Life West of Thundersley in the Core Strategy. This was identified as a spatial Trust and would benefit all especially reducing Carbon emissions by removing the existing old very option during consultation in the Spring 2006. Both statutory consultees un-carbon friendly trading estate and replacing, and building further commercial premises, that will and residents raised objections to this proposal. The Sustainability be eco friendly. Assessment of Sites on the Urban Periphery found this site to be unsustainable, particularly as a result of its remoteness to the existing urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location. 299 4 Ms MICHELLE U E Not effective because: W The proposed distribution set out in the Core Strategy has been subject to Vision, Aims and THOMAS a Sequential Test as per PPS25. This found that the distribution set out in Objectives the Core Strategy is sequentially appropriate. The Core Strategy is (i) Not deliverable: Canvey Island is within Flood Zone 3 therefore no new development of dwellings therefore considered sound in this regard. must take place. The A130 Manor regeneration Proposal would be a much better options and benefit all. With regard to infrastructure, the Core Strategy contains infrastructure policies CP1 to CP4. These seek to improve existing infrastructure and (ii) Not Sound Infrastructure: Any new developments on Canvey would add severely to the existing support additional needs arising from new infrastructure. Proposals to Page 32 of 222

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daily traffic chaos experienced by residents, businesses and visitors to Canvey. Also greatly hinder improve congestion issues on Canvey are included in this including the evacuation in an emergency. extension of Roscommon Way and junction improvements at Sadlers Farm. Whilst it is recognised that there can be greater levels of traffic flows at peak times, traffic models indicate that there is capacity within the (iii) Not Sound Infrastructure: Flooding due to surface water on Canvey is already a problem existing road network on Canvey Island to accommodate the growth therefore any new development would only add to the problem proposed. With regard to surface water, most of the existing problem arises from unadopted drainage systems. Policy CP4 requires new development (iv) Violate Planning barriers: Canvey Island is categorised a Flood Zone 3 area therefore any new to be supplied by adoptable drainage systems and include sustainable development of dwellings would go against the Environment Agency guide lines, especially when drainage management. New development should not therefore impact on there is an alternative i.e. the A130 Manor regeneration proposal. Also building on Canvey would go existing problems. Existing problems will be addressed through the against the wishes of almost 100% of the Canvey residents. preparation of a surface water management plan (CP4). The core strategy is therefore considered effective with regard to the delivery of supporting infrastructure. (v) Flexible & can be Monitored: The Manor Regeneration proposal would be both flexible i.e. could be easily extended if needed, and would be easily monitored and would do away with the need to build on Canvey. It is recognised that there are concerns about development on Canvey. However, as part of previous rounds of consultation the residents of Thundersley (Spring 2006) and the residents of Daws Heath (Summer 2008) have also objected to development proposals affecting the Green Belt in their locality. It is clear from these consultation responses that there is a lack of appetite for Green Belt development in Castle Point. As a result, the Core Strategy sets out proposals that minimise the loss of Green Belt to the quantum that is needed to meet local needs. The Core Strategy is considered justified in this approach.

The consultee supports the inclusion on an urban extension to the North West of Thundersley in the Core Strategy. This was identified as a spatial option during consultation in the Spring 2006. Both statutory consultees and residents raised objections to this proposal. The Sustainability Assessment of Sites on the Urban Periphery found this site to be unsustainable, particularly as a result of its remoteness to the existing urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location. 300 4 Ms U J Not justified because: W It is recognised that there are concerns about development on Canvey. Vision, Aims and However, as part of previous rounds of consultation the residents of Objectives MICHELLE Thundersley (Spring 2006) and the residents of Daws Heath (Summer (i) "Not robust or credible because"... in a referendum of more than 6400 Canvey residents, the 2008) have also objected to development proposals affecting the Green residents voted almost 100% against the building on Canvey. THOMAS Belt in their locality. It is clear from these consultation responses that there is a lack of appetite for Green Belt development in Castle Point. As a result, (ii) "Not robust or credible because"... No further houses should be built on Canvey Island as it is the Core Strategy sets out proposals that minimise the loss of Green Belt classified a flood risk zone 3 area when alternative areas are available e.g. the land adjacent to the to the quantum that is needed to meet local needs. The Core Strategy is A130 as proposed in the Manor Regeneration Proposal. considered justified in this approach.

(iii) "Not robust or credible because"... 35% of new housing needs to be affordable. New buildings The proposed distribution set out in the Core Strategy has been subject to constructed in a Zone 3 flood area would have to be designed in a sustainable manner that a Sequential Test as per PPS25. This found that the distribution set out in addresses the risks posed by climate change, flood risks and extreme weather events. This would the Core Strategy is sequentially appropriate. The Core Strategy is make such properties expensive and this mot affordable. therefore considered sound in this regard.

(iv) "Not robust or credible because".... The paper state that the "Regional assembly finds the Core With regard to the cost of construction in flood risk locations, several strategy "Unsound" developers have indicated that they are prepared to forward proposals for development on Canvey in the knowledge of affordable housing requirements. To this end, the Council is confident that the Core Strategy is (v) "Not robust or credible because alternative areas" are available within Castle point e.g. the are as justified in terms of seeking affordable housing delivery on the distribution outlined in the Special Policy Development Group meeting dated the 9 th September 2009 Appendix set out. B - Findings of the Green Belt Task and Finishing Group (page 2 or 3 Item 5 sub section (a)) i.e. Areas that should be given further consideration (a) Adjacent to the A130 in Benfleet as there is a substantial swathe of Green Belt in Basildon District to fulfil a separation function. The regional assembly did not find the distribution set out in the Core Strategy unsound. They raised some detailed issues that could be reasonably dealt with through minor amendments to the Core Strategy, or (vi) "Not robust or credible because"... because the Chase proposal is against the wishes of the in later documents. The Core Strategy was considered to be in general residents and would have implications on the wild life. conformity with the RSS, and is therefore considered sound in this regard.

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unsustainable, particularly as a result of its remoteness to the existing urban area, and also because of accessibility issues. The Highways Authority have sustained an objection to this proposal due to its potential impact on the strategic highway network. Furthermore, the area of Green Belt land identified for development is far in excess of the land needed to accommodate the quantum of development required that cannot be met in the urban area. The Council is committed to minimising loss of Green Belt and therefore the Core Strategy is considered justified in not including this site as a development location.

As a result, the population of working aged people is only expected to increase by 2,900 people in total by 2026 (2006 base). The proposed I responded to the previous "Further Options Report 2007-2021" concerning the Vision in the Core provision of jobs in Castle Point during this period is in excess of this figure, Strategy which stated an aspiration to reducing the degree of out commuting. For reference, I and therefore the ambition to decrease out commuting is reasonable to reproduce my comment as follows; include in the spatial vision.

"The previous consultation document set out a table of statistics showing the number of households in Castle Point as 35,280 and the workforce as 41,000. This equates to 0.86 households per "job". This ratio is important when considering the East of England Plan requirements for job creation and housing provision later in this Core Strategy. This will be referred to in responses to particular policies and supporting text, but in summary, 2,000 additional jobs will only support 1,720 new dwellings if the current ratio is maintained, not 4,000 as required by the East of England Plan. The amount of out commuting (referred to in several places in the Core Strategy) is therefore likely to INCREASE by some 2,651 by 2021, in direct contradiction to the expressed aim of reducing the total. It is also noted elsewhere in the proposed Spatial Strategy that a total of 5,000 new dwellings is proposed by 2026. If this figure is achieved, the amount of out commuting is likely to further increase by an additional 1,162 to give a total increase in out commuting of 3,813 by the year 2026."

In the current Final Publication Document, the Spatial Vision at paragraph 4.3 still contains the following sentence. "Out Commuting will be reduced ..."

In the current Employment Trajectory (Appendix B to the Document) it is anticipated that up to 2,950 additional jobs will be provided in addition to the 1,000 already created, giving a total of 3,950 (maximum) within the plan period. Appendix A shows a total of 5,261 new homes to be provided in the same plan period. Using the statistics provided in earlier drafts of the Core Strategy as to the ratio of households to jobs (0.86), 3,950 new jobs will only support 3,397 new households. The remaining 1,864 new homes will need a further 2,167 new jobs. This shortfall can only be accommodated by INCREASED out commuting.

The statement that "out commuting will be reduced", as set out in the Vision at the beginning of the Core Strategy, is therefore unattainable. This should be recognised and the wording of the Vision should be revised. Policies should be formulated to address this inevitable increase in out commuting and incorporated into the Core Strategy. 81 The Spatial Vision Mr Richard Inman S J We welcome the ‘Vision' statement. It is comprehensive and dated to 2026. It is detailed, specific W No response required. GO-East and pertinent to the characteristics of the Borough.

192 The Spatial Vision Oikos Storage Mr Philip U E The spatial vision is not effective because the approach outlined for the hazardous E This matter, along with the other representations The council does not rely on South Canvey for the delivery of its key Limited Rowell installations is not deliverable. This representation should be read in conjunction with all submitted by Oikos on the Core Strategy, relate housing and employment requirements. Its approach to the future of South Adams Hendry other representations submitted by Oikos on the Core Strategy Final Publication Document. to a facility of some significance. The issues Canvey is a long term strategy which responds to other considerations Consulting Ltd raised relate to the long term future of this such as the need to move to a low carbon economy and address needs strategic facility. The intentions of the Council beyond 2020. The approach therefore complies with the requirement to The Council is reminded that in respect of deliverability, PPS12 (paragraph 4.45) establishes the and Oikos are so fundamentally opposed that achieve flexibility in the long term set out in para 4.46 of PPS12. The importance of the principle that "partners who are essential to the delivery of the plan, such as the most appropriate course of action is to council does not therefore agree with the proposed text and maintains that landowners and developers, should be signed up to it". PPS12 makes it very plain in paragraph 4.28 debate the issues at the Examination in Public. the core strategy is sound. that there is no point in proceeding with options for the core strategy which cannot be delivered as a result of failure to obtain the agreement of key delivery agencies.

It is abundantly clear from the various representations submitted by Oikos and similar representations from the Port of London Authority that those who are ‘essential partners' in the

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delivery of an apparent key element of the spatial vision relating to the Oikos facility (one of the hazardous installations referred to in paragraph 6 of the vision) are not ‘signed up to it'.

The Port of London Authority are understood to regard the facility as a very important part of port operations on the Thames. Even if Oikos were looking to relocate (which they are not) it is understood that the Port of London Authority, both as landowner and statutory harbour authority would not allow the site to be developed for non‐port related uses.

Suggested amendments to the Spatial Vision

The vision should ensure that the overall strategy for the future planning of the borough of Castle Point is based upon the only justified and effective option for the Oikos facility, which is a continuation of its current primary use.

The first and second sentence of paragraph six of the spatial vision should be deleted and replaced with:

"The coast line of South West Canvey Island represents a sustainable and suitable location for activities associated with the marine import of fuel and oil products. Due to the rare juxtaposition of marine and land infrastructure in this area the ongoing use of this area for marine related uses will be supported." 195 The Spatial Vision Mr Philip Rowell U J The spatial vision is not justified because the approach outlined for the hazardous E This matter, along with the other representations The council is well aware that the Oikos facility is within the Port of London Oikos Storage Adams Hendry installations is not based on a robust and credible evidence base and is not the most submitted by Oikos on the Core Strategy, relate on port operational land. The council is not opposed to the continuation of Limited Consulting Ltd appropriate strategy. to a facility of some significance. The issues port related uses within south Canvey. The council would also point out raised relate to the long term future of this that the major part of the land under PLA and Oikos control is not strategic facility. The intentions of the Council previously developed land and has never been used for port related This representation should be read in conjunction with all the other representations submitted by and Oikos are so fundamentally opposed that purposes. Oikos on the Core Strategy Final Publication Document. the most appropriate course of action is to debate the issues at the Examination in Public. In order to comply with PPS 12 the council would not seek to be Fundamental to Oikos' objection to the Core Strategy, including the reference to the Oikos facility as prescriptive about the mix of land uses that may utilise this land in the a hazardous installation in the spatial vision, is a misunderstanding of the role and significance of the future. However, the council envisages that the land could be more Oikos facility in land use terms. Reference within the spatial vision is made to the facility being a effectively used for a mix of uses which would assist in meeting the needs hazardous installation. However, no recognition is given to the fact that the Oikos facility is located of the community of Canvey Island and south Essex, remove pressure for on port operational land (as defined by the Planning Acts) of the Port of London and that the facility development in the green belt, and reduce risk to residents and businesses forms a key strategic port facility within the Port of London. on Canvey Island emanating from the presence of the existing hazardous installations. The Port of London is identified by Government through its Delivering a Sustainable Transport System (November 2008) documentation as one of the country's key international gateways and a The council does not therefore agree with the need to amend the spatial component of the transport infrastructure that, collectively with the other identified elements, is vision as proposed and maintains that the core strategy is sound. critical to the functioning of the transport system as a whole and to the economic success of the nation.

The Port of London Authority is understood to regard the facility as a very important part of port operations on the Thames. Against this background the spatial vision (paragraph 6) of the strategy seeks in respect of hazardous installations (which the strategy elsewhere makes clear includes the Oikos facility) to "relocate the current uses and secure the sites for safe and sustainable

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redevelopment for new uses" and resist "Further expansion of hazardous uses in this location".

No evidence is presented by the Council which demonstrates that the only option available to ensure the safety of the community of Castle Point is the removal of the Oikos facility through its redevelopment. The safety of the site and its operation is a matter for the Health and Safety Executive (HSE), and the site currently operates in accordance with the requirements of the HSE and agreed ways of working. Following a recent change in ownership of Oikos a programme of repair, renewal and maintenance activity has been and continues to be undertaken at the facility to implement recent recommendations of the HSE regarding safety standards for fuel storage facilities. In this regard it is noted that the planning system is required to complement other consenting or control systems, not seek to duplicate the roles of these other systems, as PPS23 confirms.

As a strategic port facility the proposed aspiration of the Council to redevelop the site for other uses is not in accordance with the relevant evidence base, which the Core Strategy itself relies upon, namely the Thames Gateway South Essex Waterfront Strategy (2006). Section 4.2 of the Strategy, under the heading Ports and Logistics Development: the Key Driver of the Gateway, makes clear (section 4.2.3) that the terminals in Castle Point (which clearly include the Oikos facility) are key waterfront dependent assets and recommends that such assets need to be safeguarded to support their future business expansion and stability (Strategy Recommendation 7).

The vision of the core strategy refers to the safe and sustainable redevelopment of the site for new uses - but does not defined what these are. The Oikos site lies close to and has direct access to the deep water marine access channel of the River Thames. It has landside infrastructure that allows it to distribute oil and fuel products without the use of road or rail transport, to the benefit of the road network and residents of Canvey Island and beyond. The existing use of this site is therefore both a sustainable and suitable land use. The removal of this use would arguably run counter to the principles of sustainable development.

Oikos have no intention, either within the time frame of the Core Strategy or beyond, to seek to vacate the site and thereby allow for its change of use. Even if that were the case (and it should be clear that it is not) it is understood by Oikos that the Port of London Authority, both as landowner and statutory harbour authority would not allow the site to be developed for non‐port related uses. Reference in the Spatial Vision is made to the use currently occurring at the Oikos facility being relocated. Leaving aside the issues raised above, the Council provide no evidence that there is another site available with access to deep water and connections to the inland distribution UKOP and GPSS pipelines where this use could be relocated to.

A vision that seeks the removal of a regionally and nationally significant facility, which the operator intends to retain and whose retention the harbour authority and landowner supports, is evidently not the most appropriate strategy when considered against the reasonable alternatives.

Suggested amendments to the Spatial Vision

The first and second sentence of paragraph six of the spatial vision should be deleted and replaced with:

movement by water and rail rather than road. The council does not accept that the long term extinguishment of the hazardous uses conflicts with the i. PPG13 - Transport (2001) RSS.

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people and for the movement of freight (paragraph 4). In order to deliver this objective, local The council does not agree that the spatial vision should be amended as authorities when preparing development plans are required, amongst other things, to protect sites proposed and believes that it is consistent with national and regional policy and routes, both existing and potential which could be critical in developing infrastructure for the and is therefore sound. movement of freight (paragraph 6 and 45).

Local authorities are required, where appropriate, to work with the ports and shipping industries when preparing development plans. Local authorities should also encourage the full use of existing port facilities, and avoid nearby developments incompatible with port operations. (Annex B: Planning for Transport Paragraph 10 ‐ 11).

The achievement of the Core Strategy vision would result in the removal of a facility that through its deep‐water access and onward inland pipeline distribution network is a strategic piece of port infrastructure able to sustainably distribute goods for which there is demand and on which certain key facilities elsewhere in the nation depend.

ii. Modern Ports: A UK Policy (2000)

It is recognised to be in the national interest that ports remain able to handle current UK trade and its potential development efficiently and sustainably (paragraph 1.1.2). The Government aims to make the best use of existing port capacity through, amongst other things, greater productivity from existing infrastructure (paragraph 2.4.10)

Reflecting the guidance given in PPG13, local authorities are, where appropriate, encouraged to work with the ports and shipping industries when preparing development plans and should identify and, where appropriate, protect sites which could be critical in developing ports infrastructure (paragraph 2.5.10). Local authorities are also required to promote the role of ports in sustainable distribution, by, amongst other things, encouraging full use of existing facilities. Developments incompatible with nearby port operations should be avoided (paragraph 2.5.11).

The achievement of the Core Strategy vision would not result in making the best use of existing port capacity and would result in the removal of a strategic piece of port infrastructure able to sustainably distribute goods. Due to its strategic importance the role played by the port facility that is the Oikos installation should be promoted.

iii. Ports Policy Review - Interim Report (2007)

This interim report, which supplements Modern Ports, highlights that the planning system, at regional and local level, remains the best place to determine needs for safeguarding significant port facilities (paragraph 17).

The Regional Spatial Strategy of relevance to the Core Strategy, the East of England Plan, through policy T10 gives priority to the efficient and sustainable movement of freight and that existing well located freight wharves and facilities for water freight interchange (amongst other things) should be safeguarded where there is a reasonable prospect of developing them for port operational uses. The Oikos facility is already in active port operational use and is a site which should be safeguarded for that purpose in the long term. Such safeguarding is important so that there is certainty in the planning process, and so that incompatible developments are not allowed in close proximity to port operations.

iv. Draft National Policy Statement for Ports (2009)

Ports are recognised as having a vital role in the import and export of energy supplies, including oil (paragraph 1.8.5). In respect of meeting the requirements of the Government's policies on sustainable development, new port infrastructure is required to, amongst other things, minimise use of Greenfield land and secure competition and security of supply (paragraph 1.10.2).

This existing Oikos operational port facility, which the vision is seeking to remove, is the type of facility which the statement recognises as having a vital role in the import and export of energy supplies.

v. Delivering a Sustainable Transport System: Main Report (November 2008) and Delivering a Sustainable Transport System: Consultation on Planning for 2014 and Beyond (November 2008)

These documents (produced to explain how the Government are putting into action their approach to long‐term transport planning that was produced in response to the Eddington study and the Stern review) identify the Port of London as one of the countries key international gateways and a component of the transport infrastructure that, collectively with the other identified elements, are Page 37 of 222

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critical to the functioning of the transport system as a whole and to the economic success of the nation.

The proposed Core Strategy vision is seeking the removal of a commercially viable strategic port facility within the Port of London.

vi. Draft Overarching National Policy Statement for Energy (EN‐1)

The relevant objectives in the Government's Energy and Climate change strategy (Section 2.1) include ensuring that investment provides security of energy supply through a diverse and reliable mix of fuels and low carbon technologies (Section 2.1).

The draft policy emphasises the need for the UK, during the transition to a low carbon economy, to be able to access reliable supplies of gas and oil. The Government's approach to security of gas and oil supplies includes, amongst other things, through the strategic reinforcement of the UK's gas and oil pipeline transmission networks (paragraph 2.1.15)

In respect of oil and fuel products the draft statement makes it clear that the UK needs to ensure it has safe and secure supplies of the oil products it requires. Sufficient fuel and infrastructure capacity are necessary to avoid socially unacceptable levels of interruption to physical supply and excessive costs to the economy from unexpectedly high or volatile prices. These requirements can be met by sufficient, diverse and reliable supplies of fuel, with adequate capacity to import, produce, store and distribute these supplies to customers. This in turn highlights the need for reliable infrastructure including refineries, pipelines and import terminals and the need for flexibility in the supply chain to accommodate the inevitable risk of physical outages (paragraph 3.10.3)

The importance of the fuel distribution pipelines to which the Oikos facility is connected is also emphasised. In respect of oil distribution pipelines the draft statement indicates there is a significant need for additional pipelines to be provided, which emphasises the importance of the existing oil and fuel distribution facilities and networks such as those provided by the Oikos facility.

vii. Draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN‐4)

This draft national policy further emphasises that the efficient import, storage and transmission of natural gas and oil products is crucial to meeting the nation's energy needs during the transition to a low carbon economy. The need for investment in new gas and oil storage and transmission infrastructure to meet the national objectives relating to security of supply is identified (paragraph 1.1.1). This highlights not only the importance of new infrastructure but existing storage and distribution infrastructure.

In addition to National Policy we draw attention to the legal requirement set out in PPS12 that core strategies should be in general conformity with regional policy as expressed in Regional Spatial Strategies. The East of England RSS promotes sustainability and seeks to reduce the levels of traffic on the region's road network. Policy T11 seeks to maximise the proportion of freight by modes other than road, consistent with commercial viability. Policy T10 states that priority should be given to the efficient and sustainable movement of freight and that existing well located freight wharves and facilities for water freight interchange (amongst other things) should be safeguarded where there is a reasonable prospect of developing them for port operational uses.

The vision of the Core Strategy in respect of the Oikos facility is not in conformity with these policy objectives.

Suggested amendments to the Spatial Vision

The first and second sentence of paragraph six of the spatial vision should be deleted and replaced with:

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251 The Spatial Vision WM Morrisons Cara Ware S Morrisons supports those aspects of the Core Strategy Spatial Vision which relate to the W No response required. Supermarket Plc Peacock and Smith regeneration of Hadleigh Town Centre to provide a greater range and quality of retailing and local services. The Company considers that enhancing the range and quality of retailing, via the introduction of new retail floorspace (for which capacity is identified in the Retail Needs Assessment Study), is the key factor to take into account in securing and improving the vitality and viability of Hadleigh Town Centre.

Whilst Morrisons understands that the provision of new housing in town centres can also support their vitality and viability, the Company considers that care must be exercised to ensure that this is not at the expense of either residential amenity or retail operational viability, otherwise the benefits of either or both would not be realised. 83 Aims and Objectives Mr Richard Inman U E You may want to include reference to other LDDs that will support objectives stated in the Core W Minor amendment proposed for paragraph 4.6 to make link clear. GO-East Strategy

252 Aims and Objectives WM Morrisons Cara Ware S J Subject to the matter highlighted below, Morrisons supports the acknowledgement within the vision, W No response required. Supermarket Plc Peacock and Smith aims and objectives of the Core Strategy that delivering new retail floorspace will assist in delivering better quality jobs. As indicated above, the Company considers that the delivery of new retail floorspace is the key measure in securing and improving the vitality and viability of Hadleigh Town Centre.

Whilst Morrisons understands that securing a mix of uses in town centres can reduce the need to travel, in so far as housing development is concerned this should be subject to the same qualifications as set out above in relation to residential amenity and retail operational viability.

Morrisons supports the following aims and objectives of the Core Strategy Spatial Portrait:

• to deliver 2,500 better quality jobs; • to deliver 10,000 sq m of new retail floorspace.

270 Aims and Objectives Oikos Storage Mr Philip Rowell U E The objective relating to the removal of the hazardous uses is not effective because the E This matter, along with the other representations The councils objective to seek the extinguishment of the hazardous uses is Limited Adams Hendry approach it supports is not deliverable. submitted by Oikos on the Core Strategy, relate a long term proposal and reflects the need to be flexible and respond to Consulting Ltd to a facility of some significance. The issues changing circumstances. The strategy therefore complies with the need to raised relate to the long term future of this be effective. This representation should be read in conjunction with all the other representations submitted by strategic facility. The intentions of the Council Oikos on the Core Strategy Final Publication Document. and Oikos are so fundamentally opposed that The council does not agree with the suggested amendments and believes the most appropriate course of action is to that the core strategy is sound. The Council is reminded that in respect of deliverability, PPS12 (paragraph 4.45) established the debate the issues at the Examination in Public. importance of the principle that "partners who are essential to the delivery of the plan, such as landowners and developers, should be signed up to it". PPS12 makes it very plain in paragraph 4.28 that there is no point in proceeding with options for the core strategy which cannot be delivered as a result of failure to obtain the agreement of key delivery agencies.

It is abundantly clear from the various representations submitted by Oikos and similar representations from the Port of London Authority that those who are ‘essential partners' in the delivery of this objectives which in turn is an apparent key element of the spatial vision, are not signed up to it.

The Port of London Authority is understood to regard the facility as a very important part of port operations on the Thames. Even if Oikos were looking to relocate (which they are not) it is understood that the Port of London Authority, both as landowner and statutory harbour authority would not allow the site to be developed for non‐port related uses.

Suggested Amendments

The Core Strategy should ensure that its overall aims and objectives provide a sound basis for the future planning of the Oikos site in its current primary use.

The stated objective ‘Seek the removal of hazardous uses from the Borough' should therefore be deleted and replaced with an objective which recognises that the only justified and effective option through the lifetime of the strategy for the Oikos facility is the continuation of its current primary use. 271 Aims and Objectives Oikos Storage Mr Philip Rowell U J The objective relating to the removal of the hazardous uses is not justified because it is not E This matter, along with the other representations The council recognises that the Oikos Terminal is regulated by the HSE Limited Adams Hendry based on a robust and credible evidence base and is not the most appropriate strategy. submitted by Oikos on the Core Strategy, relate under the COMAH regulations. The council is not seeking to duplicate Consulting Ltd to a facility of some significance. The issues other regulatory regimes. However, it is clear from the report of the raised relate to the long term future of this Buncefield Major Incident Investigation Board that the COMAH regime This representation should be read in conjunction with all the other representations submitted by strategic facility. The intentions of the Council does not extinguish the risk to residents and businesses on Canvey and Oikos are so fundamentally opposed that

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Oikos on the Core Strategy Final Publication Document. the most appropriate course of action is to Island. debate the issues at the Examination in Public. The safety of the site and its operation is a matter for the Health and Safety Executive (HSE), and The council's strategy is a long term approach which will reduce the risk to the site currently operates in accordance with the requirements of the HSE and agreed ways of residents and business on Canvey particularly beyond 2020 and provide working. Furthermore, following a recent change in ownership of Oikos a programme of repair, for the use of the land with a more sustainable mix of land uses. The renewal and maintenance activity has been and continues to be undertaken at the facility to council does not accept that the retention of the port facility justifies the implement recent recommendations of the HSE regarding safety standards for fuel storage facilities. retention of the hazardous installations on Canvey. In this regard it is noted that the planning system is required to complement other consenting or control systems, not seek to duplicate the roles of these other systems, as PPS23 confirms. The council does not therefore agree with the suggested amendments and maintains that the core strategy is sound In the face of these facts, no evidence is presented by the Council, which demonstrates that the only option available to ensure the safety of the community of Castle Point is the removal of the Oikos facility, which the remainder of the Core Strategy makes clear forms one of the hazardous uses being referred to.

Furthermore, this objective runs counter to the evidence which is referred to in greater detail elsewhere in Oikos' other representations that the Oikos facility is located on port operational land (as defined by the Planning Acts) of the nationally significant Port of London and that the facility forms a key strategic port facility within the Port of London.

Suggested Amendments

The Core Strategy should ensure that its overall aims and objectives provide a sound basis for the future planning of the Oikos site in its current primary use.

The stated objective ‘Seek the removal of hazardous uses from the Borough' should therefore be deleted and replaced with an objective which recognises that the only justified and effective option through the lifetime of the strategy for the Oikos facility is the continuation of its current primary use. 272 Aims and Objectives Oikos Storage Mr Philip Rowell U N The objective relating to the removal of the hazardous uses is not consistent with National E This matter, along with the other representations The council does not oppose the use of land within South Canvey for port Limited Adams Hendry Policy as it relates to the Oikos facility. submitted by Oikos on the Core Strategy, relate use and related activities. Its strategy is therefore consistent with national Consulting Ltd to a facility of some significance. The issues policy. raised relate to the long term future of this This representation should be read in conjunction with all other representations submitted by Oikos strategic facility. The intentions of the Council on the Core Strategy Final Publication Document. The council is developing a long term strategy for the future of South and Oikos are so fundamentally opposed that Canvey in accordance with the transition to a low carbon economy. The the most appropriate course of action is to approach is therefore consistent with the draft Overarching National Policy This objective would result in the removal of what is a strategically important port facility used for the debate the issues at the Examination in Public. Statement import of fuel and oil products for a number of strategic facilities. This is not consistent with national policy in the following regards:

Policies T10 and T11 of the RSS are concerned with maximising movement by water and rail rather than by road. The council does not i. PPG13 - Transport (2001) accept that the long term extinguishment of the hazardous installations conflicts with the RSS. One of the key objectives of PPG13 is to promote more sustainable transport choices for both people and for the movement of freight (paragraph 4). In order to deliver this objective, local The council does not agree that the spatial vision should be amended as authorities when preparing development plans are required, amongst other things, to protect sites proposed and believes that it is consistent with national and regional policy and routes, both existing and potential which could be critical in developing infrastructure for the and is therefore sound. movement of freight (paragraph 6 and 45).

Local authorities are required, where appropriate, to work with the ports and shipping industries when preparing development plans. Local authorities should also encourage the full use of existing port facilities and avoid nearby developments incompatible with port operations (Annex B: Planning for Transport Paragraph 10 ‐ 11).

The achievement of this Core Strategy objective would result in the removal of a facility that through its deep‐water access and onward inland pipeline distribution network is a strategic piece of port infrastructure able to sustainably distribute goods for which there is demand and on which certain key facilities elsewhere in the nation depend.

ii. Modern Ports: A UK Policy (2000)

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(paragraph 2.5.10). Local authorities are also required to promote the role of ports in sustainable distribution, by, amongst other things, encouraging full use of existing facilities. Developments incompatible with nearby port operations should be avoided (paragraph 2.5.11).

The achievement of this Core Strategy objective would not result in making the best use of existing port capacity and would result in the removal of a strategic piece of port infrastructure able to sustainably distribute goods. Due to its strategic importance the role played by the port facility that is the Oikos installation should be promoted.

iii. Ports Policy Review - Interim Report (2007)

Such safeguarding is important so that there is certainty in the planning process, and so that incompatible developments are not allowed in close proximity to port operations.

iv. Draft National Policy Statement for Ports (2009)

This existing Oikos operational port facility, which the objective is seeking to remove, is the type of facility which the statement recognises as having a vital role in the import and export of energy supplies.

v. Delivering a Sustainable Transport System: Main Report (November 2008) and Delivering a

Sustainable Transport System: Consultation on Planning for 2014 and Beyond (November 2008)

The proposed core strategy objective is seeking the removal of a commercially viable strategic port facility within the Port of London.

vi. Draft Overarching National Policy Statement for Energy (EN‐1)

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distribute these supplies to customers. This in turn highlights the need for reliable infrastructure including refineries, pipelines and import terminals and the need for flexibility in the supply chain to accommodate the inevitable risk of physical outages (paragraph 3.10.3)

vii. Draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN‐4)

The East of England RSS promotes sustainability and seeks to reduce the levels of traffic on the region's road network. Policy T11 seeks to maximise the proportion of freight by modes other than road, consistent with commercial viability. Policy T10 states that priority should be given to the efficient and sustainable movement of freight and that existing well located freight wharves and facilities for water freight interchange (amongst other things) should be safeguarded where there is a reasonable prospect of developing them for port operational uses.

The objective of the core strategy in respect of the Oikos facility is not in conformity with these policy objectives.

Suggested Amendments

The Core Strategy should ensure the overall aims and objectives provide a sound basis for the future planning of the Oikos site in its current primary use.

The stated objective ‘Seek the removal of hazardous uses from the Borough' should therefore be deleted and replaced with an objective which recognises that the only justified and effective option through the lifetime of the strategy for the Oikos facility is the continuation of its current primary use. 38 Table 3 Mr Martin Twigg U E Delivering 2,500 jobs - No evidence has been provided that at the same time as suggesting 900 net E The Canvey Sustainable Regeneration Report and the Hadleigh Town Core Strategy Aims Fox Land and additional dwellings in Canvey/ Hadleigh town centre there is sufficient space to accommodate a Centre Capacity Study both indicate that residential development and retail and Objectives Property Limited further net quantum of retail development. floorspace can be increased in these town centres, delivering both the number of dwelling units set out in the Core Strategy and a substantial area of retail floorspace to meet the requirements of the Retail Needs Our contention is that one or both strategies will fail. The identified quantum of retail floorspace for Assessment - thus providing jobs in retailing. The Core Strategy is Hadleigh town is approximately equivalent to 50 Homes. therefore sound with regard to the strategy to regenerate town centres.

The Aim of delivering 5,000 new dwellings will not arise in the context of the suggested strategy for With regard to the delivery of housing, the Core Strategy sets out robust the reasons provided elsewhere in these submissions. Further, the proposed strategy will not deliver proposals for housing supply that clearly equate to just over 5000 dwelling 35% of affordable housing. Indeed it is telling that the Council has failed to deliver this percentage of units - see housing trajectory at Appendix A. This housing trajectory is affordable housing because of the reliance on its trajectory on small sites which have not delivered based on evidence compiled in the Strategic Housing Land Availability affordable housing. Assessment. The aim to deliver 5000 homes is therefore realistic and justified.

With regard to the ambition to meet the regional housing target of 35%. This will be challenging as it is not economically viable to achieve 35% on smaller sites within the urban area. However, the Council has experience of 100% schemes coming forward. This objective indicates the Council's commitment to the delivery of affordable housing and is therefore justified. 82 Table 3 Mr Richard Inman S Your forward calculation of the jobs and housing needs to 2026 is reasonable W No response required. Core Strategy Aims GO-East and Objectives 174 Table 3 Mr JAMES U J The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The presence of two top tier hazardous installations on Canvey exposes Core Strategy Aims TRIMMER Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the residents and businesses to risks which have implications for their safety. and Objectives PORT OF LONDON and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove The content of Table3 is therefore justified particularly following the report AUTHORITY adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey of the Buncefield Major Incident Investigation Board. The council does not Page 42 of 222

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integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should agree that the deletion of this part of the table from the core strategy will cargo per annum. properly be discussed at the examination. The make it sound. PLA, as landowner of one of the terminals and as the Statutory Port Authority for the port within The PLA contends that Table 3 (and more particularly the aim to make Castle Point a safer, healthier which the terminals operate, contends that it place to live) is not justified and the Core Strategy is therefore unsound. No robust evidence is should participate in any such discussion. adduced to substantiate the claim that the terminals pose any safety risk and therefore that their removal from Castle Point would increase the health of residents or any feelings of safety. Furthermore, no robust evidence is adduced to substantiate the claim that the approach taken represents the most appropriate strategy when considered against the reasonable alternatives, and in particular the continuation of cargo-handling at the terminals.

The PLA contends that only the deletion of this element from Table 3 and its replacement with an approach which provides for the continuation of the current cargo-handling uses at the terminals will remedy these deficiencies and make the Core Strategy sound. 175 Table 3 Mr JAMES U E The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The council does not oppose the use of part of the land within South Core Strategy Aims TRIMMER Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the Canvey for cargo handling and related uses. The council does not accept and Objectives PORT OF LONDON and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove that this requires the retention of the top tier hazardous installations on this AUTHORITY adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey land. The council's strategy is a long term approach to the future of Canvey integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should and reflects the requirement to be flexible under para 4.46 of PPS12. The cargo per annum. properly be discussed at the examination. The removal of this part of the table is not required to make the Core Strategy PLA, as landowner of one of the terminals and sound. as the Statutory Port Authority for the port within The PLA contends that Table 3 (and more particularly the aim to make Castle Point a safer, healthier which the terminals operate, contends that it place to live) is not effective and that the Core Strategy is therefore unsound. The PLA acquired its should participate in any such discussion. landholdings in Canvey Island over seventy years ago. It is operational land for the purposes of the Planning Acts. The PLA remains fully committed to the utilisation of the Oikos site for cargo- handling. It has no intention of disposing any or all of the site for alternative development throughout the plan period.

The Council is aware of the PLA's position in relation to the long-term future of the Oikos site, and the approach promulgated within Table 3 is clearly not deliverable. As such, it fails the test at Paragraph 4.45 of PPS12 and, the PLA would contend, the Core Strategy is therefore unsound.

The PLA contends that only the deletion of this element from Table 3 and its replacement with an approach which provides for the continuation of the current cargo-handling uses at the terminals will make the Core Strategy sound. 176 Table 3 Mr JAMES U N The PLA is the freehold owner of the Oikos site and associated land (extending to 198 acres) on E Notwithstanding the PLA's long-standing and The council does not agree that the aim to make Castle Point a safer and Core Strategy Aims TRIMMER Canvey Island. It is the Statutory Port and Navigation Authority for the River Thames and its Estuary continuing objections to the Core Strategy, the healthier place to live is not consistent with national policy or the RSS. The and Objectives PORT OF LONDON and furthermore has a statutory duty to promote the Port of London. The Oikos Terminal and the Council's approach continues to seek to remove council does not believe that the draft national policy statements referred AUTHORITY adjacent Calor Terminal (which is not owned by the PLA) are important deep-water facilities and the cargo-handling terminals from Canvey to are inconsistent with the aims of the Core Strategy. It therefore does not integral to the Port of London, handling (on average over the last ten years) 0.3 million tonnes of Island. Such a fundamental issue should accept that the removal of part of Table 3 is required to make the Core cargo per annum. properly be discussed at the examination. The Strategy sound. PLA, as landowner of one of the terminals and as the Statutory Port Authority for the port within The PLA contends that Table 3 (and more particularly the aim to make Castle Point a safer, healthier which the terminals operate, contends that it place to live) is not consistent with national policy and that the Core Strategy is therefore unsound. should participate in any such discussion.

Both the Oikos and Calor terminals are strategically important to the national and regional economies, handling petroleum products which are close to major centres of demand and which can distributed sustainably by pipeline; to both the UK Oil Pipeline (UKOP) and Government Pipeline and Storage System (GPSS) from the Oikos Terminal and to the Coryton Refinery in Thurrock from the Calor Terminal. The draft Overarching National Policy Statement for Energy (EN1) notes that the UK must ensure that it has access to safe and secure supplies of oil and gas.

Such an approach requires well located import terminals with access to pipeline distribution networks. The draft National Policy Statement for Ports notes that ports have a vital role in the import and export of energy supplies and furthermore that ensuring the security of energy supplies into UK ports is an important consideration. The PLA would contend that the Core Strategy is not consistent with national policy.

The PLA contends that only the deletion of this element of Table 3 and its replacement with an approach which provides for the continuation of the current cargo-handling uses at the terminals will remedy these deficiencies and make the Core Strategy sound. 340 Table 3 Cllr Martin Tucker U J Table 3: Core Strategy Aims and Objectives, Aim: Deliver 2500 better quality jobs, p.24 E As elected representatives of Castle Point The objectives under the aim to secure better quality jobs focus on the Core Strategy Aims Canvey Island Borough Council residents, and with multiple business environment and on improving skills levels. Higher economy and Objectives Independent Party representations made for consideration, CIIP employers, who pay higher wages are attracted to areas that have a good Page 43 of 222

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There is no real qualitative statement defining the meaning of a ‘better quality job'. In real terms, would like to participate at the oral part of the environmental quality and higher skills levels. Therefore it is considered employees seek higher pay above any other single aspect of a job. It is possible to suggest that examination to justify and clarify the document that this aim is realistic, and should therefore be included in the Core employers with employee development opportunities provide better quality jobs than those that do submitted in response to the Core Strategy. Strategy. not, but in general this is not the primary motivation for employees. In their Castle Point Employment Study Report (2006), commissioned by CPBC, Roger Tym and Partners make the following It is recognised that growth is proposed in sectors that already operate in statement: Castle Point. However, within these sectors there are different job types e.g. unskilled labour through to professional/managerial. Stimulating growth 3.10 Full time workplace earners earn only £411 compared to the county, regional and national in existing sectors does not necessarily mean therefore that wage levels averages of £523, £512 and £518 respectively. This highlights the low quality of jobs on offer in will remain low if supported by other improvements. Castle Point, which we discuss in more detail in the next chapter. The two Greenfield sites referred to for employment in this representation Under the 'Creating Employment Opportunities' heading, the CS states that there will only be growth are at West Canvey. Both were identified in the Local Plan. in existing employment sectors which, as has been defined above, only provide ‘low quality' jobs. Although admirable, evidence suggests that the aim is undeliverable, and therefore ineffective. The EEDA Site to the west of Morrisons and south of Northwick Road has extant planning consent for commercial development. Objection to Table 3: Core Strategy Aims and Objectives, Objective: Deliver at least 18ha of additional development of this site at this stage is not therefore appropriate. employment development, p.24 The long-term employment land to the south of Charfleets will be made If additional employment development is required, it should not be to the detriment of green space. accessible by the extension of Roscommon Way to Haven Road. This was The two sites (8ha and 10ha) are both open green space with the smaller site containing a football granted funding and approval on the bases that employment development pitch. As will be explained under the heading of 'Creating Employment Opportunities', the loss of this in this location will trigger economic benefits. This land does not play a green space for employment development is unjustified. strategic role in the landscape, as views across the site are obscured by existing development. Neither is this site accessible public green space. The quantum of development proposed for this location will be determined as part of the Canvey Area Action Plan having regard to Nature Conservation constraints in the general location.

The Core Strategy is therefore considered sound with regard to the aims and objectives related to employment. 116 5 Mr Kenneth John U J The roads in Thundersley area, Rayleigh Road, Hart Road, Kiln Road are already very busy and W The County highway Authority have been consulted on this document and The Spatial Strategy Reeve have been close to gridlock when affected by accidents or road works in the vicinity. Caused in the have not raised concerns with regard to highway capacity in the main by people attempting to find a free road not affected. Thundersley area. The Core Strategy is therefore considered sound in this regard. 142 5 Mr Simon Hart S J E As someone who has grown up in Thundersley No response required. The Spatial Strategy and seen it grow and develop I am shocked to hear of any increased traffic that may use the Rayleigh Road, Stadium Way, Daws Heath road and the Woodman’s Junction. Anyone who travels out of the Borough in the morning or enters the Borough in the evening via the Rayleigh Weir will tell you about the total gridlock that occurs, now the Fire Station is situated at the Rayleigh Road / Stadium Way junction things can only get worse. 147 5 Mr Andrew Dutton MS GABRIELLE S J 1.1. Persimmon Homes (Essex) Ltd. fully support the identification of Land to the East of Canvey E Persimmon Homes (Essex) ltd are the This consultation response supports the proposed distribution of housing in The Spatial Strategy Persimmon Homes ROWAN Road, Canvey Island as a location for housing growth as set out in Policy SS2. landowners of a key site (land to the east of Castle Point to include land East of Canvey Road. It does however raise Ltd PEGASUS Canvey Road, Canvey Island) which is an some issues that are addressed below: PLANNING GROUP integral part of the delivery of the Core Strategy, 1.2. The Council has correctly identified the need for increased housing growth on Canvey Island therefore they should be included within all due to the level of current and future populations living on the Island and the opportunities for Alignment with the Revision to the East of England Plan to 2031. The relevant discussions. regeneration and the potential for the creation of sustainable communities as outlined in Table 2. Council has objected to the proposed housing distribution scenarios set out The Council's approach to the provision of housing on Canvey Island is sound. in the consultation document for the East of England Plan revision because none of the growth scenarios gave proper consideration to environmental capacity. Alignment with the scenarios set out in that plan may therefore 1.3. Persimmon Homes note the comments regarding the housing provision as set out in paragraph result in the Core Strategy being undeliverable and is not therefore 5.5 as this provides for development up to 2026. Whilst this reflects the advice in PPG3 regarding considered appropriate. the supply of housing land for a 15 year period following the adoption of a DPD, there is a need to consider the policy framework over a longer timescale given the green belt coverage across the Borough. Paragraph 5.9 refers to the period until 2031, when dealing with green belt issues. Justifying the release of Green Belt land for development. The evidence base provides justification for development in the Green Belt locations identified in the Core Strategy, but this is not considered to be reflected in 1.4. We have reviewed the consultation recently conducted by the East of England Regional the supporting text to policy SS2. As a result a minor amendment is Assembly regarding the review of the East of England Plan to 2031. In the light of the consultation proposed to paragraph 5.19. documents and the related demographic information, there will be a need for further housing growth in the Borough beyond 2026. It would seem necessary for consistency purposes to refer to the latest regional consultation document in the Core Strategy to demonstrate that there is flexibility in the plan to deal with changing circumstances and that these housing figures are regarded as minimum targets to be achieved, rather than ceilings which should not be exceeded.

1.5. We support the approach in Policy SS2 of the identification of sites for housing growth and community development. Paragraph 5.17 acknowledges that "whilst there is substantial capacity Page 44 of 222

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within the existing urban area to accommodate most of the Borough's need, there is the requirement to consider land on the urban periphery for development also, as the supply from the urban area is not sufficient to deliver the entire housing requirement ." Therefore the Council has described the exceptional circumstances that justify the need to provide additional housing on Greenfield sites and has identified in Table 4 Land to the East of Canvey Road, Canvey Island to be " developed to provide a community hub providing a range of community and leisure services for the west of the Island and up to 400 homes." This approach responds to the Portrait of Castle Point at pages 12, 13 and 19 of the Final Publication Document.

1.6. The Revised Assessment of Sites on the Urban Periphery (September 2009) provides a site profile of East of Canvey Road in Appendix C.3 which outlines the sustainability assessment undertaken for the site. The sustainability ranking for the site (2) demonstrates that this site is well located. The Council has undertaken the necessary assessment to help achieve its housing provision as well as the provision of important community infrastructure.

1.7. Persimmon Homes (Essex) Ltd. support the housing allocation at Land to the East of Canvey Road, Canvey Island (Policy SS2). Housing on this site is developable and deliverable as defined at paragraphs 56 and 54 of PPS3.

Green Belt Function

1.8. Persimmon Homes have reservations regarding the justification provided for development on Green Belt sites. Paragraph 5.19 sets the context for the decision to identify Green Belt sites in addition to sites within the built up area and states that " there is however a further need for housing capacity beyond this location. As a result, a number of sites were reviewed with regard to their potential sustainability, and their likely impact on the function and extent of the Green Belt ." Three locations were identified as potential housing growth areas, including land to the East of Canvey Road, Canvey Island. Whilst we fully support the identification of the sites as identified in paragraph 5.19, it is important to ensure that the Core Strategy identifies the exceptional circumstances that give rise to the limited green belt release proposed at East of Canvey Road.

1.9. These locations have been assessed adequately as part of the process of sustainability appraisal; however, there appears to be a lack of assessment carried out in terms of Green Belt principles and purposes. Paragraph 5.9 appears to state that this assessment is yet to be undertaken, noting that " the functions of the Green Belt and the quality of natural habitats will be carefully assessed to ensure that the stated purpose of the Green Belt is safeguarded until 2031 ."

1.10. Notwithstanding this statement, an analysis of the Green Belt function of the identified sites has been carried out as part of the PPS25: Development and Flood Risk Sequential Test which is a supporting document to the Core Strategy Final Publication Document. We endorse this analysis for land East of Canvey Road which correctly states at page 24 that " the southern area of the site proposed for development is bordered on three sides by existing residential development and Cornelius Vermuyden School. Therefore the development of this site can be regarded as an infill development - the site does not contribute towards the prevention of urban sprawl.

Further to this, the area proposed for residential development does not have a separation function. The area to the north of the site will remain as public open space and therefore not affect the openness or visual impact of the land or take development closer to Benfleet.

The functions of the Green Belt in this location are therefore weak and provide benefits only at the very local level in terms of views for neighbouring landowners. This area of green belt does not fulfil a strategic function."

1.11. It is considered that this analysis should be included within the Core Strategy Final Publication Document to ensure that there is a clear and robust justification provided for the identification of sites presently within the Green Belt to accommodate development. The soundness of the Core Strategy and the identification of housing growth locations would be enhanced by the inclusion of this justification within the DPD.

1.12. The justification for Policy SS2 should include this assessment of the Green Belt function in order to underline the fact that there is a robust evidence base for this decision. 286 5 Dr Philip Pearson U J Concern over the lack of a full Water Cycle Study (WCS) to inform Policy SS1 and Policy CP 4 W The Watercycle Scoping Report went further than a scoping report would The Spatial Strategy RSPB necessarily go, and provided clear guidance as to the key issues regarding waste water treatment. It is recognised that there are potential quality In the Core Strategy, levels of development, and indeed schemes such as the Olympic Mountain capacity issues at the WWTW on Canvey Island. Anglian Water have been Biking Event, can only be delivered if there is suitable water availability and capacity for wastewater consulted, and provided an indication that all major development in Castle treatment. A thorough Water Cycle Study would provide the necessary evidence-base to prove that Point (Canvey and Benfleet) was deliverable in terms of waste water the scale of development proposed within the Core Strategy is deliverable, but this has not been treatment, with infrastructure improvements. The need for further completed at this time. This is necessary to ensure that the scale of development within the Core development of the Watercycle Study is recognised in policy CP4, and will Page 45 of 222

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Strategy will have no adverse effects on the Benfleet and Southend SPA or Thames Estuary and ensure that Anglian Water can build into their AMP, infrastructure Marshes SPA, either through reduced water levels or water quality. Currently the HRA indicates that requirements for growth. there is likely to be sufficient capacity to meet water demands, but there is insufficient capacity within existing Sewage Treatment Works to avoid an adverse effect on the SPAs, especially in-combination The outcomes of the Watercycle Study Scoping Report were reflected in with the plans of neighbouring Council's. A robust suite of measures, such as phased development, the HRA and therefore the impact on European Sites has been considered. should be provided in the Core Strategy to show that the scale of development proposed within the Core Strategy is deliverable. The RSPB will object to housing plans that risk having an adverse effect on Benfleet and Southend SPA and Thames Estuary and Marshes SPA. The Council should The Olympic proposals are running ahead of the Core Strategy and will be consider policy wording that allows development to take place at levels that meet current water subject to separate appraisals regarding their impact on the natural abstraction levels without having an adverse effect on SPAs, such as that put forward in Proposed environment. Publication Recommendation 16. The Core Strategy is therefore considered sound with regard to its consideration of waste water treatment. 39 Principles of Mr Martin Twigg U E Paragraph 5.9 E The council does not accept the respondents conclusion regarding the Sustainable Fox Land and SHLAA. The core strategy identifies a sufficient land supply to meet the Development and Property Limited requirements to 2026 and the council does not accept that a strategic From our assessment of the SHLAA 2008 and in the absence of evidence from the Council we Growth review of green belt is required before 2031. believe there is a shortfall in the housing supply to 2026 by an incredible 1,955 dwellings. Even taking broad assumptions the maximum supply likely to be available is 3,447 homes. As such the Council will have failed to identify sufficient land to comply with the East of England Regional Spatial Strategy and will not have identified sufficient land which enable the Green Belt to endure until 2031. A strategic review of the Green Belt is therefore necessary rather than the tinkering around the edges which has been undertaken as part of the Core Strategy. 59 Principles of Mrs MJ Goode U J Below I have set out my reasons for opposing your plans to build a large number of new houses/flats W This representation refers to proposals to provide new homes on Green Sustainable and expand industrial areas. Belt land to the East of Rayleigh Road, North of Daws Heath Road. This Development and proposal was removed from the Core Strategy in December 2008 because Growth it was considered that the Green Belt in this location fulfilled a strategic All new homes generate at least one car if not two. The idea that buses will solve the problem is function in separating Hadleigh from Rayleigh. The Core Strategy is not highly unlikely. Bus routes are so long it takes hours to get from one part of the area to another (I do therefore unsound with regard to this representation. use buses very occasionally). People need to be able to drop children at school and then get themselves to their workplace. In most households today both partners have to work, hence two cars not one. This is the real world, not the ideal on paper where people walk/bus/train to work. Work With regard to the matter of reducing the need to travel by private vehicle, places are not next door, most people have to travel some distance to their place of business. this is consistent with national policy set out in PPS1 and PPG13. Furthermore, there are plenty of examples from urban areas elsewhere, where a good mix of development and good levels of public transport At rush hour times the Daws Heath Road from the Woodman’s, the Rayleigh Road and Hart Road provision reduce the need for people to use their car. It is therefore are all blocked because of the excessive amount of traffic now, before any new houses are built. The considered that the inclusion of this principle in policy SS1 is consistent South East corner of England is the most crowded area in the Country. I travel around the UK and with national policy and justified. know how difficult it is to get around the South East. The Dartford Bridge, Blackwell Tunnel, London, M25 all bottlenecks. If there is an accident on the A13 or A127 all surrounding roads come to a standstill, this happens outside my own home. With regard to the Olympic Mountain Biking Event. It is recognised that the event itself will generate traffic, although the organising body are doing as much as possible to encourage people to travel to the event by public The mountain bike Olympic event at Hadleigh Castle in 2012 will generate an enormous amount of transport. The event will run over two days in 2012, with a test event in extra traffic for the surrounding area. 2011. It is not therefore considered that the Olympic event will generate an ongoing congestion problem, and that measures are being put in place to I have lived in the Daws Heath area for 23 years now and like most people here we think of this area reduce local harm during the event. The core strategy is therefore as a little oasis of countryside, with wooded areas and green spaces to walk around. We need there considered sound in including reference to this event. spaces, you have allowed a huge amount of flats to be built within the Castlepoint area and these people need somewhere outside to go, as they have no gardens. 190 Principles of Miss Carrie Williams S J We agree with the statement in paragraph 5.8 that the delivery of new development must not be W We would prefer written representations, but will No response required. Sustainable The Environment considered in isolation from the drainage issues in the Borough and that existing conditions should happily attend the EiP at the Inspector's (or Development and Agency be improved and not exacerbated. Council's) request. Growth 261 Principles of Ms KATHARINE U E Paras 5.5 and 5.6 W Minor amendments proposed to paragraphs 5.5 to 5.6 as requested. Sustainable FLETCHER Development and ENGLISH The Borough has 7 scheduled monuments, 6 grade I and II* listed buildings, 28 grade II listed Growth HERITAGE buildings and 2 conservation areas. We would expect the distinctive historic assets to be referred to in these paragraphs as requiring continued protection.

Recommendation:

- Para 5.5 amend to: ‘..the unique natural environment and distinctive historic assets of the Borough'.

- Para 5.6 omit ‘natural' in line 2 so that the ‘environment' covers the historic, and natural. 40 Policy SS 1 Mr Martin Twigg U E Policy SS1 Should make clear the housing requirement of 5,000 is a minimum figure. The Core E The requirement set out in the East of England Plan for Castle Point is Principles of Fox Land and Strategy approaches this as a ceiling which is not to be exceeded. This is wrong. 4,000 dwelling units. 5,000 dwelling units is therefore greater than this Sustainable Property Limited figure and reflects an assumption that the annualised rate may be required Development and to be rolled forward to 2026. The Council has concerns with regard to Growth environmental capacity, as reflected in its response to the East of England Plan Review Consultation. As a result, the Council considers that it has Page 46 of 222

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gone beyond the requirement of the East of England Plan by identifying additional supply to 2026, and that 5,000 dwelling units should not be expressed as a minimum when there are clear concerns about environmental capacity. The Core Strategy is considered sound without making the amendment proposed. 84 Policy SS 1 Mr Richard Inman U E We welcome the broad outline of Policy SS1, especially the forward calculations of employment and W Minor Amendment to bullet 6 of policy SS1. Principles of GO-East housing needs, the commitment to ensuring at least 70% of new homes are on previously developed Sustainable land and the commitment to high quality design that is resilient to flood risk and climate change Development and effects. We recommend that you reconsider the construction of the sixth bullet point which could, as Growth presently worded, be construed as preventing engineering or other operations intended to protect coastline and habitats from the effects of climate change. There is no explicit recognition of the need for adaptation, which may provide opportunities as well as challenges for Castle Point. You might expand your approach to managing flood risk and make a link to policy CP5. 193 Policy SS 1 Miss Carrie Williams U E We generally support this policy, especially the inclusion of flood risk, and energy and water W We would prefer written representations, but will Minor Amendment to bullet 6 of policy SS1. Principles of The Environment efficiency. We do however agree with Richard Inman of Go-East that the sixth bullet point could be happily attend the EiP at the Inspector's (or Sustainable Agency reworded as it might represent a barrier to the implementation of the Thames Estuary 2100 Plan and Council's) request. Development and future opportunities for flood risk management. We therefore consider this policy to be inconsistent Growth with policy CP5 and also policy CP2 (should our proposed changes be accepted). 209 Policy SS 1 Mr Bruce Paterson U J Section 5.18 Policy No. SS1 Table 4 E In every planning application I have proposed to 396 to 408 London Road was assessed against the Sustainability Criteria Principles of C.P.B.C. in relation to this site, all but 2 have set out in the Sustainability Assessment of Sites on the Urban Periphery Sustainable been refused on the grounds the land lies within (2008). This found the site to be relatively unsustainable. Following a Section 5.19 Policy No. SS1 Table 4 Development and the green belt. In 25 years of owning this site revision of the methodology to weight some criteria more important than Growth this is the first opportunity I would have of others (based on public consultation results), the site scored relatively The criteria applied to this policies SS1 & SS2 are totally, unsound, unjust and unfair, and appealing my case before an Inspector. Who better in terms of sustainability. inconsistent with the criteria set. In particular this council has chosen green belt sites that are against would have the authority to exclude this land the public interest to be developed. Whilst they have ignored more suitable sites that have no public from within the green belt. However, the site is located in the Metropolitan Green Belt in a location that objection, I would like to draw the inspectors attention to 2 sites in particular being the land East of is important for preventing urban sprawl and the coalescence of place. The Rayleigh Road, Benfleet (Appendix C 1), which has had nothing but public protests and yet my own This is extremely important as if I am refused landowner has made several applications for the redevelopment of this site at 396 London Road, Benfleet (appendix C 36) which has a petition of over 1500 signatures in this opportunity to put my case before the site, and for its further use for Car Sales. These applications have been favour of development has been overlooked. inspector it could be a further 25 years before refused on Green Belt terms and where appealed the Planning Inspector another opportunity arises. has supported the Council's position that the Green Belt in this location is The unsound criteria applied to al 28 chosen sites is inconsistent, unjust and in most cases totally of strategic importance (App: CPT/553/98/FUL/VAR/C). The site is biased. And as such I wish to appeal the inclusion of the land at 396 London Road, Benfleet, being currently subject of enforcement action for failure to recognise the kept within the Green Belt. decisions of these previous applications.

It is recognised that there are objections to other sites in the Green Belt. However, it is considered that whilst this site does not look pretty, it is in the Green Belt and does perform a strategic function. As a result, the Council is of the view that the exclusion of this site from the Core Strategy is justified and consistent with national policy. 253 Policy SS 1 WM Morrisons Cara Ware U E Subject to the matter highlighted below, Morrisons supports the strategy of delivering W With regard to the potential conflict between residential amenity and retail Principles of Supermarket Plc Peacock and Smith employment growth and regeneration within the town centres, but the Company considers operation, it is recognised that it is not possible to locate residential Sustainable that care must be exercised to ensure that the delivery of new housing as part of any accommodation above all retail units. However, there are examples of Development and regeneration strategy should be subject to the same qualifications as set out above in residential development above supermarket provision across the Country Growth relation to residential amenity and retail operational viability. and therefore consideration needs to be given to supermarket designs that are more reflective of urban locations, rather than edge of town locations.

The Council is also concerned about substantial areas of surface car parking in the town centre and believe that the parking to accompany supermarket provision could occupy upper levels, if residential development is unsuitable. Their are local examples of such car parking provision at the Sainsbury's, Rayleigh Weir and Somerfield, London Road, Leigh-on-Sea.

The Council is confident that the concerns of this consultee can be reasonably addressed without change to the Core Strategy. 262 Policy SS 1 Ms KATHARINE U E We consider that the reference should be included to the historic environment to ensure appropriate W Minor amendment to policy SS1 to include reference to historic Principles of FLETCHER balance in the policy, in accordance with guidance in PPS1 and PPGs 15 and 16. environment. Sustainable ENGLISH Development and HERITAGE Recommendation: Growth

In bullet 6, amend to: ‘...the natural and historic environment, including the coastline, coastal habitats and historic features from development and the effects...' 317 Policy SS 1 Mr Roy Lewis U E The strategic approach taken towards the Spatial Strategy for the Borough is welcomed. Full support E Essex County Council would wish to attend the The Council is aware that there is a saved policy from the Essex and Principles of Essex County is given to the proposed emphasis on delivering employment growth and regeneration to provide oral part of the examination to further elaborate Southend-on-Sea Replacement Structure Plan with regard to the Coastal Sustainable Council 2,500 additional jobs and housing growth of 5,000 new homes between 2001 and 2026 that are well its representations on the Core Strategy; to Protection Belt. Development and integrated with community service locations and supported by the infrastructure needed; whilst provide the wider sub-regional/ regional context Growth ensuring availability of land to meet emerging longer term needs, sustainable growth with an for matters included within the Core Strategy; With the exception of some undefended areas in the intertidal zone (where Page 47 of 222

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emphasis on using previously developed land and safeguarding the Metropolitan Green Belt, and and to provide technical assistance on matters development is limited due to flood risk), the coastal protection belt is environmental conservation. relating to delivery of County Council services. entirely located within the Green Belt where there is a presumption against development. The protection that the Green Belt offers to the coastline and coastal habitats is recognised in policy SS1. The recasting of Chapter 5 of the Document with the inclusion of Policy SS1 and Policy SS2 addresses the major concerns expressed by the County Council in response to the previous Proposed Publication Document of January 2009. Inclusion within the Core Strategy of these two Given the significant overlap with the Green Belt, it is considered policies sets out a clear strategic approach for the future of Castle Point. It provides the Borough inappropriate to also reference the Coastal Protection Belt in the Core Council and its partners with a firm base from which to pursue initiatives to secure a sufficient supply Strategy. In preference, the Council proposes to develop proposals for of land to meet development needs and new infrastructure provision to support development that positive uses and functions of the Green Belt as part of the Benfleet, supports the strategic vision for the Borough. Such underpinning will be important given that Castle Hadleigh and Thundersley Plan and the Canvey Area Action Plan. Point is not required to accommodate a large amount of regional strategic growth and is a Green Belt district, but with economic and regeneration issues to be addressed. The Core Strategy is therefore considered sound by the Council and does not need amending as recommended by this consultee. Nevertheless, Policy SS1 should be amended to also incorporate reference to the Coastal Protection Belt, strategic policy guidance for which is currently provided within ‘saved' Policy CC1 of the Essex & Southend-on-Sea Replacement Structure Plan. The fourth bullet of Policy SS1 should be amended by insertion of the words ‘and the Coastal Protection Belt' before the words ‘until 2031'. In support of this addition the Core Strategy should also include suitable and effective replacement policy guidance for the Replacement Structure Plan Policy CC1 (which is ‘saved' following a direction of the Secretary of State, dated 27 th September 2007, under paragraph 1(3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004) which reads,

‘Within the Coastal Protection Belt defined in adopted local plans there shall be the most stringent restrictions on development within the rural and undeveloped coastline situated outside existing built- up areas, and any development which is exceptionally permitted within this Belt shall not adversely affect the open and rural character, historic features or wildlife.'

In addition, the supporting text for Policy SS1 should refer to the need for community facilities, including schools, to support sustainable development. This would support the vision of both authorities to secure high standards of local educational attainment and the delivery of 21 st century schools, delivery of which is supported by the Building Schools for the Future programme. Recognising that some schools in Castle Point (for example, The Deanes School, Thundersley, and The King John School, Benfleet) lie within the periphery of the Green Belt, the supporting text of Policy SS1 should acknowledge that redevelopment and enhancement of key existing educational facilities may be necessary within Green Belt locations, with a commitment to highlight particular key sites within relevant Local Development Plan Documents. 334 Policy SS 1 Jetbury Investments MARY POWER U J Paragraph 41 of PPS3 Housing (November 2006) identifies a national annual target of 60% of new E Jetbury Investments Ltd's representations raise The SHLAA effectively demonstrates that 70% of new development can be Principles of Ltd SAVILLS housing to be provided on previously developed land. Policy SS2 of the East of England Plan (May issues of significant importance that question the delivered on previously developed land. The Council therefore considers Sustainable COMMERCIAL LTD 2008) also sets a target of 60% of development to be on previously developed land. soundness of the plan. We therefore request the Core Strategy to be justified in this regard. Development and participation in the oral examination to ensure Growth our case can be fully made and subject to We acknowledge that these are not maximum targets, however, there is no evidence provided to questions by the Inspector as appropriate. demonstrate that 70% is a realistic or achievable target for the Borough. We are therefore not convinced that Policy SS1 is based on a robust and credible evidence base. 392 Policy SS 1 WM Morrisons Mr Jason Lowes S J W No response required. Principles of Supermarket Plc Rapleys Sustainable Development and Growth 41 Distribution of Mr Martin Twigg U E Paragraph 5.12 to 5.21- Distribution of Sustainable Development and Growth E The core strategy includes a clear explanation of the distribution of Sustainable Fox Land and development throughout the borough as a whole. The needs of the Development and Property Limited borough are to be met primarily through development within the urban area There appears to be no comment as to the justification of the distribution between Canvey Island Growth in accordance with government policy. This is to be delivered through a and the Mainland notwithstanding the embargo on granting new residential dwelling planning programme of regeneration which will provide for housing, employment and consents on the island over the last two years. key community infrastructure to meet the needs of the borough as a whole. The core strategy identifies a variety of sources of funding to provide this In the Sustainability Appraisal January 2009 carried out by Baker Associates they also comment community infrastructure. The council does not accept the respondents that they are unclear as to the reasoning for the 50/50 distribution between the town centre and justification for providing a greater proportion of new housing in the urban growth. mainland part of the borough.

The concern therefore is that without the evidence to substantiate the position stated in the draft Core Strategy there is no way of testing whether the sites are deliverable, developable or available.

Canvey Island has suffered from problems with image and perception. As such low rates of delivery and demand exist. This point is reinforced by our review of delivery rates of those sites identified in the Council's Urban Capacity Study (2004) which demonstrates a net gain on the mainland of 44% compared with only 15% on Canvey Island.

There is a recognised need for enhanced facilities, particularly health, leisure and education on Canvey Island. New development would need to be supported by enhanced provision of community Page 48 of 222

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facilities as without this, the shortfall would be exacerbated. The Council has not produced any evidence which demonstrates how these new facilities will be funded. It will be marginal whether it is viable for sites on Canvey Island to contribute in any meaningful way towards the provision of new infrastructure owing to the high cost of development against lower values achievable on the Island. If new development is relied upon to deliver the facilities, this may prove to be a barrier for new schemes to come forward.

To ensure the housing supply is deliverable and achievable the mainland should provide for a greater proportion of new housing development in the Borough. 42 Distribution of Mr Martin Twigg U E From our assessment we cannot support the Council's conclusions in relation to the quantum and E Attend Examination The council does not accept the respondents assessment of the capacity of Sustainable Fox Land and distribution of growth. This table has been prepared on the basis of the Council's SHLAA 2008 which the various locations referred to in the response. For example the council Development and Property Limited we believe is unsound. Thus there is not a sufficient supply of land to meet the RSS requirement of a has had independent assessments of the capacity of Canvey and Hadleigh Growth minimum 5,000 homes by 2026. In the absence of sufficient evidence from the Council our analysis town centres which demonstrate that the capacity of these locations is in shows: accordance with the figures referred to in the document. Similarly the council maintains that the capacity of the other sites referred to is considerably greater than that set out in the response. Employment growth and Regeneration

Canvey Town Centre - Is only likely to provide a maximum of 137 net increase in dwellings

Canvey Sea Front - 112 Mobile homes should be excluded as these are neither suitable nor available to meet the local housing need.

Hadleigh Town Centre - Is only likely to provide a maximum of 106 net increase in dwellings.

Manor Trading Estate - Even if such a contaminated site could be developed the maximum number from this source would be 150.

Housing Growth and Community Development

Point Industrial Site - Is only likely to provide a maximum of 55 dwellings and not 175.

Land east of Canvey Road - For such a large allocation until the EA have agreed an exception to PPS25 the 400 dwelling cannot be counted as deliverable.

Castle View School - The availability of the site remains in doubt. Essex County Council made a clear commitment in the Preferred Option in retaining the School. Objections have also been made about the Petroplus installation being too close to this site for it to be used for further housing.

Sustainable Growth & Environmental Conservation

Canvey Island/ Benfleet, Hadleigh and Thundersley - The way in which assumptions have been made in the SHLAA 2008 as to the availability of sites is unsound. The figure of 1,450 bears no relation to the breakdowns provided in the SHLAA 2008 but what is clear the figure includes a proportion of sites where no responses were received from Land owners, unimplemented planning consents and untested assumptions along the ‘Main Route Survey'. 71 Distribution of Barratt Mr SIMON U J Also Effective and Consistent with National Policy E Barratt's development proposals in the broad Whilst it is recognised that the East of Rayleigh Road, North of Daws Heath Sustainable FLISHER location of Daws Heath Road are a significant Road location is sustainable, it is considered by the Council that the Green Development and THE BARTON part of the local planning context for Castle Point Belt in this location has a strategic function in preventing the coalescence Section 5.19 asserts that CPBC has reviewed a number of alternative sites with regard to their Growth WILLMORE Borough, as reflected by the fact that officers of place by separating Hadleigh from Rayleigh. This is consist with the sustainability as broad locations for growth. In this context, the following points are of particular PLANNING identified the broad location as a major housing aims of the Green Belt set out in PPG2, and therefore the Core Strategy is relevance: PARTNERSHIP allocation in previous iterations of the Core considered to be consistent with national policy and therefore sound. Strategy and continue to rank the site as the • The Sustainability Criteria specified by CPBC in previous iterations of the Core Strategy most sustainable urban periphery option. It is have been deleted; anticipated that a planning application for residential-led development at the site will be • CPBC cite their ‘Revised Assessment of Sites on the Urban Periphery' (September 2009) submitted between this current LDF consultation as part of the evidence base to the Core Strategy, but fail to allocate for housing the broad and the commencement of the EiP. Participation location to the north of Daws Heath Road (also called east of Rayleigh Road) which this in the EiP would therefore serve to ensure that document ranks as the number one site for housing in the Borough. the information provided to the Inspector is comprehensive and up to date. It is clear from the evidence base to which CPBC refer, together with the previous representations by Barratt and the previous iterations of the Core Strategy, that the broad location to the north of Daws Heath Road continues to perform excellently against sustainability criteria. Sustainability is at the heart of the planning process, as detailed in the provisions of PPS1, and it is considered that the broad location to the north of Daws Heath Road provides an opportunity for a planned urban extension to an existing settlement that will bring significant environmental, social and economic benefits. The release of the area from the Green Belt is important as it will allow planned and Page 49 of 222

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sustainable growth that will enhance the existing community as well as the Borough as a whole. The site is particularly suited to development due to factors such as its close spatial relationship with existing urban areas; self-contained nature; limited possibility for resultant settlement coalescence; juxtaposition with existing land uses and facilities; and its excellent degree of accessibility.

In summary, it is concluded that the unsoundness of CPBC's approach to housing policy within the Core Strategy is centred on:

• Failure to justify the approach that has been taken. CPBC's do not appear to have considered their own evidence base (the assessment of urban periphery sites) when drafting the Core Strategy. The sustainability evidence in favour of the broad location to the north of Daws Heath Road, submitted by Barratt, does not appear to have been properly taken into account. CPBC have taken an unreasonable approach to the way in which their review of the relative merits of sites on the urban periphery has been translated into the broad allocations for housing that are contained in the Core Strategy. • Failure to effectively deliver housing growth in the most appropriate broad location; • Failure to comply with relevant strategic policy requirements, including the requirements of PPS1.

In response to the unsoundness of the approach that has been taken to date, the main changes that should be made to the Core Strategy are:

• An explanation should be given by CPBC as to why the broad location that they continue to rank as the number one sustainable site for housing has not been allocated for residential development in the Core Strategy. • It should be noted that the Sustainability Appraisal, prepared by Baker Associates, also repeatedly highlights this fundamental flaw. For example, it highlights at Section 4.7 that "Neither the DPD or site assessment process gives a justification for this site not being allocated. The SA suggests that the allocation of this site could have preferable implications for sustainable development than other ‘mainland' allocations".

Overall, it is considered that the broad location to the north of Daws Heath Road should be identified in the Core Strategy for new residential development. As has been previously acknowledged by CPBC officers, the development of the broad location should play an important part in ensuring that the provisions of the Core Strategy are both effective and consistent with the overall strategic policy context within which the Core Strategy sits. 85 Distribution of Mr Richard Inman U E We welcome the Core Strategy's recognition of the flood risk to Canvey Island. You may want to W With regard to the proposed link to policy CP5 in paragraph 5.19, a minor Sustainable GO-East make a link to Policy CP5 at this point. The Sustainability Appraisal (para 4.7) suggests that an amendment is included to enable this. Development and alternative site to the east of Rayleigh Road should also have been identified. Growth With regard to the exclusion of the site to the East of Rayleigh Road, North of Daws Heath Road, this site is considered by the Council to fulfil a strategic Green Belt function by preventing the coalescence of place by separating Hadleigh from Rayleigh. This is consistent with the aims of the Green Belt as set out in PPG2, and therefore considered to be sound. 140 Distribution of Mrs Olwyn Harris S J E The Hands Off the Green Belt Group wish to be No response required. Sustainable Hands Off Our represented at the oral part of the examination Development and Green Belt to ensure that the views of many of the residents Growth of Daws Heath who wish the Core Strategy to be upheld, and the land north of Daws Heath Road to be protected, from the renewed attempts by Barratt's building company to obtain planning permission for a housing development, on green belt land, which is out of keeping in scale and nature with this semi-rural area.

Our local councillors, by refusing to vote for a strategy that included the Daws Heath Site, recognised the important green belt function that this land plays in separating the Rayleigh and Thundersley communities. They shared the public's lack of faith in the effectiveness of the scoring system which placed the Daws Heath site, previously not favoured for development, ahead of others in suitability in the draft Core Strategy of 2008.They further recognised the fierce opposition to its inclusion by local residents and leisure users of the Daws Heath

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area.

We feel that the Core Strategy is sound in that the site was removed on the basis of research and fact finding during the consultation period and the involvement of the local community in bringing about a change in line with overwhelming public opinion 177 Distribution of Ms NATALIE S J EEDA's principal role is to improve the economy of the East of England through the promotion of No response required. Sustainable BLAKEN sustainable economic development and regeneration; and through the delivery of the Regional Development and EEDA Economic Strategy (RES) ( Inventing the Future - Collective Action for a sustainable economy, Growth 2008). The RES advocates a region that is internationally competitive with a global reputation for innovation and business growth that harnesses and develops the talents and creativity of all and is at the forefront of a low carbon and resource efficient economy.

Planning Policy Statement 1 ‘Delivering Sustainable Development', 2005 reminds local authorities that they should plan for sustainable growth in support of the RES through local development documents. Also, Planning Policy Statement 12 ‘Creating Strong Safe and Prosperous Communities through Local Spatial Planning', 2008 highlights the importance of spatial planning in relation to economic growth and regeneration. The RES supports and complements the East of England Plan and EEDA supports the implementation of policies within that strategy. 393 Distribution of WM Morrisons Mr Jason Lowes U J Paragraph 5.19, and the bullet points following it should be deleted, and replaced with the following E The issues raised by these representations are The Core Strategy sets out a distribution of development that identifies the Sustainable Supermarket Plc Rapleys wording: fundamental to the soundness of the Core broad locations for growth in Castle Point to 2026. This is consist with Development and Strategy, and are sufficiently complex to warrant advice received from GO-East in 2007, and therefore the amendments Growth discussion at the examination. proposed by this consultee are not considered appropriate by the Council, "There is a further need for housing capacity beyond this location, particularly on Canvey Island, in as this would mean that the Core Strategy fails to respond to this advice. order to accommodate housing growth and the Council will review the existing green belt boundary on Canvey Island through the Canvey Island Area Action Plan to ensure that there is sufficient land available to meet the identified development requirements throughout the Plan period." The Council is confident that the Core Strategy is sound with regard to both issues raised regarding the evidence base. The reason for this requested change is as follows: The SHLAA was prepared using detailed street level surveys. All landowners with potential sites were identified and written to. It is Paragraph 5.19 of the Core Strategy is unsound, as the Council's identification of three Green Belt recognised that a number of these landowners did not respond to this locations for residential development on Canvey Island is unjustified on the grounds that: consultation, however the SHLAA considered deliverability over a period of 18 years, and therefore it is reasonable to assume that landowners may • (i) The Council's Strategic Housing Land Availability Assessment (SHLAA) is flawed, as it not hold the same view of redevelopment later in the plan period that they overestimates the capacity of the existing urban area on Canvey Island to accommodate did in 2008, particularly as the economy improves. Where no response was new housing, and received, the potential contribution from a site was not included in the first five years of the plan period. Furthermore, a proportion of the development • (ii) The Council's evidence supporting the sites is unconvincing and does not provide from sites where no response was received was distributed on a non-site sufficient evidence that the most appropriate sites have been identified for release from specific bases to "never" coming forward for development. Therefore, the the Green Belt. SHLAA has fully taken into account the issue of uncertainty surrounding such sites. Both of these issues have been comprehensively discussed in previous representations, most th recently on 19 March 2009 (which are attached for information), albeit these representations With regard to the industrial areas identified for redevelopment, the Council predate the Council's revised Assessment of Sites on the Urban Periphery (September 2009). is anticipating the receipt of an application for one of the sites in due course. As a result, the Council is confident that land is available from this Castle Point Strategic Housing Land Availability Assessment (January 2009) source, although it does recognise that it is harder to achieve such redevelopment in comparison to the development of a Greenfield Site. The document sought to identify potential housing sites from a variety of sources, including surveys to identify potential sites on main routes in Canvey Island, and an update to the Council's 2004 The SHLAA is therefore considered sound, and will be updated regularly to Urban Capacity Study. However, the surveys were carried out in November 2007, when there was ensure that it remains so. more optimism in the housing market than in January 2009, and no allowance is made within the SHLAA for any influence this change of economic circumstances might have on the intentions of the With regard to Green Belt Sites, the Council has prepared a document owners of the potential residential sites. entitled Sustainability Assessment of Sites on the Urban Periphery (2008). This was subject to consultation alongside the Further Preferred Options Further, approximately 48% of the dwellings identified in the Urban Capacity Study update were not Report and scrutiny by Members. As a result of this, the assessment was subject to a response from the relevant land owner, and in the case of the Main Route Survey, 33% revised to build in comments that the scoring was not sufficiently objective of the units were not subject to a response. A lack of response would, if anything, indicate that the and did not weight sustainability issues sufficiently. In order to overcome owners of those sites no longer wished for them to be brought forward for residential development. this, clearer, more objective measures were attributed to each criterion, However, the SHLAA assumes that the same proportion of these units will be ultimately delivered for and the results of a citizens panel survey were used to identify the residential units as those units which had been subject to a response. These surveys are therefore importance of each criterion. Each site was then rescored. With regard to flawed in terms of methodology and by the passage of time, and indicate a level of potential housing land West of Canvey Road (Triangle) the sustainability score remained significantly higher than is likely to be deliverable. negative, and the position of this site in sustainability terms in relation to other sites did not change. As a result, this location is not considered to be a reasonable alternative. The Core Strategy is considered sound in The SHLAA also identified two industrial estates on Canvey Island as being potentially suitable as excluding this site as a development location. residential sites. However, both sites are in multiple ownership, and it is recognised by the SHLAA that there is little evidence that a sufficient number of the owners have aspirations for residential development on the site to render either site realistically deliverable for residential use. Therefore, Page 51 of 222

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these sites cannot be relied upon to deliver housing during the plan period.

In conclusion, the SHLAA strongly indicates that the existing urban envelope of Canvey Island is unable to accommodate the growth in housing which is required by the Core Strategy. However, it over-estimates of the capacity of existing urban area of Canvey Island. Therefore, it is not possible to assess how many new residential units will be required on peripheral sites during the Plan period and, correspondingly, it is not possible to ascertain whether the sites identified will be sufficient to prevent pressure for further, uncontrolled development in the Green Belt.

As such, identifying locations to accommodate new housing on peripheral sites at this stage renders the Core Strategy unsound, and therefore reference to them should be removed. In these terms, it is suggested that the wording of the Core Strategy be amended to confirm that Green Belt boundaries will be reviewed as part of the Canvey Island Area Action Plan. This will provide an opportunity for further assessment to take place without the need to reconsider the Core Strategy.

Evidence Supporting the Identified Sites

The evidence supporting the identification of three sites on Canvey Island in the Core Strategy does not adequately justify their release from the Green Belt. This evidence chiefly consists of the Council's Revised Assessment of Sites on the Urban Periphery, dated September 2009. This is an updated assessment of a previous version published in 2008, which was subject to detailed representations by Morrisons in March 2009. There are four principal issues which render this assessment unreliable, as follows:

The Scope of the Assessment - the assessment considers a number of criteria and factors against a number of identified potential sites. However, these criteria and factors do not reflect the issues that PPG2 advises should be the material factors when considering whether land should be included within the Green Belt. The assessment also appears to pay no regard to the importance of setting clearly defined boundaries for the Green Belt. These issues are discussed in further detail in the representations relating to the soundness of this element of the Core Strategy in terms of National Policy (which have been submitted alongside these representations).

Further, notwithstanding the need to minimise encroachment of development onto the Green Belt, the assessment does not consider the amount of space which each site would release from the Green Belt in comparison to the quantum of development that would be delivered. For example, whereas site C.37 (the Triangle) would require 10.47 hectares to be removed from the Green Belt to deliver between 315-550 units of housing, site C.3 (east of Canvey Road) has a site area of nearly 40 hectares for 350 units of housing, albeit it is recognised that the site would include a health centre, leisure centre and some open space provision.

Identification of the Individual Sites - the assessment does not define any boundaries for the individual sites and therefore identification of the sites to interested parties (such as adjacent owners/occupiers) is not possible. Further, lack of identification of the sites also prevents independent testing of how each site was assessed.

It is also unclear as to how some of the sites within the assessment have been assembled, and why some of the identified housing sites incorporate development which could be delivered independently and within existing settlement boundaries. For example site C.3, the land east of Canvey Road, incorporates a new leisure centre and a new healthcare centre alongside 350 units of housing. There is no evidence that the community facilities are ancillary, or dependent, on the delivery of the housing. There is also no explanation as to why a new healthcare centre or leisure centre cannot be accommodated within existing settlement boundaries. However, the "bundling" of housing with unrelated community facilities creates the appearance that the housing on the site is more sustainable than it is.

Weighting - in scoring the various sites, a weighting system was used based on the results of a Citizens Panel consultation in 2008, and the findings of the assessment have been heavily influenced by this. As identified within Appendix 3 of the Sustainable Appraisal supporting the Core Strategy, the weighting process revealed that people surveyed put most significance on the protection of open land and sites of wildlife importance. However, as a result of the findings, the weighting of issues such as whether the land had been previously developed has been inappropriately skewed to influence the assessment up to four times as much as other important considerations such as whether the delivery of the site would reduce the need to travel and promote sustainable forms of transport.

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prominence to accessibility issues is inconsistent with the principles of sustainable development, and is particularly inappropriate given that the Core Strategy identifies severe traffic congestion on Canvey Island at present. Therefore, as a result of the manner in which the assessment was weighted, the assessment cannot be relied upon to properly reveal which sites are the most sustainable to release from the Green Belt.

Scoring - as with the previous assessment in 2008, the scoring of each element appears inconsistent. Although it is difficult to comment on how each site was scored without details of their location, there are a number of examples where sites very close to one another, which might normally be expected to secure similar scores for various criterion, receive different scores. For example, in the case of site C.2 (west of Canvey Road), and site C.34 (the Triangle), which are adjacent to one another. In the second factor of Criterion E (relating to accessibility) the site west of Canvey Road is awarded a score of 2, as it "is adjacent to a busy road with employment and housing adjacent". However, the Triangle site scores -1, as it "is removed from the existing urban area by a busy road", notwithstanding that the sites are adjacent to the same ‘busy road', and the same housing.

In addition to such inconsistent scoring, some of the individual scores themselves are questionable. For example for site C.3 (east of Canvey Road) the two factors for criterion G (relating to ecology are scored as +2 even though there will be no positive benefit to ecology, and therefore the score should be 0. As this criterion is given quadruple the weight of other issues such as accessibility, this significantly overstates the sustainability of this site and undermines the assessment.

Finally, in addition to the issues within the Assessment of Sites on the Urban Periphery, the Council's Sustainability Appraisal also raises questions as to how the assessment has translated into identification of potential development sites in the Core Strategy. Notwithstanding the contents of the Sustainability Appraisal, to date, no justification for the selection of the sites has been provided.

Conclusions

In summary, the Council has provided insufficient evidence to confirm the capacity of the existing urban envelope to deliver the housing numbers required and, correspondingly, the number of units which will be required outside the urban envelope (albeit the evidence strongly suggests that more housing will be required outside the existing settlement boundaries than is allowed for in the Core Strategy). Further, the Council has not provided sufficient and reliable evidence to indicate that it has chosen the best locations for accommodating housing in sites on the urban periphery. In these terms, all location specific references to potential housing sites in the Green Belt on Canvey Island should be removed. An updated SHLAA should be produced, and sites on the urban periphery assessed appropriately. 394 Distribution of WM Morrisons Mr Jason Lowes U N Paragraph 5.19, and the bullet points following it should be deleted, and replaced with the following E The issues raised by these representations are The Core Strategy sets out a distribution of development that identifies the Sustainable Supermarket Plc Rapleys wording: fundamental to the soundness of the Core broad locations for growth in Castle Point to 2026. This is consist with Development and Strategy, and are sufficiently complex to warrant advice received from GO-East in 2007, and therefore the amendments Growth discussion at the examination. proposed by this consultee are not considered appropriate by the Council, "There is a further need for housing capacity beyond this location, particularly on Canvey Island, in as this would mean that the Core Strategy fails to respond to this advice. order to accommodate housing growth and the Council will review the existing green belt boundary on Canvey Island through the Canvey Island Area Action Plan to ensure that there is sufficient land available to meet the identified development requirements throughout the Plan period." The Core Strategy is considered to be consistent with PPG2 through the exclusion of land to the West Of Canvey Road (Triangle) as a development location. The reason for this requested change is as follows:

The site is visually prominent and clearly undeveloped. Its development Paragraph 5.19 of the Core Strategy is unsound as the identification of three Green Belt locations for would, in the view of the Council constitute a significant incursion into the residential development on Canvey Island is inconsistent with National Planning Policy. Countryside and would be a clear example of urban sprawl. As a result, this would be contrary to PPG2 and undermine the strategic function of the National policy in respect of the Green Belt is set out in Planning Policy Guidance 2: Green Belt, Green Belt on Canvey Island. which was published in January 1995, and amended in March 2001.

PPG2 confirms that the purposes of including land in the Green Belt are as follows:

• i) To check the unrestricted sprawl of large built-up areas; • ii) To prevent neighbouring towns from merging into one another; • iii) To assist in safeguarding the countryside from encroachment; • iv) To preserve the setting and special character of historic towns, and • v) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. • vi)

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confirms that the purposes of including land within Green Belt have paramount importance, and should take precedent over land use objectives. PPG2 also confirms the importance of setting clearly defined boundaries for the Green Belt, using readily recognisable features such as, inter alia, roads. The document also stresses that Green Belt boundaries should be drawn with the need to promote sustainable patterns of development in mind.

The evidence supporting the three identified sites chiefly consists of the Council's Revised Assessment of Sites on the Urban Periphery, dated September 2009. This document is a checklist of a number of sustainability criteria, weighted in accordance with the criteria identified as being of importance by a Community Panel in 2008.

However, the assessment does not take into consideration a number of the identified purposes of including land in the Green Belt, for example the need to check unrestricted sprawl of large built-up areas, and the need to prevent neighbouring towns from merging into one another. Further, the assessment makes no reference to, and therefore the sites were not assessed against, whether the sites had defendable boundaries to prevent further encroachment onto the Green Belt.

In these terms, the Core Strategy is unsound as it is not in compliance with national policy. However, removing reference to the three sites, and replacing them with a commitment to review Green Belt boundaries as part of the Canvey Island Area Action Plan would ensure that the Core Strategy is sound in this regard. 12 Policy SS 2 Mrs J Allen U J As someone who moved from an area that once had many green open spaces but became filled W The Core Strategy sets out policies in the form of CP1, CP2 and DC16 that Distribution of with over-development, i would have the same to happen to this lovely Island. I was brought up on will ensure that new housing development is supported by community Sustainable care in Hornchurch and remember many green spaces. I spent much of my adult life in Surrey, and facilities and open space provision. Existing parks and open spaces are Development and saw what over-development did to the area that I loved in, Coulsdon in Surrey. protected from development under policy DC16, and policy CP2 seeks to Growth 2008 - 2026 improve access to the natural environment through the creation of nature reserves covering much of West Canvey. Every house that was purchased by Developers ended up being filled with too many houses! (Over- development), which in turn meant that thee was no where for young children, and teenagers to spend their spare time, consequently the area ended up being covered with graffiti and a lot of crime With regard to the town centre, Canvey Town Centre is the subject of incurred because obviously they were bored! There was nothing for them to do, and nowhere to go! Masterplanning, as set out in policy CP7. This aims to ensure that a mix of development is provided in the town centre to improve its vitality. This will provide opportunities for employment. Our two local towns i.e. Couldson and Purley, Surrey ended up as ghost towns. The shop in turn were purchased by property developers and ended up, as, in my opinion, small estates with no facilities. Again no account was taken of leaving green and open spaces for youngsters and young Policy CP6 meanwhile seeks improvements to the employment areas and families. No parks were left, and I could not wait to leave the area. An area that I once loved and the delivery of additional land for employment purposes in order to provide raised my children in. jobs for local people.

I love Canvey Island and would hate it to go the same way as many other areas in Britain. Thought The Core Strategy has therefore given consideration to the future needs of must go into any redevelopment, and all issues I have raised should be taken seriously. The people local residents in proposing the housing distribution set out in policy SS2. It on Canvey area unique, in my opinion, and i feel many feel the same as I do. is therefore considered sound in respect of the issues raised in this consultation response. I also think it is vitally important to encourage business onto the Island so that our young people and older people will find employment. Work, I feel makes a person have some pride in themselves, their families, and their community. Over-development, in my opinion, will be a nightmare in the making.

Please also leave what green space we have. We get so much enjoyment from walking our pets and also having spaces where young children and teenagers can play football, cricket and even boating. Keeping young people occupied with even a youth club will I can assure you reduce crime. 32 Policy SS 2 Mrs D Fincher U J I have not a computer so not able to obtain all the information suggested. W It is recognised that there is some local resistance to flats being built in Distribution of town centre locations. However, there is also resistance to development on Sustainable Greenfield land. The provision of flats in town centre locations, particularly As I am wheelchair bound due to an accident in 2005 have not been able to show more interest in Development and above shops and in edge of centre locations is consistent with PPS3 and the future of Castle Point and however hope that very much consideration be given to Increase the Growth 2008 - 2026 PPS4. This relieves pressure on Greenfield land and the Green Belt - shopping area and no more flats be built in the main area. consistent with PPG2 and sustainability principles in PPS1. Therefore, the Core Strategy is considered appropriate in seeking to increase dwelling I will be unable to attend any such meetings discussing future plans for Hadleigh but hopefully will capacity in town centre locations, alongside renewal of retail provision. hear what is planned. I have lived here 52 years and have not seen the main are of Hadleigh improve so much.

Hoping your plans with Core Strategy will be successful and empty properties of long standing be looked into more. 35 Policy SS 2 Mr Neal Warren U N As a resident of Castle Point, I have followed the development of the Core Strategy document very E Of the 3ha of employment development proposed on Green Belt land at the Distribution of closely. While the final document is a great improvement on the previous drafts, I am still concerned Rayleigh Weir, only 1.3ha remains undeveloped. The developed land was Sustainable over proposals to develop greenbelt areas within the Borough when there are existing Brownfield granted consent by the Secretary of State. Development and areas that have not been fully investigated. The proposal to develop land East of Rayleigh Road is Growth 2008 - 2026 one point I would ask for review. While the proposal is much smaller than original proposals, the The 1.3ha of remaining land is adjacent to the existing employment area at area is close to one of the most congested junctions in the Borough. The A127 / A129 is a source of the Rayleigh Weir and separated from the residential area to the south by a major traffic hold ups in rush hours, and it only takes a minor traffic issue somewhere in the Borough Page 54 of 222

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or back in Southend and this junction grinds to a halt. Any development which will put further traffic large field. It is therefore unlikely that the loss of the natural rainwater on to the A129 or A127 must be prohibited. I suggest independent visits be made to look at this attenuation benefits of this site will impact on residential development in junction to see what effect developments will have. Castle Point is already over developed, and the this area. Furthermore, the Core Strategy contains policy CP4 which infrastructure is inadequate. requires on-site attenuation of surface water runoff.

The South East of England where Castle Point is located is a water stressed area, further The remaining 1.3ha of undeveloped land is to the east of the development development will mean that greater pressure will be placed on the water supply system meaning permitted by the secretary of state, and does not extend any further south extensive investment at residents cost to ensure a basic need is met. In addition development of than this development. Therefore, the Green Belt separation in this location greenbelt land will mean less ground available to absorb rain water and increase the risks of would be retained if this site were developed. flooding. With climate change we are already being told loss of green land is an issue for flooding. It is this reason that new developments must utilise permeable solutions for driveways. However land With regard to traffic generation, the County Highways Authority have not will be lost to buildings and permeable surfaces will not be sufficient. objected to this proposal on the grounds of limited highways capacity in this location. Greenbelt land is needed to mark boundaries and stop urban sprawl, it is also home to wildlife and with reducing greenbelt the remaining sites are key to ensuring wildlife habitats are maintained. If The Core Strategy, in including 3ha of employment land adjacent to greenbelt is developed where does the wildlife move to? Rayleigh Weir industrial estate is considered sound as it can be delivered effectively, without impacting on the strategic function of the Green Belt in Please consider these points and also review the scoring mechanisms used by the Council in this location. identifying land for development, as I believe they are flawed and do no take account of several issues such as traffic volumes and general infrastructure. 36 Policy SS 2 Mr & Mrs D W U J Russell House is situated on the main Canvey Road, next door to Theohall. Our proposal is for W This is a matter of detail regarding the boundary for development regarding Distribution of JONES development of the infill's from Theohall up to the garden centre adjacent to Northwick Road. the proposed provision of housing for older people on the West of Canvey Sustainable Theohall at present is used as a scrap yard fronting onto Canvey Road, this is a complete eyesore Road frontage. This will be dealt with as part of the Canvey Area Action Development and which is viewed from both dual carriageways (Canvey Road and Roscommon Way) to the front and Plan, and therefore the Core Strategy is considered sound. Growth 2008 - 2026 the rear of the property. For many years Russell House has a lawful use for storage and a builders yard. Hill Farm which is next door to Russell House is now a luxury dwelling that was erected on the site of a small wooden farm building. Then we come to the Dutch Cottage which is now a museum with a car park that attracts numerous visitors in the season.

There are two more properties on the frontage - Homestead and Raydel House owned by the Howard family with plans for family homes. The garden centre is the last property on the frontage with proposal for a 50 bedroom nursing home.

There has been concern that if this area were to be developed there would be some increase in traffic movement. This has been discussed with Mr Brooker Head of Highways Department, he indicated that the existing four exits from Russell House and Theohall could be dispensed into a single improved access onto Canvey Road the imminent development of Roscommon Way extension phases I and II would reduce traffic by more than 50% in this area.

This site serves no useful green belt purpose. It is more than 40 years since the area was farmed, as it was actually 40 years ago when permission was given for an oil refinery to be built. This never came to fruition and the area was no longer farmed and was owned for many years by Occidental. The government has described this area as brown fill site.

The Howard family proposals and a well planned much needed development of affordable housing on the site of Russell House and Theohall would make a combination of various attractive features of the area. 56 Policy SS 2 Mr Barry Brazier U J It is proposed to develop a community hub on public land and adjacent vacant land to the north of W The land proposed for the creation of a community hub North of Kiln Road Distribution of Kiln Road to deliver a wide range of community and leisure services. is currently identified as a College and as Local Government on the Sustainable Proposals Map. A significant part of this site is already developed providing Development and leisure, council offices and a college, however one field remains open and It is contended that this proposal is NOT JUSTIFIED as it appears not to be the most appropriate Growth 2008 - 2026 is currently used by students and employees of the Council during summer strategy when considered against reasonable alternatives. months for siting out. There is the potential for this field to be used to provide a healthcare centre for Thundersley. It is recognised that this will This intention is laudable, but the location for this is crucial. The only "public land" obviously result in the loss of a field, however, a further field to the north of this is identifiable in this area is the open land to the rear of the Council Offices, known as Runnymede identified in the local plan as public open space. The Council intend to Paddocks. retain the allocated public open space.

Since the Paddocks came into ownership of the Council, this land has been progressively built on. It is recognised that town centres are good locations for community Initially with the Council's offices, followed by Runnymede Hall, then the swimming pool, finally with services, however it is not practical to relocate the current facilities at the the allegedly "temporary" building (the White House) which has now become permanent. Kiln Road Site to a town centre. The development of stronger links between the existing facilities is therefore essential, and the provision of a healthcare centre would compliment existing facilities well. The remaining open fields are extensively used by the public, including various youth and community groups, for informal recreation and outdoor activities. To further reduce the area available for public recreation will be contrary to aims and intentions set out elsewhere in the proposed Core Strategy The Core Strategy is therefore considered sound in proposing a community Document. hub North of Kiln Road.

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I refer specifically to the following;

a) Table 4 (Spatial Distribution of Regeneration and Growth - Sustainable Growth and Environmental Conservation) contains the statement that "opportunities for outdoor recreation will be encouraged". By developing these fields, the area of land available for outdoor recreation will be REDUCED, thus DISCOURAGING outdoor recreation.

b) Paragraph 6.18 states that "Open spaces are considered to have a vital role to play in a healthy and active community by providing opportunities for exercise, socialising and mental stimulation." Whilst this paragraph refers specifically to the need for formal open space to support natural open space, the underlying principle holds true in relation to all open space, whether formal "Public Open Space" or open land used informally.

• c) Table 9 (Monitoring Framework for Measurable Aims) seeks to increase the area of land open for public recreation by 50 hectares by 2026. The removal of part or all of the Runnymede Paddocks from the existing area of land open for public recreation will be counter to the Council's target.

This existing open land is located centrally within the residential area of "south Thundersley". It is the only area of open field (as opposed to wooded escarpment) available in this neighbourhood for informal outdoor public recreation. Should the 250 houses be built further along Kiln Road (in spite of the objections highlighted in separate Responses to this consultation and the overwhelming objections received to a recent Planning Application) the need to retain these open fields will be even greater.

The reference to "adjacent vacant land" in table 4 (Spatial Distribution of Regeneration and Growth) is equally worrying. Vacant land to the east of Runnymede Paddocks is included within the Local Wildlife Site CP23, whilst that to the north is Local Wildlife Site CP16. All of this land falls within the current Green Belt. All of the reasons for preserving Local Wildlife Sites, (as set out in separate Responses), apply equally to any proposal to build a community hub in this location. This "vacant land" should NOT be built on.

Alternative, better, locations for this facility are available.

The Spatial Portrait of Castle Point refers, in table 2 (Healthcare facilities), to the intention to provide a new healthcare facility located in the "Thundersley/Hadleigh area". Paragraph 6.3 states that "Community facilities should be located in town centres or other accessible locations to maximise community access and build a sense of local community identity." I would suggest that the town centre regeneration of Hadleigh provides an ideal opportunity to locate this much needed facility in a town centre. Possible sites include the former (now vacant) fire station, the nearby vacant "Crown" public house, the vacant former Land Rover and car showroom opposite the vacant fire station, and the existing bus depot at Victoria House Corner which would be better re-located to an employment area. Other parts of Hadleigh are also in need of re-generation and this facility could provide a focus for inward investment into the town centre.

Further afield, the possibility of siting this facility in a regenerated Tarpots centre should not be ignored. This location would be accessible, with good transport links to Thundersley and Hadleigh, particularly if the "passenger transport corridor" comes to fruition, and is located between the residential areas of New Thundersley and South Benfleet. Again, this facility could provide a focus for inward investment into the Tarpots centre.

To build this community facility remote from a town centre will not contribute towards building "a sense of local identity" as called for in paragraph 6.3 of the Core Strategy. A revised location in a town centre should be selected. 64 Policy SS 2 Sue Bull U E I do not have a great deal to add to my previous comments dated 20 Mar 2009. W Policy CP4 requires the preparation of a Watercycle Strategy, and for Distribution of Anglian Water developers to engage constructively with Anglian Water in ensuring Sustainable drainage issues are resolved. The Core Strategy is considered sound in I attach spreadsheet giving some indication of the constraints and issues that may be encountered. Development and respect of this representation. Growth 2008 - 2026 Spreadsheet to be uploaded later - all housing development proposals set out in the Castle Point Core Strategy shown as amber. This means that "Infrastructure and/or treatment upgrades required to serve proposed growth". 65 Policy SS 2 Mr Malcolm Kent U J APPENDIX C2 SITE PROFILE WEST OF CANVEY ROAD FRONTAGE ONLY/ W The West of Canvey Road (Frontage Site) has been included in the Core Distribution of Garden World Strategy since an early stage - it is not a last minute addition and is based Sustainable Garden Centre on consideration of the sustainability assessment of sites on the Urban SUSTAINABILITY ASSESSMENT . Development and Periphery carried out in 2008. As a result of consultation responses, the Growth 2008 - 2026 assessment was revised in 2009 to include a greater number of AX1 WILL IT CREATE NEW JOBS OR RESULT IN JOB LOSSES, MORE JOBS WILL BE LOSS measurable criteria, and weighting of criteria. The reassessment found that

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THAN CREATED 24JOBS WILL BE LOSS AT THE GARDEN CENTRE ,WITH ONLY 10 NEW this site continued to perform well in terms of sustainability. JOBS CREATED .AVERAGE AMOUNT OF STAFF USED TO RUN A SCHEMES OF THIS SIZE THIS IS NOT A CARE HOME . Ex1 is the site within 400 m walking distance of a range of The site has good access to public transport routes, good access to community facilities . the site is on a corner of a very busy road with poor footpaths elderly residents convenience retail and is well located in terms of safe access and egress would not be able to walk to the supermarket and there is no bus service . Fx2 would residents from Canvey Island in the event that a flood was to occur. Extra care leaving the site pass through a town centre . only if they go by bus .but not if they take a train. Hx1 accommodation, as the landowners propose to provide on this site, offers a would the development of the site result in the removal of a inappropriate building .this is the only variety of levels of care. As a result, skilled jobs will be provided on this site Garden centre on Canvey island serving 40,00 population and has made full use of the land under through its redevelopment. planning regulation,!x3

With regard to noise and smell, businesses operating in this location are In flood Zone 3 there is no safe aggress in the event of a flood ,there is no emergency plan for typically lighter industry, training facilities or related to vehicle storage - canvey.there area suffers from flooding in heavy rain condition and with the proposed development minibuses, ambulances and lorries for training. As a result, residential of east of Canvey road and the loss of Greenfield land flooding could increase. This site next to a amenity in this location is not an issue. With regard to the smell from landfill busy industrial park with heavy lorries passing all day and the oil refinery, this can be detected across most of Canvey and parts of the mainland and is not a reason for excluding this particular site from Totally wrong location for elderly residents, suffers from pollution smells from oil refinery and landfill the Core Strategy. site. The councils put this site in at the last minute was not on original plan There are emergency procedures in place for Canvey Island, as set out in policy CP5 a plan is being developed to enable residents to clearly understand what these procedures and how they should respond in the event of an emergency.

The Core Strategy has therefore given full consideration to the issues raised by this consultee and is considered sound in the inclusion of the West of Canvey Road (Frontage) for development. 66 Policy SS 2 Mr P Hartman U J All the following are unsound as no infrastructure and as a result of Council's own omission section W Policies CP1 through to CP4 set out how infrastructure will be delivered to Distribution of no 6. policy CP4: support growth and the needs of existing residents. As a result, the Sustainable locations identified in the Core Strategy are considered sound. Development and Growth 2008 - 2026 • Canvey Town Centre With regard to the proposal for development at North West Thundersley, South West Canvey • there is no infrastructure in place to support development in this location - • Canvey Seafront significant remodelling of a roundabout on the strategic road network is • The Paddocks required to achieve access to the site, and public transport routes serving • The Point Industrial Estate this location are limited. The County Highways Authority have sustained and objection to this proposal due to the impacts it would have on • Land East of Canvey Road infrastructure capacity. The Core Strategy is therefore considered sound in • Castleview School excluding this location.

All the following are unsound as no infrastructure:

• Hadleigh Town Centre • Manor Trading Estate • Rayleigh Weir • Land to the North of Kiln Road

Suggested land use bordering A127, A130 described as North Benfleet or Thundersley - reasons Excellent infrastructure. 67 Policy SS 2 A Williams U N I believe that planning to build on Canvey flood plain is unsound and unrealistic due to the facts W A sequential test in accordance with the requirements of PPS25 has been Distribution of that:- prepared to accompany the Core Strategy. This finds that the Core Sustainable Strategy is sequentially appropriate in terms of the distribution of Development and development proposed. Canvey Island is substantially protected by sea a) Global warming will raise sea levels significantly in the future! Growth 2008 - 2026 defences that offer a 1 in 1000 year level of protection. The Thames Estuary 2100 Plan seeks to maintain and improve the level of protection to b) More building works would mean more flooding from surface water! respond to climate change. The Core Strategy is therefore considered effective and justified. c) Would place intolerable extra pressure on services and infrastructure!

d) 45,000 people already live on the Island close to an aging Gas Plan with only one exit route!

e) The roads on Canvey will be unable to cope with the daily extra pressure!

Furthermore, I notice from my local newspaper that a planning application for a house in Mayland Avenue, Canvey was turned down recently because of strict rules about building on flood plains!

Does this mean that there is one rule for the Council and another for the public.

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68 Policy SS 2 Mr James Lord U E The Council must not be allowed to use Canvey Island as a key part of it's Strategy. Canvey is on a W The Core Strategy has been subject to a sequential test, in accordance Distribution of floodplain and only has limited access. In the event of a major crisis occurring there is no way that with the requirements of PPS25. This assessment found the Core Strategy Sustainable the current population could be safely evacuated let alone any increased population. The Council to be sequentially appropriate. There are Emergency Plans in place for Development and have completely ignored the area east of the A130 which already has viable access which would not Canvey Island that can be activated in the event of a Flooding Event. Growth 2008 - 2026 interfere with existing residential developments and which would provide the required additional These plans use Met Office Data and the EA Flood Warning System that employment with minimal disturbance. The land is mostly plotland and not accessible to general enables early evacuation as appropriate. Furthermore, community refuges public and the majority of owners in this area would not oppose a plan including their land. are being developed as part of new community buildings.

It is recognised that this consultee supports proposals to develop an urban extension to the North West of Thundersley. This was subject to consultation in the Spring of 2006, when many statutory consultees and residents objected to the proposal on the grounds of sustainability. The Sustainability Appraisal of Sites indicated that this development location is not sustainable as a result of its remoteness. There are also concerns about the extent of Green Belt land that would be lost as a result of this proposal, which is far greater than what is required to meet housing needs.

The County Highways Authority have maintained an objection to this proposals due to the impact it would have on the strategic road network. There is currently no access to the site and significant work would be required to a junction on the A130.

The ownership of the land is not recognised in PPG2 as a reason for removing land from the Green Belt. Furthermore, there is no evidence presented by this consultee that the majority of landowners in this location do support this proposals.

The Core Strategy is therefore considered sound in terms of the distribution of development identified. 69 Policy SS 2 Mr Adrian Lumb S J we would like to re-iterate our support for Castle Point Borough Council’s Core Strategy-Local W If you require any further details or information No response required. Distribution of Development Framework. on whatever matter during the forthcoming Sustainable process, or there is a requirement for us to Development and attend meetings please do not hesitate to Whilst writing we would like to confirm that the proposal outlined for the development of land at Growth 2008 - 2026 contact us. Canvey Rd between Northwick Corner and the Dutch Cottage remains unchanged.

The need for specialist mixed use accommodation for vulnerable adults-elderly people is as acute as ever, locally, regionally and nationally. This is an excellent site for such provision and ancillary requirements being in a good sustainable location. Many local jobs would be created.

You will no doubt refer to the points and issues raised in the original submission document all of which remain valid. 70 Policy SS 2 Barratt Mr U J Also Effective and Consistent with National Policy E Barratt's development proposals in the broad The Council has identified sufficient housing land to meet the housing Distribution of location of Daws Heath Road are a significant requirement set out in the East of England Plan to 2021. It has also Sustainable SIMON part of the local planning context for Castle Point identified a sufficient supply of land to meet housing needs to 2026. At this Policy SS2 is fundamentally unsound, given its stated intention of ‘distributing sustainable Development and Borough, as reflected by the fact that officers point the Council queries the appropriateness of the scenarios identified in development and growth' over the period to 2026. The following factors are crucial to the policy's Growth 2008 - 2026 FLISHER identified the broad location as a major housing the East of England Plan revision consultation, and therefore cannot unsoundness: THE BARTON allocation in previous iterations of the Core commit to further development beyond 2026 without additional WILLMORE Strategy and continue to rank the site as the consideration of the environmental capacity. Therefore, the Council is PLANNING • CPBC make inadequate provision for delivery of the housing requirements of the Regional most sustainable urban periphery option. It is confident that the Core Strategy is in conformity with the East of England PARTNERSHIP Spatial Strategy; anticipated that a planning application for Plan as far as is reasonably possible at this time. The representation from residential-led development at the site will be the Regional Assembly support this view. • The failure to allocate the broad location to the north of Daws Heath Road for new housing submitted between this current LDF consultation development is at odds with the evidence base and the conclusions of the Council's own and the commencement of the EiP. Participation Whilst it is recognised that the East of Rayleigh Road, North of Daws Heath officers. in the EiP would therefore serve to ensure that Road location is sustainable, it is considered by the Council that the Green the information provided to the Inspector is Belt in this location has a strategic function in preventing the coalescence comprehensive and up to date. The evidence base cited by CPBC fails to justify the approach that has been taken to the Core of place by separating Hadleigh from Rayleigh. This is consist with the Strategy's housing policies. CPBC's supporting documents, including the SHLAA and housing aims of the Green Belt set out in PPG2, and therefore the Core Strategy is trajectory assumptions, are lacking in robustness and credibility. Furthermore, the conclusions of considered to be consistent with national policy and therefore sound. CPBC's own Assessment of Sites on the Urban Periphery, which ranks the Daws Heath Road broad location as the most sustainable option, are not incorporated into the Core Strategy.

Barratt have undertaken a review of the housing land supply in the Borough and have concluded that CPBC are clearly unable to demonstrate an adequate deliverable supply of housing in order to meet the requirements of the regional spatial strategy and PPS3. It is anticipated that Barratt's housing land supply review will shortly be submitted to CPBC in support of a planning application for new residential development at Daws Heath Road. The allocation of the broad location to the north of Daws Heath Road for new residential development in the Core Strategy would help to ensure that

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the LDF is sound.

CPBC have been unable to explain why the previous draft allocation of land to the north of Daws Heath Road for housing has been removed. The broad location to the north of Daws Heath Road was previously recognised by CPBC as the most sustainable urban periphery site in the Borough and it is therefore considered that there is no sound planning basis for the abandonment of the development of the site at this late stage.

Development of the broad location to the north of Daws Heath Road would accord with the aspirations of Barratt and reflect the previous iterations of the Core Strategy prepared by CPBC and supported by Barratt. Delivery of a new neighbourhood in this location would help to enable the strategic delivery of the national and regional objectives for sustainable growth, but in a manner that would be tailored to the specific priorities of the locality.

The key strategic planning and sustainability advantages of the broad location to the north of Daws Heath Road are detailed in Barratt's previous representations. These advantages have been promoted by Barratt and acknowledged by CPBC in previous iterations of the emerging Core Strategy. Barratt consider that the way in which these advantages have been ignored by CPBC in the latest iteration of the Core Strategy is fundamentally unsound.

It is clear from PPS3 that suitable housing land must be identified within the Local Development Framework to enable appropriate proposals to be granted planning permission and implemented when necessary. Barratt agree with the previous advice of GO-East in connection with the emerging LDF, that the Spatial Strategy should be informed by "the extent to which the different options are feasible (linked to the evidence base), or about the implications of the options in terms of environmental, social and economic impacts". It is considered that development of the land to the north of Daws Heath Road would be both feasible and beneficial in terms of the resultant environmental, social and economic impacts.

In summary, it is concluded that the unsoundness of CPBC's approach to housing policy within the Core Strategy is centred on:

• Failure to justify the approach that has been taken. CPBC's evidence base in relation to the SHLAA and housing trajectories is flawed. CPBC have taken an unreasonable approach to the way in which their review of the relative merits of sites on the urban periphery has been translated into the broad allocations for housing that are contained in the Core Strategy. • Failure to effectively deliver the required quantum of housing growth in the Borough based on the current flawed approach to the allocation of sites for new housing. • Failure to effectively deliver housing growth in the most appropriate broad location; • Failure to comply with relevant strategic policy requirements, including the requirements of PPS3 and the East of England Plan.

In response to the unsoundness of the approach that has been taken to date, the main changes that should be made to the Core Strategy are:

Overall, it is considered that the broad location to the north of Daws Heath Road should be identified in the Core Strategy for new residential development. As has been previously acknowledged by CPBC officers, the development of the broad location should play an important part in ensuring that the provisions of the Core Strategy are both effective and consistent with the overall strategic policy context within which the Core Strategy sits. 78 Policy SS 2 Elaine De Can U E The Town Council representation on the Core Strategy outlines the flaws which make the document E Local Town Council for an area where Policies CP1 through to CP4 are very clear about the delivery of Distribution of Canvey Town unsound: development is proposed. infrastructure and the timescales associated with this. Many of the Sustainable Council community infrastructure projects on Canvey are already in a phase of Development and delivery. The Core Strategy has therefore given clear consideration to the Growth 2008 - 2026 • Lack of consideration of infrastructure prior to any development taking place delivery of infrastructure to support development. • Development on Green Belt is not justified as Canvey lies on a flood plain • There should be an emergency flood plan in place for the whole of Canvey Island before With regard to development in the Green Belt, the Core Strategy is any development takes place supported by a SHLAA, which has identified that there is insufficient capacity in the Urban Area to accommodate housing requirements. As a

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result, a limited amount of development needs to be located in the Green Belt. Consultation with the public indicated that there is strong objection to Green Belt development across the Borough, and therefore sites that are a) Sustainable and b) do not harm the strategic function of the Green Belt have been identified.

With regard to flood risk, the distribution of development identified in the Core Strategy has been subject to a sequential test in accordance with PPS25. This assessment found that the Core Strategy is sequentially appropriate.

There are emergency procedures in place for Canvey Island as required by legislation, however it is considered that a plan, currently under preparation, would provide greater clarity to residents as to what these procedures are and what they should do in the event of an emergency. The Emergency Planners are working with the Environment Agency to develop this plan to include community refuges within the Flood Risk Zone in new community buildings.

The Core Strategy is therefore considered to be robust and effective with regard to the issues raised in this representation. 86 Policy SS 2 Mr Richard Inman U E The aspirations for spatial distribution of development are explained clearly in SS2 and illustrated on W Minor Amendment to wording in policy SS2 to clarify point. Distribution of GO-East the Key Diagram. It may be difficult, for a member of the public without local knowledge, to identify Sustainable the location of Castle View School and Manor Trading Estate. You might consider adding Development and appropriate markers to the diagram. Growth 2008 - 2026 You should be clear, if it is your intention, that you will use the subsequent Area Action Plans for Canvey Island and Benfleet, Thundersley and Hadleigh to allocate sites for development. The use of the phrase "beyond those areas specifically" might be interpreted as reliance on windfalls to deliver a significant proportion of planned development 113 Policy SS 2 Mr Kenneth John U J The roads in the Thundersley area, Rayleigh road, Hart road, Kiln road are already very busy and W Policy CP3 seeks improvements to infrastructure to relieve current Distribution of Reeve have been close to gridlock when affected by accidents or road works in the vicinity. Caused in the congestion issues, to accommodate growth and to improve choice of Sustainable main by people attempting to find a free road not affected. transport mode. The Core Strategy therefore addresses the issues Development and identified in this representation and is therefore effective. Growth 2008 - 2026 120 Policy SS 2 Mr Thomas Charter U J Stop building houses on Canvey Island now and keep off our green belt land what is left of it. W I don't find it necessary because I did not get a As a result of consultation, the Council has identified that residents in all Distribution of degree in Core strategy, or a degree in kidology. areas in Castle Point are concerned about development in the Green Belt. Sustainable Therefore, the Council has sought to limit the amount of Green Belt Also, keep out non resident Councillors from voting, that Canvey Island has to have more houses Development and development proposed in the Core Strategy, and identify a) the most because they will only say yes, because it is just a case of NIMBY, like a Giant housing estate every Growth 2008 - 2026 sustainable locations, and b) the locations that will have the least impact on year it is getting bigger thanks to Castle Point. the strategic functions of the Green Belt. The Core Strategy is therefore considered sound with regard to the distribution of development proposed.

With regard to the democratic process, the decision to submit the Core Strategy to the Secretary of State for examination was made by Full Council in accordance with statutory regulations. 131 Policy SS 2 Mr ROY WARREN U J Also effective and consistent with national policy. W The representation misunderstands how any redevelopment of the Castle Distribution of Sport England View School site may be taken forward. Sustainable (East) Sport England strongly objects to the proposal to redevelop the existing Castle View School site to Development and provide educational facilities, a children's play area and up to 50 homes in the period beyond 2021. A current planning application seeks approval for a new skills campus on Growth 2008 - 2026 Redeveloping the site would result in the loss of the school's playing fields (which are large enough land currently used as hard surface play space and car parking. It is to accommodate the equivalent of about three winter playing pitches) plus the loss of the school's intended to link to the existing sports hall and gymnasium which will sports hall and gymnasium which are understood to be recently built facilities that are used by the remain. It is also intended to use the existing sports fields in connection community outside of school hours. There are no proposals to replace the playing fields and it is with this new development. unclear whether the sports hall and gymnasium would be retained on the site as part of a vocational college or whether they would be fully replaced as part of the school's relocation to the existing Redevelopment of existing school buildings will take place once the new Furtherwick Park School site. The loss of the school site to development is therefore objected to for Castle View School has opened at Furtherwick Park. It is that footprint of the following reasons: existing school buildings which would be used to accommodate approximately 50 new dwellings. • Even if the school's sports facilities would no longer be required by Castle View School for school use following their relocation, they would offer potential for meeting the needs of the local community on Canvey Island. School sports facilities play a major role in meeting community sports facility needs as they complement dedicated community sports centres/playing fields by providing additional facilities that are available for use outside of school hours. Without these dual use facilities, many areas would either have no or insufficient access to local sports facilities. Furthermore, it is understood that Castle View School's sports facilities are currently used by the local community outside of school hours. The school's playing fields for instance are used by two community football clubs

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(Mornington Boys and Simco Asbestco) and Canvey Island Cricket Club (indoor and outdoor nets). If these facilities are closed and developed, existing community use would therefore be displaced and it is unclear how the facility needs of clubs, groups etc that use these facilities would then be met. The Football Association and the England & Wales Cricket Board have advised that the clubs would be very concerned about losing access to facilities at the Castle View School site; • No replacement provision is proposed for the playing fields and other sports facilities. Consequently, there would not appear to be any compensatory provision proposed. The playing fields at the new Castle View School site (at the Furtherwick Park School) would not represent acceptable replacement provision as they are already existing playing fields and there would be a net loss of playing field provision. The same would apply to indoor sports facilities unless new indoor sports facility provision was made as part of the redevelopment of Furtherwick Park School that would not result in a net loss of indoor sports facility provision across the two school sites; • There is no up-to-date evidence base available that, in Sport England's view, would justify the school playing fields being released for development on the basis of them being surplus to community needs. The Council's PPG17 Open Spaces Appraisal (2006) did not include an adequate playing pitch assessment which would have robustly identified quantitative playing fields needs in accordance with the guidance in PPG17 or Sport England's guidance on playing pitch assessments (Towards a Level Playing Field, 2003). For example, the methodology used to prepare the Open Spaces Appraisal does not identify quantitative deficiencies (or the distribution of deficiencies within the district) based on an up-to-date and comprehensive assessment of needs in accordance with PPG17 guidance and did not assess latent demand and future demand for facilities in detail. It was recommended in the Council's Open Spaces Appraisal (paragraph 6.4.42) that a playing pitch strategy should be undertaken to develop a better understanding of facility distribution within the Borough and (in paragraph 7.13) that a playing pitch strategy would better inform demand and supply levels and this should be undertaken to inform policy. This has not been undertaken; • The Council's Leisure Strategy did not include a detailed assessment of indoor sports facility provision that demonstrates that the loss of the site's indoor sports facilities could be justified i.e. to demonstrate whether there was a clear surplus of indoor sports facility provision in the Borough. The Essex Sports Facilities Strategy (2008), which was prepared by Sport Essex (the county sports partnership) in association with Castle Point Borough Council (and all of the other local authorities in Essex) after the Leisure Strategy was prepared identified that there would be a demand for 25.51 sports hall courts in the Borough by 2020 (accounting for natural and housing-led population growth) and that at present while there are 28 courts in the Borough, only 10 are fully accessible to the community. Consequently, there is considered to be a quantitative shortfall of sports hall provision which is fully accessible to the community which may be exacerbated by the loss of the school's sports facilities.

In view of the above, Sport England considers that the proposals for allocating this site for development would clearly fail the tests of soundness for the following reasons:

Justified:

• The evidence base to support development on this site resulting in the loss of playing fields and indoor sports facilities is inadequate as set out above; • No consultation appears to have been undertaken with community sports users of the Castle View School or the relevant sports governing bodies that represent the clubs or Sport England as a statutory consultee on planning applications affecting playing fields; • No alternatives sites have been proposed for replacing the sports facilities affected. • The proposal is inconsistent with other policies in the Core Strategy. Policy CP1 (Delivering Community Infrastructure) protects community infrastructure from development for non-community use unless it is part of a programme of strategic infrastructure replacement. Developing a large part of the site for housing would be clearly contrary to this policy and there are no proposals for replacing the sports facility infrastructure affected. More specifically, Policy DC16 states that Council will protect all existing outdoor sports fields from development unless criteria which are not applicable to this proposal are met. Policy DC16 does not provide a basis for exceptions such as that proposed on the Castle View School site.

Effective

• There are significant regulatory barriers to delivery. The Council will be aware of Sport England's role as a statutory consultee on planning applications affecting playing fields. If this site was allocated for development in the core strategy without satisfactory replacement playing field provision being Sport England would have to object to a future

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planning application as a statutory consultee. Due to the weight that should be applied to objections made by statutory consultees and the need to refer planning applications to the Secretary of State (through the provisions of the Town and Country Planning (Consultation) (England) Direction 2009) that Sport England objects to, there would be potential for significant uncertainty and delays in the delivery of a development on this site

National Policy

• The proposal clearly fails to accord with the guidance in PPG17 on development affecting playing fields and other sports facilities (paragraphs 10-15). In particular, in the absence of a robust assessment of needs, none of the criteria relating to development on playing fields would be met by this proposal. The lack of an adequate evidence base on sports facility needs as set out above would also not accord with paragraphs 1-5 of PPG17; • The proposal not accord with Sport England's established playing fields policy, (‘A Sporting Future for the Playing Fields of England' (1997) which can be downloaded from our website at www.sportengland.org/facilities__planning/putting_policy_into_practice/playing_fields.aspx . This policy is consistent with PPG17 and is used by Sport England for assessing planning applications affecting playing fields as a statutory consultee.

I would advise that I have consulted the sports stakeholder group that has been set up by Essex County Council to inform the Building Schools for the Future programme on Canvey Island. The group is made up of representatives of all the local school and community sport stakeholders. The group has advised that they were not aware of proposals to dispose of Castle View School's playing fields and other sports facilities and that their current position would be to object to the loss of these facilities. The Football Association and England & Wales Cricket Board have also confirmed their objection to this proposal.

To address this objection, it is requested that either the playing field and other sports facilities that are currently in community use are removed from a development allocation, or a related site allocation is made in the DPD for satisfactorily replacing the sports facilities that would be lost or if can be clearly demonstrated to Sport England's satisfaction that the site is surplus to local needs through the preparation of a satisfactory playing pitch assessment and indoor sports facility assessment. I would advise that I would have no objection in principle to the school's buildings (excluding indoor sports facilities) being redeveloped for a vocational college or housing unless this would prejudice the use of or access to the sports facilities. 152 Policy SS 2 Mr D. A. Head S J E As a local resident who has vigorously No response required. Distribution of campaigned for nearly two years to remove the Sustainable land north of Daws Heath Road from the Core Development and Strategy I wish to attend the examination in Growth 2008 - 2026 public to enquire;

1. That the views and wishes of the local residents and Councillors are upheld by ensuring the land north of Daws Heath Road remains Greenbelt.

2. To defend the above land from developers trying to override residents wishes for their own commercial ends.

3. That the due process of proposals, consultations , negotiations and Council voting over the past two years are upheld and not put asunder by commercial interests. 153 Policy SS 2 Mr David Lawrenson Fiona Jury U J The proposed distribution of employment and housing growth alongside community improvements is E This matter is considered to be of importance to With regard to employment land provision on Canvey Island, the contention Distribution of Argent Homes unjustified. The locations identified at Canvey Island, do not represent the most sustainable options my client who owns strategic housing land in the that there is significant areas of empty floorspace is not evidenced. The Sustainable Limited available in the Borough. Whilst there is a need for a Regeneration Framework for Canvey in order Borough. They are concerned that the Council's Council is of the view that the existing employment area is largely

Development and to stimulate private sector investment, the Island already has available substantial amounts of approach does not comply with National policy. occupied. Furthermore, the Employment Study identifies that there is Growth 2008 - 2026 employment floor space that is vacant and without an 'end-user'. The identification of new Participation at the oral examination is higher unemployment and a greater number of economically inactive employment land has not been tested against market conditions and future demand, and therefore requested to enable further discussion on this people who may re-enter employment on Canvey Island compared to the cannot be supported or justified. matter. mainland. As a result, it is consistent with PPS1 and PPG13 to locate employment opportunities close to where people live. The locations for proposed housing growth in Canvey are also at risk. For example, there is difficulty securing landowner approval to secure vehicular access to land to the east of Canvey Road which With regard to the availability of housing land on Canvey Island, the has been identified for up to 400 homes. At Castle View School, funding is unavailable to secure the landowners of East of Canvey Road, West of Canvey Road (Frontage), new vocational centre and proposed housing. The landowner (Essex County Council) has not Castle View School and Point Industrial Estate are all in contact with the committed to the release of the Green Belt land for the proposed new housing of 50 dwellings that is Council with regard to the development of their sites. Plans are at various identified in the Core Strategy. All of the proposed housing sites on Canvey Island are also at risk stages of development, but it is clear that these areas of land are all Page 62 of 222

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from flooding. capable of development during the plan period, policy permitting.

The Implementation Framework that accompanies the Core Strategy identifies the key projects for With regard to the implementation framework, a number of infrastructure achieving the delivery of new homes, jobs and community facilities in Castle Point and the schemes have been pursued since the preparation of the schedule. The funding/timing status of each. This does not support the implementation of Policy SS2 and the funding has now been identified for all but one community infrastructure growth locations on Canvey identified in Table 4 over the Plan period. project on Canvey, and two key highway schemes have received funding. This will support growth on the Island as set out in the Core Strategy. In order to deliver a more sustainable pattern of development and growth in the Plan period, the Core Strategy should provide for a more modest level of housing growth on Canvey Island until the This consultee contends that growth on Canvey cannot be delivered until delivery of SERT or a passenger transport corridor and a new/improved access onto the Island is such time as SERT and a Third Road have been delivered. The County secured. The following broad locations should be removed from the Core Strategy: Point Industrial Highways Authority have advised that there is sufficient capacity in the Estate; land to the east of Canvey Road; land fronting the west of Canvey Road; and Castle View existing road network on Canvey Island to accommodate the level of School. growth identified for the Island. Therefore the delivery of this infrastructure before growth is not necessary. The proposed Spatial Strategy already endorses the part redevelopment of Manor Trading Estate, and in doing so, accepts that it is a sustainable location for new housing growth. The proposed The consultee seeks the Core Strategy to be revised to delete capacity for Manor Trading Estate should be increased from 200 homes to 1,000 new homes based development on Canvey, and to include the redevelopment of Manor on the relocation of the existing trading estate to the north-west of Benfleet which could provide a Trading Estate for 1,000 homes, with employment relocated to the new employment growth area. In addition, land at 396- 406 and 408 London Road should be A130/A127 junction. The Council does not consider this option to be identified as a broad location for accommodating 50 and 30 new homes respectively in order to meet sustainable, as the proposed employment location has no relationship with any shortfall in the housing requirement. These sites comprise part previously developed land, adjoin the existing settlements of the Borough, and would require employees to an existing community hub and are within a highly accessible location, outside of the flood plain travel further and probably by private vehicle to access the site (limited unlike Canvey Island. public transport serving this location). The County Highways Authority have sustained an objection to this proposal due to its impact on the Strategic road network).

Furthermore, this land fulfils a strategic green belt function by separating Thundersley from settlements in Rayleigh and Basildon. Consultation has revealed that residents in Castle Point are concerned about development in the Green Belt, and the location and quantum of development set out in this proposal is such that this would be contrary to local concerns.

The consultee also supports the inclusion of 396 to 408 London Road as a development location. This site sits within a narrow strip of Green Belt between Benfleet and Thundersley. The intensification of development on this site would therefore impact on the strategic function of the Green Belt. The Council was previously supported on this view by the Planning Inspectorate on appeal.

The Core Strategy is therefore considered to be sound in terms of the distribution of development proposed in policy SS2, with regard to the issues raised in this consultation response. 160 Policy SS 2 Mr Ray Dove Fiona Jury U J The proposed distribution of employment and housing growth alongside community improvements is E This matter is considered to be of importance to With regard to employment land provision on Canvey Island, the contention Distribution of Manor Regeneration unjustified. The locations identified at Canvey Island, do not represent the most sustainable options my client who owns strategic housing land in the that there is significant areas of empty floorspace is not evidenced. The Sustainable & Development available in the Borough. Whilst there is a need for a Regeneration Framework for Canvey in order Borough. They are concerned that the Council's Council is of the view that the existing employment area is largely

Development and Company Limited to stimulate private sector investment, the Island already has available substantial amounts of approach does not comply with National policy. occupied. Furthermore, the Employment Study identifies that there is Growth 2008 - 2026 employment floor space that is vacant and without an 'end-user'. The identification of new Participation at the oral examination is higher unemployment and a greater number of economically inactive employment land has not been tested against market conditions and future demand, and therefore requested to enable further discussion on this people who may re-enter employment on Canvey Island compared to the cannot be supported or justified. matter. mainland. As a result, it is consistent with PPS1 and PPG13 to locate employment opportunities close to where people live. The locations for proposed housing growth in Canvey are also at risk. For example, there is difficulty securing landowner approval to secure vehicular access to land to the east of Canvey Road which With regard to the availability of housing land on Canvey Island, the has been identified for up to 400 homes. At Castle View School, funding is unavailable to secure the landowners of East of Canvey Road, West of Canvey Road (Frontage), new vocational centre and proposed housing. The landowner (Essex County Council) has not Castle View School and Point Industrial Estate are all in contact with the committed to the release of the Green Belt land for the proposed new housing of 50 dwellings that is Council with regard to the development of their sites. Plans are at various identified in the Core Strategy. All of the proposed housing sites on Canvey Island are also at risk stages of development, but it is clear that these areas of land are all from flooding. capable of development during the plan period, policy permitting.

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School. before growth is not necessary.

The proposed Spatial Strategy already endorses the part redevelopment of Manor Trading Estate, The consultee seeks the Core Strategy to be revised to delete and in doing so, accepts that it is a sustainable location for new housing growth. The proposed development on Canvey, and to include the redevelopment of Manor capacity for Manor Trading Estate should be increased from 200 homes to 1,000 new homes based Trading Estate for 1,000 homes, with employment relocated to the on the relocation of the existing trading estate to the north-west of Benfleet which could provide a A130/A127 junction. The Council does not consider this option to be new employment growth area. In addition, land at 396- 406 and 408 London Road should be sustainable, as the proposed employment location has no relationship with identified as a broad location for accommodating 50 and 30 new homes respectively in order to meet the existing settlements of the Borough, and would require employees to any shortfall in the housing requirement. These sites comprise part previously developed land, adjoin travel further and probably by private vehicle to access the site (limited an existing community hub and are within a highly accessible location, outside of the flood plain public transport serving this location). The County Highways Authority have unlike Canvey Island. sustained an objection to this proposal due to its impact on the Strategic road network).

The Core Strategy is therefore considered to be sound in terms of the distribution of development proposed in policy SS2, with regard to the issues raised in this consultation response. 172 Policy SS 2 Ms NATALIE S Castle Point is located within the Thames Gateway South Essex (TGSE) and is defined as an No response required. Distribution of BLAKEN Engine of Growth within the RES. As such the urban areas of the TGSE and their hinterlands are Sustainable EEDA expected to disproportionately drive growth, given the importance of agglomeration and the Development and concentration of assets. EEDA continue to support the Core Strategy in its recognition of the Growth 2008 - 2026 importance of the urban areas and that Canvey Island, Benfleet, Hadleigh and Thundersley are all identified as locations for employment growth. 198 Policy SS 2 Mr David R Gibson S E As a local resident who has vigorously No response required. Distribution of campaigned for nearly two years to remove the Sustainable land north of Daws Heath Road from the Core Development and Strategy I wish to attend the examination in Growth 2008 - 2026 public to enquire;

1. That the views and wishes of the local residents and Councillors are upheld by ensuring the land north of Daws Heath Road remains Greenbelt.

2. To defend the above land from developers trying to override residents wishes for their own commercial ends.

3. That the due process of proposals, consultations , negotiations and Council voting over the past two years are upheld and not put asunder by commercial interests. 201 Policy SS 2 Miss Carrie Williams U J We feel that the Core Strategy is not sound because it is not justified. The accompanying W We would prefer written representations, but will The Council note that the Environment Agency is generally supportive of Distribution of The Environment Sustainability Appraisal clearly identifies that a preferred site to the East of Rayleigh Road has been happily attend the EiP at the Inspector's (or the findings of the sequential test undertaken in accordance with PPS25. Sustainable Agency omitted from policy SS2, even though it scores positively on the sustainability indicators and it is Council's) request. The Environment Agency were consulted throughout the preparation of this Development and identified as an area suitable for residential development in an area outside of the risk of fluvial or assessment. Growth 2008 - 2026 tidal flooding in the accompanying PPS25 Sequential Test document. In addition to this one site, a number of other sites have also been identified in these two supporting documents as being in an Nonetheless a query is raised as to the justification of proposing area of Flood Zone 1 and scoring positively on the sustainability indicators. The reasons for their development in the Green Belt. The SHLAA demonstrates that there is omission from policy SS2 have not been included. We therefore cannot be certain that policy SS2 insufficient capacity in the urban area to accommodate the housing represents the most appropriate policy because there is no clear comparison against alternatives. requirements for Castle Point. The Green Belt boundaries are tightly drawn around the urban area in Castle Point, and therefore there is a need to In order to make this document sound, an exploration of the reasonable alternatives for housing accommodate a proportion of the housing requirement in the Green Belt in should be included to ensure the flexibility of the housing supply in the borough. The reason for the order to meet housing needs. In order to remain in conformity with PPG2, it omission of any sustainable sites should be included to justify the Council's position. is important to ensure that the sites identified for development do not fulfil a strategic Green Belt function. It is considered by the Council that the sites identified in the Core Strategy for Housing Growth in the Green Belt do not Page 64 of 222

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Furthermore, we do not believe that the Core Strategy is supported by sufficient evidence to justify fulfil a strategic Green Belt function. the underlying assumption that protecting greenbelt land should take preference to avoiding vulnerable development in areas within Flood Zone 3, the high risk flood zone, which would pose The Council believes that land to the East of Rayleigh Road, whilst being a risks to life and property. This is especially true where those proposed sites score positively on the potentially sustainable development location, does fulfil a strategic Green sustainability criteria and have been assessed as being reasonably available for residential Belt function, and therefore this site is not considered by the Council to be development whilst the function of the greenbelt areas have been assessed as reduced. The general a suitable development location. Thus, whilst the site may be sequentially approach of giving priority to brownfield land is in line with national policy within PPS3, however preferable to development locations on Canvey in terms of sustainability PPS3 also recognises the need to take into account environmental constraints and risks, including and flood risk, the site remains in the Green Belt due to its strategic flood risk, in setting out strategies for the planned location of new housing in order to achieve function and is not therefore available for development. sustainable development objectives set out in Planning Policy Statement 1 and that some sites might not therefore be suitable for housing (see paragraphs 38 and 41). This ties in with the process of applying the PPS25 Sequential Test and Exception Test which places flood risk classification and The Environment Agency also query the decision to include brownfield the vulnerability of proposed developments as the primary concern, with the designation of land as sites within the urban area on Canvey in preference to Green Belt sites on brownfield as a secondary consideration when applying part b of the Exception Test. Given that the mainland in Flood Risk Zone 1. There are four main reasons for this: paragraph 5.19 of the Core Strategy states that there is a need for housing capacity within the greenbelt, which is contrary to the guidance contained within Planning Policy Guidance note 2, there 1) There is a need for regeneration on Canvey Island to improve the vitality is no justification to support the assumption that developing the brownfield land in the high risk flood zone is the most appropriate course of action given the reasonable alternative of accommodating of the town centre, the seafront and improve the quality of the built environment; those housing figures in areas at lesser flood risk - either by releasing an minimal additional amount of greenbelt, or by slightly increasing density of development elsewhere. 2) There is a housing need on Canvey Island arising from the existing population. Canvey has a distinct identity and community and therefore it is It should be noted that we generally support the conclusions of the PPS25 Sequential Test necessary to try and meet the needs of Canvey's population on Canvey; document that supports this Core Strategy in stating that development is required on Canvey Island and that this approach can be justified. Site Specific Allocations made in other DPDs will need to be supported by a more detailed Sequential Test to ensure compliance with PPS25. 3) Consultation with residents has revealed that there is a strong resistance to Greenfield/Green Belt development throughout the Borough. It is therefore the Council's objective to minimise the amount of development located within the Green Belt within the Core Strategy; and;

4) The Greenfield Sites identified to the Council by landowners on the mainland fulfil the Green Belt functions identified in PPG2, and therefore their development would be contrary to national policy.

As a result, the Council believes that the distribution of development identified in the Spatial Strategy has taken into full consideration the issues of flood risk and balanced them accordingly with the issues of Green Belt. The Core Strategy is therefore considered to be sound with regard to the issues raised by this consultee. 202 Policy SS 2 Miss Carrie Williams U E We feel that the Core Strategy is not sound because it is not effective. Should any of the Flood Zone W We would prefer written representations, but will The Council note that the Environment Agency is generally supportive of Distribution of The Environment 3 sites be found to be undevelopable, the Core Strategy does not explore alternatives to happily attend the EiP at the Inspector's (or the findings of the sequential test undertaken in accordance with PPS25. Sustainable Agency accommodate their required growth targets. We therefore cannot be certain that policy SS2 is Council's) request. The Environment Agency were consulted throughout the preparation of this Development and flexible enough to respond to changing circumstances. The accompanying PPS25 Sequential Test assessment. Growth 2008 - 2026 and Sustainability Appraisal identify a number of other sites located in areas outside of the tidal and fluvial flood zones that have not been included in this policy and no justification for their omission is Nonetheless a query is raised as to deliverability of the plan as a result of provided. the potential for development locations in Flood Risk Zone 3 becoming undeliverable. The Council is confident that landowners are willing to deliver their development proposals, and therefore from the perspective of this consultee, the issue of flood risk management is a concern. Policy CP5 sets out how the Council will deal with flood risk management as part of In order to make this document sound, an exploration of the reasonable alternatives for housing development proposals. This has been further enhanced as a result of this should be included to ensure the flexibility of the housing supply in the borough. The reason for the consultation to include reference to community refuges. The Council is omission of any sustainable sites should be included to justify the Council's position. therefore confident that with additional work with emergency planners that the development locations on Canvey Island are deliverable in terms of flood risk management. Furthermore, the Core Strategy contains flexibility in terms of the total housing supply planned for.

Reasonable alternatives were given consideration during earlier rounds of consultation on the Core Strategy. It is not therefore necessary to include a discussion of these in the final document.

As a result, the Council believes that the distribution of development identified in the Spatial Strategy can be delivered. The Core Strategy is therefore considered to be sound with regard to the issues raised by this consultee. 205 Policy SS 2 Goldencircle Ltd Mr Haydn Payne S J E In order to fully participate with any debate that No response required. Distribution of Alliance Planning is held in relation to the identification of the site Sustainable East of Canvey Road for a housing led scheme Development and and its release form the Green Belt. Growth 2008 - 2026

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223 Policy SS 2 Petroplus Refining Miss Sally Fordham U E Petroplus would like to object to Policy SS2 on the grounds of both employment and housing. E We believe it is necessary to attend the oral part The Petroplus Oil Refinery is located in Coryton in the Borough of Distribution of and Marketing Drivers Jonus of the examination as the Coryton Oil Refinery Thurrock. The consultation zone around this hazardous installation does Sustainable Limited (Petroplus) complex plays the role of an international, however extend into Castle Point. However, none of the development Employment Growth and Regeneration Development and national and regional gateway. Petroplus wishes locations identified in the Core Strategy sit within this consultation zone, Growth 2008 - 2026 for this role to be explicitly recognised and and as such the HSE PADHI System does not result in an objection to the Policy SS2, and more specifically Table 4 of the Core Strategy sets out the Spatial Distribution of explicitly protected in the Castle Point Core Core Strategy. The HSE have been consulted directly on the Core Strategy Regeneration and Growth in the Borough. The Employment Growth and Regeneration Section Strategy. and have not issued an objection. As a result, the distribution of states the following: development is considered sound with regard to the proximity of proposed development locations to hazardous installations. "South West Canvey will become a key economic centre with enhanced employment opportunities through the regeneration of the existing Charfleets Industrial Estate and adjacent delivery of a further With regard to Green Belt, the SHLAA demonstrates that there is 18ha of land for business uses" (p.28). insufficient capacity in the urban area to accommodate the housing requirement for the Borough. The Green Belt is tightly drawn around the urban area in Castle Point and therefore it is necessary to accommodate Petroplus have made it clear in previous Core Strategy consultations that they would object strongly some of the housing requirement in the green belt to meet the housing to employment allocations on Northwick Road. The designation of employment uses at Northwick needs of the Borough. the use of the Green Belt for housing provision is Road would constrain both the operation and future expansion of the Coryton Oil Refinery Complex. therefore justified. For this reason, our client believes that the Core Strategy is not ‘Effective' according to the Tests of Soundness outlined in PPS12. For a Core Strategy to be Sound, it must be deliverable. Petroplus are of the opinion that siting further land for business uses at Charfleets Industrial Estate will With regard to development in Flood Risk Zone 3, the Core Strategy is constrain the growth of the Oil Refinery Complex which is the only facility of its kind in the East of supported by a sequential test prepared in accordance with PPS25. The England. This could have negative repercussions on Coryton Oil Refinery remaining an international, assessment found that the distribution of development in the Core Strategy national and regional gateway. was sequentially appropriate.

Housing Growth and Community Development

Table 4 notes that on Canvey Island, land to the East of Canvey Road will be developed to provide a community. It is also noted that previously developed land fronting the west of Canvey Road will be redeveloped for 50 units of specialist housing provision for older people in the period beyond 2021. The Castle Point ‘Key Diagram' and Site Proposals section demonstrates that these sites lie partly in the Green Belt, and both are in Flood Plain areas (Zone 3).

As previously stated in other rounds of consultation, Petroplus would strongly object to any intensification of development to both the east and west of Canvey Road as it would prejudice or fetter the operations or further expansion of Coryton Oil Refinery Complex. It is particularly bad planning to propose a new housing development close to a major petrochemical complex and on Green Belt land and in a Flood zone.

In our previous objection letter, we drew attention to proposals in the early 1990s for major development to the east of the Coryton Refinery Complex on Canvey Island; proposals known as Northwick Village. The Inspector‘s conclusions to that Inquiry were clear. The Inspector stated that "nothing should be done which would constrain the operations or future expansion of the Coryton oil refinery." The Secretary of State, in refusing planning permission, agreed with the Inspector "that because of their national and local importance nothing should be done to unnecessarily constrain the operations or future expansion of the Mobil refinery" [now known as Coryton Oil Refinery Complex]. The Secretary of State, in dismissing the development in the vicinity of the refinery, accepted that it is a "matter of commonsense not to increase the number of people living close to a refinery".

Petroplus believes that the Core Strategy is not ‘Effective' according to the Tests of Soundness outlined in PPS12. A Core Strategy document must be Sound to be deliverable. Petroplus are of the opinion that developing Green Belt land at risk of flooding is bad planning, and an ineffective strategy to adopt. 228 Policy SS 2 Mr Bruce Paterson U J Section 5.18 Policy No. SS1 Table 4 E In every planning application I have proposed to 396 to 408 London Road was assessed against the Sustainability Criteria Distribution of C.P.B.C. in relation to this site, all but 2 have set out in the Sustainability Assessment of Sites on the Urban Periphery Sustainable been refused on the grounds the land lies within (2008). This found the site to be relatively unsustainable. Following a Section 5.19 Policy No. SS1 Table 4 Development and the green belt. In 25 years of owning this site revision of the methodology to weight some criteria more important than Growth 2008 - 2026 this is the first opportunity I would have of others (based on public consultation results), the site scored relatively The criteria applied to this policies SS1 & SS2 are totally, unsound, unjust and unfair, and appealing my case before an Inspector. Who better in terms of sustainability. inconsistent with the criteria set. In particular this council has chosen green belt sites that are against would have the authority to exclude this land the public interest to be developed. Whilst they have ignored more suitable sites that have no public from within the green belt. However, the site is located in the Metropolitan Green Belt in a location that objection, I would like to draw the inspectors attention to 2 sites in particular being the land East of is important for preventing urban sprawl and the coalescence of place. The Rayleigh Road, Benfleet (Appendix C 1), which has had nothing but public protests and yet my own This is extremely important as if I am refused landowner has made several applications for the redevelopment of this site at 396 London Road, Benfleet (appendix C 36) which has a petition of over 1500 signatures in this opportunity to put my case before the site, and for its further use for Car Sales. These applications have been favour of development has been overlooked. inspector it could be a further 25 years before refused on Green Belt terms and where appealed the Planning Inspector another opportunity arises. has supported the Council's position that the Green Belt in this location is The unsound criteria applied to al 28 chosen sites is inconsistent, unjust and in most cases totally of strategic importance (App: CPT/553/98/FUL/VAR/C). The site is biased. And as such I wish to appeal the inclusion of the land at 396 London Road, Benfleet, being currently subject of enforcement action for failure to recognise the kept within the Green Belt. decisions of these previous applications.

It is recognised that there are objections to other sites in the Green Belt. Page 66 of 222

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However, it is considered that whilst this site does not look pretty, it is in the Green Belt and does perform a strategic function. As a result, the Council is of the view that the exclusion of this site from the Core Strategy is justified and consistent with national policy. 233 Policy SS 2 Mr T Warren U J We should not have 400 new homes built on Canvey as the roads will not take the extra traffic. It is W The County Highways Authority has not objected to the proposed Distribution of hard enough now with a build up of traffic in the last few years, with only two roads on and off the development locations on Canvey Island as they consider that there is Sustainable Island. adequate capacity in the existing road network, with some minor Development and infrastructure improvements, to accommodate the growth proposed in the Growth 2008 - 2026 Core Strategy. The Core Strategy is therefore considered justified in the The other thing is the building on the green belt, we will not have any green belt left at this rate! distribution of development proposed.

236 Policy SS 2 Mrs Zena Wiser S J I am the owner of a plot of land (identified on the attached map) which is approximately 55ft wide x W None necessary - site allocation request which will be dealt with when Distribution of 120ft deep that fronts Canvey Road between the Garden Centre (known as 'Garden World') and the defining exact site area in Canvey Area Action Plan. Sustainable Scrap Yard next door to the north of the property known as 'Theohall' Development and Growth 2008 - 2026 This section was recommended for development some years ago long before the local plan process because the then head of planning and his planning team recommended this frontage should be designated as land for development as it does not serve a Green Belt function.

As with the Garden Centre, which is recognised as a prime Brown Field site, and in between that and the Scrap Yard to the north are the properties 'Theohall', 'Russel House', 'Hill Hall', 'The Dutch Cottage', 'Homestead' and 'Raydele House'.

My plot of land fronts up to a made up adopted highway with all statutory services, such as Foul Sewerage, Surface Water Drainage, Gas, Electric, Mains Water supply and Telephone connection.

This whole frontage, from the Scrap Yard to the North to the Garden Centre to the South, is not designated SS1 land.

I was recently married and would like to start a family, but this is very difficult as I currently live in a small 1 bedroom bungalow and do not have funding to purchase a larger property.

Would you please give this matter your urgent attention to be considered as the Final Consultation Document and recommend my request to the Inspector. 237 Policy SS 2 Mr David Howard S J I am the owner of a property known as ‘Homestead' (identifies on the attached map) that fronts W None necessary - site allocation request which will be dealt with when Distribution of Canvey Road between the Garden Centre (known as ‘Garden World') and the scrap Yard next door defining exact site area in Canvey Area Action Plan. Sustainable to the north of the property known as ‘Theohall'. Development and Growth 2008 - 2026 This section was recommended for development some years ago long before the local plan process because the then head of planning and his planning tram recommended this frontage should be designated as land for development as it does not serve a Green Belt function.

As with the Garden Centre, which is recognised as a prime Brown Field site, in between that and the Crap Yard to the north are the properties ‘Theohall' ‘Russel' House', ‘Hill Hall', ‘The Dutch Cottage', ‘Homestead' and ‘Raydele House'.

My property ‘Homestead', fronts up to a made up adopted highway with all statutory services, such as Foul Sewerage, Surface Water Drainage, Gas, Electric, Mains Water supply and Telephone Connection.

This whole frontage, from the Scrap Yard to the North to the Garden Centre to the South, is not designated SSSI land.

‘Homestead' was built in the 1930's and is in need of redevelopment. The property is not large enough for my family requirements, but under the current planning rules I am unable to build a larger property on this plot. I believe the redevelopment of this site would enhance the area considerably.

I would, therefore, formally ask that you take this matter into consideration under the Final Consultation Document and recommend my request to the Inspector. 248 Policy SS 2 Simon Dodd U J We support the contention that the redevelopment of the frontage for 200 homes should be removed W The redevelopment of the frontage to Church Road for residential purposes Distribution of European Metal from the Core Strategy. We agree with the statement that it is not deliverable and it also would is not dependent upon the relocation of the European Metal and Recycling Sustainable Recycling Limited threaten other policy objectives and particularly waste. facility. The redevelopment of this frontage would substantially improve the Development and amenity of this part of Thundersley. The council does not accept that it is Growth 2008 - 2026 reasonable for the recycling operator to seek to obstruct the achievement The Benfleet scrap site (which we own) is a major waste recycling site in the Borough and the of the redevelopment of the Church Road frontage for residential Page 67 of 222

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encroachment of housing towards the site could threaten its long term operation. purposes.

Our site occupies approximately 2.2 acres and processes in excess of 100000 tonnes of ferrous and The relocation of the metals recycling facility is a longer term opportunity. non ferrous scrap per annum. The council recognises that there are benefits to recycling from the existing facility and that this may be dependent upon the identification of an alternative site for the recycling operations. There is significant capital sums invested in the site(some millions of pounds ) with a significant depth of concrete across the yard together with drainage and interceptors, the instillation of a large sheer and significant power supply, end of live vehicle processing building and equipment, weighbridges and a non ferrous building.

Any proposal to move the operation would need to offer similar facilities together with the full reimbursement of any disturbance costs. 255 Policy SS 2 WM Morrisons Cara Ware U E Subject to the matter highlighted below, Morrisons supports the regeneration of Hadleigh W With regard to the potential conflict between residential amenity and retail Distribution of Supermarket Plc Peacock and Smith Town Centre to improve environmental quality, and to increase the provision of a broad mix operation, it is recognised that it is not possible to locate residential Sustainable of retail, leisure and community services. The Company considers, however, that delivering accommodation above all retail units. However, there are examples of Development and the provision of 500 new homes in Hadleigh Town Centre should be subject to the same residential development above supermarket provision across the Country Growth 2008 - 2026 qualifications as set out above in relation to residential amenity and retail operational and therefore consideration needs to be given to supermarket designs that viability. are more reflective of urban locations, rather than edge of town locations.

The Council is also concerned about substantial areas of surface carparking in the town centre and believe that the parking to accompany supermarket provision could occupy upper levels, if residential development is unsuitable. Their are local examples of such carparking provision at the Sainsbury's, Rayleigh Weir and Somerfield, London Road, Leigh-on-Sea.

The Council is confident that the concerns of this consultee can be reasonably addressed without change to the Core Strategy. 263 Policy SS 2 Ms KATHARINE U J The 2012 Olympic Mountain Biking Event is a new proposal since the last consultation on the Core W With regard to the Olympic Mountain Biking proposal, this was previously Distribution of FLETCHER Strategy. We have not found reference to it in the Sustainability Appraisal and it is important that included in the Proposed Publication Document in table 4, table 5 and Sustainable ENGLISH there should be no significant environmental effects. In relation to cultural heritage, we would policy CP2. Therefore, this consultee had the opportunity to raise this issue Development and HERITAGE recommend that safeguards are added to the policy. previously. It is noted that the Sustainability Appraisal does not highlight Growth 2008 - 2026 the potential conflict between the Olympic Mountain Bike proposal and the historic environment, however the Council is aware that ECC have been

working with English Heritage regarding this issue, and that these conflicts will be addressed in the site specific Environmental Statement, and through We note the site ‘East of Canvey Road' is identified for 400 houses and community and leisure the planning application. These are running ahead of the Core Strategy in facilities. This site may affect the site and setting of a scheduled monument [ref 32424, Roman Salt terms of timescales. Therefore the Core Strategy is considered sound with Works]. This site should only be allocated if adequate information is available to demonstrate no regard to this matter. Nonetheless, it is agreed that policy SS2 could be significant adverse impact on the scheduled monument. made more explicit with regard the historic environment in column 3, row 4 bullet point 2. Recommendations: With regard to the proposals for the East of Canvey Road, the development location is south of the SAM. The landowners intend to transfer the land on Policy SS2, amend Table 4, ‘Sustainable Growth and Environmental Conservation', third column, 2 nd which the SAM is located to the Council as part of a S106 Agreement for bullet, to: ‘Sites of ecological or historic importance will be protected and enhanced...' open space. It is agreed that the Core Strategy is not clear on this point and therefore an amendment is proposed to this bullet point, although this Policy SS2, amend Table 4, ‘Housing Growth and Community Development': to add at end of third is not the amendment proposed by English Heritage, as the dependency is bullet (Land east of Canvey Road) ‘This site is dependant upon the nearby scheduled monument not as strong as English Heritage contend. being safeguarded from adverse impact, in accordance with an approved masterplan'.

283 Policy SS 2 Ms Sinead O S J Southend Borough Council agrees with the general approach to the Spatial Strategy and that W None necessary - transport issues dealt with in transport infrastructure Distribution of Donoghue regeneration areas are the focus for development and growth, with both Canvey and Hadleigh Town policy. Sustainable Southend-on-Sea Centres identified as key locations for change during the plan period. Preferably we would have Development and Borough Council supported the option of development solely within the existing urban area, however given that Castle Growth 2008 - 2026 Point has been unable to identify sufficient land within the existing urban area, we accept that there is a requirement to consider land on the urban periphery for development also. Southend Borough Council presumes that further increasing housing density thresholds in suitable locations within the existing urban area would still not allow Castle Point to meet its housing requirement over the period.

Any development on the urban periphery must be supported in terms of infrastructure (particularly transport) and not compromise the function of the ‘green lungs' and Green Belt land, which provide amenity to the existing residents and buffer the urban areas.

The Council questions also whether it may be worthwhile including text related to the need for new development to encourage modal shift to reduce the need to travel by car and promote other forms of transport including cycling and walking, so that this issue is addressed at the most strategic level.

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295 Policy SS 2 Mr Mr David Williams U J I write on behalf of my client Mr Reeves in response to the current consultation on the above E The site to the south of Essex Way ranked eighth in the sustainability of all Distribution of Strutt and Parker document. Mr Reeves is the owner of the 0.8 hectare site to the south of Essex Way, North Benfleet, the sites on the urban periphery. The sites selected for development in the Sustainable R also known as the land adjacent to the Glyders. The purpose of this response is to summarise and green belt all ranked above this site. The council recognises that this site Development and reiterate the benefits of this site, our concerns with the Core Strategy Document and to briefly has a positive impact on certain of the criteria. If additional housing Growth 2008 - 2026 Reeves consider the Soundness of the Core Strategy document as is appropriate at the Regulation 27 stage. capacity is required from sites included in the assessment then this site may come forward. Strutt and Parker, on behalf of Mr Reeves have been engaged in the Core Strategy Document at each stage of its production. We have emphasised the benefits of the site at each consultation However, underpinning the scoring of all sites is a consistent approach to opportunity and these are as follows: the assessment of all of the impacts in relation to each of the criteria. The council maintains that it is unsound to seek to reassess individual site scores against particular criteria without undertaking a consistent 1. Provision of local affordable housing as required by Policy CP8 in an accessible location; assessment of all sites. The council does not accept that the representation includes any comments that undermine this approach and that 2. Provision of a shared ownership scheme targeted at first time buyers; and consequently the core strategy remains sound.

3. Provision of an extension of the bridleway network to link the public rights of way to the north and south, providing better access to recreational opportunities for local residents.

Previous Involvement in the LDF

Comments were first made in response to the Key Issues and Options document in March 2006 Details of the site were then submitted to the Call For Sites exercise under the reference 13395 in April 2007, followed by a response to the Core Strategy Issues and Options Consultation. In March 2008, the Council invited Strutt and Parker to a meeting with Steve Rogers and Kim Fisher regarding the deliverability and sustainability of the site in question. As a result of the meeting, a Supplementary Report on the sustainability criteria set out in draft policy CP1 of the Core Strategy Preferred Options Report 2007 was submitted.

In August 2008 a response was submitted to the Further Preferred Options consultation which supported the accommodation of the sites listed under option SP1 3 within the Spatial Strategy. This option proposed the allocation of several small urban periphery sites including the land to the south of Essex Way. The option was supported due to the increased flexibility given by the sites in terms of delivery of housing, the dispersed impact on the area and the close proximity of the sites to existing jobs, services and infrastructure in the existing town centres.

More recently a response to the Proposed Publication Document Consultation in March 2009 was made. Since the locations for new development in the Spatial Strategy for the Borough, now contained under policies SS1 and SS2 of the Final Proposed Submission document are unchanged from the previous iteration of the document, these comments still stand in relation to the current consultation. They are as follows:

i ) The balance of housing is skewed away from the mainland. To address this, the sites listed under option SP1 3 of the further preferred options document including the land to the south of Essex Way were supported for inclusion in the spatial strategy.

ii ) The demand for small houses to cater for first time buyers as identified by the Housing PPS3 encourages a site specific approach to allocating the size and type of affordable housing. It has been stated throughout our involvement in the consultation process that the owner of the site to the south of Essex Way aims to provide a scheme targeted at first time buyers. This would address the omission of the approach advocated by PPS3.

iii ) There is an over reliance in the proposed allocations of housing on previously developed The sustainability appraisal shares our concern that increased flexibility in future growth can be provided with more careful consideration of a logical Green Belt boundary. The allocation of a site such as that to the south of Essex Way would provide a more efficient use of land, in a location that is surrounded on three sides by residential land uses and does not contribute to the aims of the Green Belt as set out in PPG2.

Discussion of Representations Document

The current Core Strategy Final Publication Document is accompanied by a discussion document considering previous representations and resulting changes to the Core Strategy. It considers the land to the south of Essex Way specifically. The document highlights that in the revised assessment of sites undertaken by the Council in 2009, the land under Mr Reeves ownership does not score any higher that the preferred locations for development. The discussion document also states that the site is highly visible due to the topography of the land and that development would result in a loss of Green Belt countryside contrary to PPG2. In response to these points:

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The revised assessment has failed to take into account the additional benefits that the site can provide. Under the 10th criterion, which considers the mix of housing types and provision of affordable housing, the aim to provide affordable housing and a scheme for first time buyers has not been taken into account. Under the 4th criterion which considers the provision of community facilities, the proposed extension to the bridleway network which is supported by groups such as the British Horse Society, has not been considered by the assessment.

With regard to the impact on the Green Belt, due to the surrounding residential context of the site and the mature boundary at the eastern edge, the site does not fulfil the five purposes of the Green Belt, set out under PPG2 paragraph 1.5.

In conclusion, based on the above comments, the document is not considered meet the first Test of Soundness. This test considers whether the document is justified or founded on a robust and credible evidence base. The Core Strategy is not justified due to the failure to take into account the benefits of the site to the south of Essex Way in the site assessment process. 297 Policy SS 2 Mr J Howard U J The sustainability scoring for certain sites considered to flawed and wrong. Example is (1) Land East W The Core Strategy was subject to full and thorough consultation with Distribution of of Canvey Road, (2) Garden World west of Canvey Road, and (3) Land West of Canvey Road ‘The residents in January to March 2009. The electoral register was used to Sustainable Triangle' . All three sites within a close area of each other, however sites (1) and (2) come out with ensure that all residents were written to with a summary leaflet and Development and two of the highest scores while site (3) one of the lowest. Those scoring the sites appear to have questionnaire. All respondents to this consultation were written to, Growth 2008 - 2026 failed on the positives for sites (1) and (2) while ignoring negatives by large, while site (3) has its alongside statutory consultees, with regard to the Regulation 27 negatives focused upon, and positives omitted. Finally site (2) sites within site (3), how can the consultation. The regulation 27 consultation was also advertised in the scores be so different and justified? local press, in Viewpoint - the Council Newspaper distributed to all households, and through press releases. The Council is therefore confident that the Consultation on the Core Strategy has been thorough.

With regard to land to the West of Canvey Road, the consultee believes that it is a suitable alternative site to land to the East of Canvey Road. However, the Sustainability Assessment of Sites (Original and Review) found this location to be particularly unsustainable for the following reasons:

The site to the East of Canvey Road does not have these constraints and is therefore considered justified in its inclusion in the Core Strategy. It is not considered justified to include the West of Canvey Road (Triangle) Site in the Core Strategy. 311 Policy SS 2 Thorney Bay Park Mr Russell Forde U N The CSFPD does not satisfactorily accommodate the strategic housing proposals that we advocated E Strategically important site. The Council recognises that Thorney Bay caravan park can continue to Distribution of Smart Planning Ltd in our earlier submissions. Consequently, on behalf of our clients, we reiterate our OBJECTION to increase the number of caravans on site under existing planning consents. Sustainable the CSFPD as set out in the earlier documents. For completeness our concise points are as follows: Development and The Council would give consideration to the redevelopment of this site for Growth 2008 - 2026 1) The proposed allocations relate to land that is largely undeveloped. The use of undeveloped land residential development if it was a reasonable alternative. However, the rather than previously developed land (such as the Objection Site) is contrary to national policy. The Council is currently unable to permit the redevelopment of the site for Objection Site's appearance stems from planning permissions from the 1950's relating to the siting of residential development. caravans. It provides housing and holiday accommodation to a current total of 1000 homes. Without any further intervention, and in the absence of permanent housing allocations, it has potential under A significant proportion of the site is within the consultation zone for the existing permissions and site licensing conditions to provide a total of 1508 mobile homes for Calor Gas Installation at South Canvey. Residential development within permanent occupation. There are no restrictions under the Town and County Planning Acts. this zone would result in an objection from the HSE in accordance with their PADHI methodology. 2) The proposed Core Strategy identifies a number of sustainable transport infrastructure improvements, one of which is the further extension of Roscommon Way from Haven Road to Whilst a proportion of the Thorney Bay caravan site currently sits beyond Western Esplanade. The proposed residential development of Thorney Bay Caravan site would the HSE consultation zone, HSE consultation document CD212 suggests contribute directly to this scheme which would help to address a transport deficiency, support that these zones may be revised in the future to account for societal risk. economic growth in southern Canvey and would help to reduce local air quality issues as required by This would make the remainder of the site undevelopable also, the Core Strategy. undermining the delivery of the Core Strategy.

4) If strategic housing is to take place on Canvey Island then the Objection Site is more capable of The Core Strategy is therefore considered sound in excluding Thorney Bay dealing with issues arising from the potential for flooding, sustainable drainage systems and the in the Spatial Strategy. It should be noted, that the Core Strategy seeks the management of surface waters than others. Topographically, the site level is higher than other areas redevelopment of the Thorney Bay caravan park as a long-term objective in of Canvey Island. Locationally, the site is immediately adjacent to one of the most significant surface policy CP9. water outlets on Canvey Island (Scarhouse Dyke) and is therefore more capable of providing

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sustainable solutions for surface water runoff than other locations more remote from the system.

5) The Objection Site can be comprehensively redeveloped in two or more phases. The first phase would be outside the cordon sanitaire and not affected by the future of the hazardous installations. However, it is important to note that the proposed allocations do not take account of the fact that there is already a significant resident population at the Objection Site of which about 300 caravans are already sited within the cordon sanitaire.

6) The Canvey Island Sustainable Regeneration Report recognises the strategic significance of the Objection Site and provides design proposals and practical solutions for its phased development. The regeneration report acknowledges the potential timescales relating to relocation of the hazardous installations but also endorses that a development could take place by exploring the development potential of that part of the site falling outside the cordon sanitaire as a first major phase with a smaller residual phase to follow.

7) The Sustainability Appraisal of the Castle Point Borough Local Development Framework, July 2007 advises in paragraph 6.5 that ‘...a concern for sustainability means taking a very long term perspective, with sustainability the long term vision rather than necessarily an achievable state.' The consideration of the site as a whole for residential development accords with this long term view and would rationalise a large number of sustainable development issues within the context of a long term plan.

The Objection Site should be allocated for housing in lieu of the housing allocations currently proposed in the Draft Core Strategy. The CSFPD fails to acknowledge the unique circumstances of Thorney Bay Park, over and above the proposed allocations, and particularly, though not exclusively, the ability of the site to be developed in a phased manner and its current residential occupation. As such the CSPFD is unsound and should be altered to fully address the strategic context of Thorney Bay Park. 312 Policy SS 2 Mr G. Smith Mr Russell Forde U E the proposal is to redevelop the Church Road frontage of Manor Trading Estate for housing and to E Strategic location. The council accepts that the statement in para 6.49 should refer to 4ha of Distribution of G & K Groundworks Smart Planning Ltd decant businesses, where possible, onto 4.0 hectares of land currently designated as green belt to employment land. The council also appreciates the need to take a flexible Sustainable LTD the immediate east of the Trading Estate. The CSFPD is generally in accordance with our original view as to the precise uses that take place on this land. In principle Development and submissions to the Proposed Publication Document. We summarise those submissions here and however the council is seeking to improve the environmental impact of the Growth 2008 - 2026 have highlighted points either requiring emphasis or not accounted for in the CSFPD in bold. employment uses in this area. These are matters that will be dealt with in detail in the Benfleet, Hadleigh and Thundersley Plan. Similarly the matters relating to the detailed funding and timescales for delivery are considered Erratum: The CSFPD refers to ‘4.0ha of vacant land' (Policy SS2, Table 4). However there is a more appropriate to the Benfleet, Hadleigh and Thundersley Plan. The separate reference to ‘2ha extension to the east of the employment area' (page 45, paragraph council does not therefore accept that the representations make the policy 6.49). This ambiguity should be corrected by changing the latter reference to ‘....4ha unsound. extension....'

(i) The land owners generally welcome the allocation of their land for employment purposes and confirm a willingness to work with the Council to secure the actual development of this land together possibly with the redevelopment of his adjoining land in partnership with the Council and others.

The core strategy proposal is consistent with the landowners' aspirations which are clearly documented in planning appeal reference APP/M1520/A/07/2034627 which sought to develop a smaller contiguous area to provide urgently needed, new, modern accommodation for potentially viable local businesses already on the Manor Trading Estate. It is an indictment of the failure of that appeal to note that one of the businesses, relying on a positive appeal outcome, went into liquidation shortly thereafter.

(ii) The land owner agrees with the Council that the existing Manor Trading Estate is "run down". and of poor environmental quality and yet "well occupied" The roadways are in poor condition, there are problems with drainage and many of the buildings are themselves now in relatively poor condition and/or inefficient for modern employment purposes. The overall appearance of the site is therefore extremely poor. The site is nevertheless occupied by a variety of employment uses ranging from B1, B2 through to sui generis uses some of which include an element of retail. The existing situation is unlikely to improve without both the release of additional land for employment purposes and the allocation of some land for residential purposes.

(iii) The Council will need to ensure that existing occupiers of that part of the estate which is to be allocated for residential development are, so far as possible, given an opportunity to move on to the new allocated land. Further, in this regard, the Council will need to consider the scope of the allocation and perhaps allow part of it to be used for B2 and/or the various sui generis uses that exist at present .

Given that the approach will be a comprehensive one, and one that is phased over time, the opportunity to incorporate non-B1 uses in an environmentally friendly manner can be optimised by careful design of the new employment areas to make sure that potential

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external symptoms of use are minimised as far as possible.

(iv) There has been previous opinion expressed by existing owners, owner/occupiers and tenants of the land allocated for residential development that they do not wish their businesses to move any significant distance. Many of these businesses have been established for a long time and are committed to the area; they have established trading links; a local presence and employ local people many of whom can walk, cycle, share lifts or catch the bus to work. The proposed new allocation for employment purposes is therefore ideally situated. Further, it is in a highly sustainable location. This can only be improved upon with new buildings providing secure cycle storage, changing facilities and the new developments being the subject of Green Travel plans.

Some of the existing occupiers may not have supported this allocation is because they are under the impression that it can only be used for B1 purposes. The CSFPD retains a reference to the proposed allocation being used for ‘clean employment uses'. This requires further definition and it may be possible that some of the existing businesses may not fall strictly within such a definition. If so then some of the existing businesses may not be reassured of finding a new home within the new employment area. We say that the proposed allocation should go as far as possible in accommodating the existing businesses, whilst preserving and improving environmental quality, and without prejudicing the ability of as many as possible of the existing businesses to relocate to the new area.

The Use Classes can sometimes be a blunt instrument when applied to businesses that have many facets and we suggest that the Council take a very pragmatic and informed view towards the existing businesses in understanding what their external symptoms of use are, and how these can be incorporated into the new employment area through design led solutions, careful zoning of activity, the reasonable use of planning conditions and general sensitivity towards those businesses and the business aspirations of their proprietors. This would also provide flexibility of use and help to ease the burden of relocating the existing businesses as far as possible particularly in times of recession.

As before, we recommend that the reference to ‘clean employment uses' is amended in the light of the above comments.

(v) The land owner would be willing to implement the necessary infrastructure in order to provide serviced employment land to enable the existing businesses to relocate in an orderly fashion.

(vi) The land owner would be willing to cooperate with both the Council and a private housing development partner as a means of enabling the overall process of development to take place. This commitment is made notwithstanding whether or not the Council consider it expedient to exercise any Compulsory Purchase powers to deal with any residual land fragmentation issues arising from assembly of the proposed housing land.

The CSFPD does not seek to set out any funding arrangements or to establish more precise time frame for the delivery of this LDF proposal, other than, in the latter case, to rely upon the Development Plan period. We consider that more precise consideration of these arrangements and delivery period should be considered within the CSFPD. Their absence is not fatal to the document but, even an indication of how these parameters are to be defined would make the CSFPD more robust 318 Policy SS 2 Mr Roy Lewis U E In relation to Policy SS2 there are two aspects which require further consideration, E Essex County Council would wish to attend the With regard to the proposed amendment to the fifth point under Housing Distribution of Essex County oral part of the examination to further elaborate Growth and Community Development relating to Canvey Island the council Sustainable Council its representations on the Core Strategy; to recognises the importance of providing educational facilities as a priority. A. Canvey Island: Housing Growth and Community Development, fifth bullet - the County Council Development and provide the wider sub-regional/ regional context However, it maintains that it is desirable to refer to the provision of a fully supports the reference to provision for educational facilities on the site of Castle View School. Growth 2008 - 2026 for matters included within the Core Strategy; children’s play area and further housing on the site to provide a degree of The provision of a Vocational Centre on the site will aid the transformation and extension of and to provide technical assistance on matters certainty as to the future use of the remaining land and also to identify a educational facilities on the Island and will be a key contribution to the social and economic relating to delivery of County Council services. site that will provide a potentially significant contribution to the housing land regeneration of Canvey Island through enhancement of skills and economic opportunity. The County supply. The council believes that these matters can be resolved through Council's prime objective is for the site at Castle View School to continue to fulfil a role in meeting further discussion with ECC and that the policy is therefore effective. the educational needs of Canvey Island and Castle Point.

With regard to the second point under Employment Growth and The County Council, as owner, will continue to manage the site to ensure the success of the Regeneration relating to Benfleet, Hadleigh and Thundersley the council Vocational Centre. Development for other than educational purposes, including limited residential has discussed this matter with ECC highway officers in the past and agrees development, would be contemplated insofar as it supported the successful realisation of the with the need for further assessment when more detailed development proposals for the Vocational Centre. Current plans for the Vocational Centre anticipate its opening in proposals are available. The council also recognises the significance of the September 2011 only on part of the site. The remainder of the site will be vacated by January 2012 recycling facility and if this is to be relocated will seek to identify and with the relocation of the existing Castle View School to the Furtherwick Park site. The subsequent alternative site for the continuation of this function. use and purpose of the remainder of the Castle View site is for future consideration and in those circumstances it is premature to specify a dwelling capacity within the Core Strategy. Equally, given the regeneration agenda for Canvey Island it would be inappropriate, as currently implied by Policy SS2, for part of the site to remain vacant from 2012, pending development post 2021. Consequently, Policy SS2 fifth bullet (Canvey Island, Housing Growth and Community Development) should be

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amended by deletion of the existing text and its replacement by,

‘Land currently in use by the Castle View School will be redeveloped to provide educational facilities as a priority with the scope and timing of development for other uses only to follow fulfilment of the educational priorities for the site.'

Relevant revision of Table 10 and Appendix A should also recognise this amendment.

B. Benfleet, Hadleigh and Thundersley: Employment, Growth and Regeneration, second bullet - proposes to redevelop the frontage of the Trading Estate for 200 dwellings and also to redevelop the scrap yard and about 4.0ha of vacant land to the east of the estate for clean employment uses. Successful implementation of these proposals requires two key matters to be addressed,

i) the development of 200 dwellings on the frontage of Manor Trading Estate would generate increased traffic levels along Church Road/Rushbottom Lane and on to the already congested junction at Tarpots corner. Following planned improvement of the junction as part of the A13 Passenger Transport Corridor further assessment will be required of the traffic measures to facilitate the development without detriment to the junction or the local highway network. Also, when more detailed development proposals are available, further consideration will be required of the impact of continuing commercial traffic to Manor Trading Estate on the proposed residential development.

ii) removal of the existing scrap yard would have a detrimental impact on the capacity of the local area to recycle metals and limit the area's ability to make an effective contribution to waste recycling targets. The County Council's Waste Development Document, which is in preparation, will plan for future capacity for waste recycling and loss of this scrap yard will significantly limit that Document's ability to build upon existing capacity of recycling facilities in the county. The Borough Council should identify provision at an appropriate alternative site in the Borough for continuation of the waste recycling function of the scrap yard. 335 Policy SS 2 Jetbury Investments MARY POWER U J Also Effective and Consistent with National Policy E Jetbury Investments Ltd's representations raise It is unclear how a lack of flexibility in the Core Strategy is demonstrated Distribution of Ltd SAVILLS issues of significant importance that question the when referring to a current lack of a 5 year supply without the Core Sustainable COMMERCIAL LTD soundness of the plan. We therefore request Strategy - the purpose of the Core Strategy is to address this shortage Policy SS2 Distribution of Sustainable Development and Growth 2008 - 2026 Development and participation in the oral examination to ensure which the Housing Trajectory clearly demonstrates it does. Growth 2008 - 2026 our case can be fully made and subject to - Not Justified, Effective or Consistent with National Policy questions by the Inspector as appropriate. With regard to the Town Centre Masterplans, the Canvey Town Centre Masterplan is now complete, and the Hadleigh Town Centre Masterplan is 2.1 We object to this policy on the basis that it does not comply with the Tests of Soundness set out underway. Delivery in both locations is therefore far more certain than this in PPS12 Local Spatial Planning (June 2008) on the basis that it is not justified effective and consultee believes, and should be given preference to Greenfield consistent with national policy contrary to paragraph 4.52. development as per PPS3. The Core Strategy is not therefore unsound in this regard. 2.2 The Core Strategy and Annual Monitoring Report 2008/09 state that there is sufficient supply of housing land to meet housing needs in Castle Point up to 2026 if the proposals set out in the Core With regard to land North of Kiln Road, the capacity of this location has Strategy final publication document are delivered (AMR page 18). However, the AMR states that been reduced to reflect information provided to the Council with regard to without the Core Strategy it is unlikely that Employment Land Rejuvenation and Urban Peripheral nature conservation issues in this location. This is explained in the Development will occur. This reduces the five year supply by around 180 units to 986. There discussion supporting the outcomes of consultation in January to March therefore appears to be little flexibility in the Core Strategy to deal with changing circumstances. 2009. The Core Strategy is therefore justified and correct in reducing the capacity in this location. 2.3 Furthermore, the ability to meet the housing targets is heavily reliant on housing being delivered in Canvey and Hadleigh Town Centres, where an overall target of 901 homes has been set in the The Housing Trajectory does demonstrate under delivery in the period to Core Strategy. The Council's Strategic Housing Land Availability Assessment (SHLAA) published in April 2009. However, it should be recognised that housing delivery 2009 states that the deliverability of housing in these town centres will be more difficult without the nationally has been down over the last 2 years (before this period delivery presence of a town centre masterplan to secure delivery in the next five years. It states that this was on target). Furthermore, there was no Core Strategy in place. The would lead to a further fragmented approach to delivery which has characterised Hadleigh Town Core Strategy proposes Greenfield land to help address the deficit, with Centre in the past. The preparation of these documents has been delayed until after the Core some of this land phased to occur early in the plan period. The Core Strategy Examination. Until these documents have been developed and subject to consultation, it is Strategy is not therefore considered unsound with regard to delivery to therefore difficult for the Council to be confident about whether the targets can be achieved. Given date. this high degree of uncertainty, it seems short sighted of the Council to exclude other sustainable Green Belt sites from the Core Strategy as this prevents it from taking a flexible responsive approach The Council is aware of the Green Belt criteria, and is of the view that the to the delivery of housing in accordance with Government objectives. locations identified for development do not cause harm to the strategic function of the Green Belt. The land to the north of Kiln Road is identified 2.4 Previous versions of the Core Strategy including the proposed Publication Document published as Green Belt, and does prevent the coalescence of place, and protect the in January 2009 referred to the provision of 310 homes at land to the north of Kiln Road. However, countryside from development. There is notable nature conservation value Policy SS2 reduces this to 250 homes. We note that Barratt Homes has submitted a planning in this location, and it is considered that further development beyond 250 application (ref CPT459/09/FUL) for land to the north of Kiln Road for 150 units and it seems that this homes may have an impact on this. application has resulted in a reduced calculation of the capacity of this land. There is already an application awaiting determination by the Council (ref CPT/708/04/OUT) for 310 dwellings. The Residents in Castle Point, through a citizens panel survey, identified nature application by Barratts will lead to piecemeal development of the site (see objection letter submitted conservation as being of particular concern to them. As a result, when by Savills October 2009). The Barratts application has not been fully assessed by the Council yet several consultees, the councils sustainability appraisal consultants, and and we have been told by the case officer that the earliest it will go to Committee is February 2010. Scrutiny Members sought for weighting to be applied to potential The previous Local Plan Inspector identified that this site was capable of achieving 310 dwellings development locations the outcomes of this survey were applied. Given the Page 73 of 222

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and it was accordingly safeguarded for housing development in the Local Plan (Policy H5). There nature conservation interests affecting the North of Kiln Road location, this are no reasons or evidence why the capacity of this site has been reduced on the basis of an resulted in the sustainability score being lower than other sites. Whilst the undecided application, thus undermining the credibility of the evidence base. landowners may dispute this point, it is clear from planning application work this issue does make development in this location difficult and unfavourable. 2.5 Table 22 of the Core Strategy Final Publication document identifies a deficit of 254 homes up to 2009. The Council's SHLAA 2009 identifies that 4518 of the Council's housing target can be identified in the existing urban area, leaving a requirement of 500 homes on the urban periphery. The Core Strategy is therefore considered sound with regard to its However, there is no evidence to demonstrate that sites informing the figures included in the housing evidence base, and with regard to the distribution of development trajectory at Table 23 of the Core Strategy are available, suitable and achievable in accordance with identified. Further development to the north of Kiln Road is not considered paragraph 54 of PPS3. Given this and the fact that Council has not previously been able to meet its acceptable due to nature conservation concerns. housing targets we are not convinced that the policy is based on robust and credible evidence and subsequently whether it is flexible and deliverable, which would result in it being contrary to national policy in particular in PPS3.

2.6 Policy SS2 Supporting paragraph 5.19 identifies three locations for the release of Green Belt land: West of Canvey Road, East of Canvey Road and Castle View School. These sites are identified as capable of providing 500 homes up to 2026 across the three sites. Policy SS2 states that beyond those locations identified, the extent of the Green Belt will be maintained and protected. However, it is our view that there are other sustainable sites that do not serve the five purposes of including land in the Green Belt, as identified in Planning Policy Guidance 2 Green Belts 1995 (PPG2), which have been omitted from this list and could meaningfully contribute to the delivery of housing supply in the borough in particular land to the north of Kiln Road, Thundersley which in part has already been assessed to be suitable for release subject to housing supply need determined by a previous development plan Inquiry Inspector.

2.7 We have reviewed the Reassessment of sites on the urban periphery (September 2009) and do not think that the weighting system accurately represents the sustainability of the sites assessed.

2.8 A confidential Sustainability Statement was submitted to Steve Rogers in August 2008 on behalf of Jetbury Investments Ltd as part of the Core Strategy evidence building process. In our view this statement demonstrates that the site, land at Kiln Road to the west of the land safeguarded for housing in the Local Plan (referred to as C.9 in the assessment of sites) is sustainable and has the capacity to provide a range of 731 to 1218 dwellings. This would protect the Council's position should other sites not be delivered.

2.9 Furthermore, when spatially considering the Green Belt in and around Thundersley, the inner Green Belt land north and south of The Chase, as confirmed at the previous Local Plan Inquiry by the Inspector (1996), can not perform the five functions of including land within it, as it is surrounded by development on all four sides. Therefore, if Green Belt land needs to be released to meet identified development needs, this land north and south of The Chase should be considered above and before other Green Belt land release. The previous Inspector's conclusions are a material consideration and should be taken into account in the assessment of the sites, but seem to have been overlooked.

2.10 This site is ranked as joint 13 in the reassessment of sites. Taking the above into account, the criteria against which it has been assessed do no accurately present the position. In relation to the loss of openness, the site scored -1 as the table states that there is no mitigation for this. However, given the Inspector's conclusions that it does not perform the five functions of including land within it this does not seem reasonable. This equally applies to the score of -2 regarding whether the site is part of or close to an area of nature conservation, as the Inspector's conclusions demonstrate that this is not an overriding factor.

2.11 The Core Strategy acknowledges that the sites identified for Green Belt release are within Canvey Island and therefore subject to flood risk, but states that this can be overcome. In addition, the reassessment of the sites identifies that East of Canvey Island (referred to as C.3) can accommodate a maximum of 350 homes, but the Core Strategy states that 400 homes will be provided. This therefore questions the reliability of the housing figures and suggests that they may have been altered to reach the required housing targets. The reassessment ranks land East of Rayleigh as the most sustainable, but this is not included in Policy SS2 for the release of Green Belt Land. Land to the West of Canvey although ranked 5 in the reassessment is, however, included in policy SS2 for the release of Green Belt land.

2.12 Given the issues referred to above and the current economic climate there is a real possibility that some of the sites which have been included within the housing trajectory figures may not be developed or at least not at the capacity included in the housing trajectory. In light of this, it is therefore particularly important that the Council protects its position and identifies sustainable Green Belt sites, that do not meet PPG2 criteria, as strategic locations for the delivery of housing to ensure that the minimum targets are achieved and if possible exceeded. The Spatial Strategy proposed does not allow for a flexible responsive approach to the delivery of housing, contrary to Government objectives in Planning Policy Statement 3 Housing 2006 (PPS3). The Core Strategy in its current Page 74 of 222

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form is therefore considered to be unsound. 341 Policy SS 2 Cllr Martin Tucker U E The Spatial Strategy, p.25 E As elected representatives of Castle Point The Sustainability Assessment of Sites on the Urban Periphery is Distribution of Canvey Island Borough Council residents, and with multiple recognised by the Council as a contentious document because it deals with Sustainable Independent Party representations made for consideration, CIIP issues of a contentious nature to both residents and developers alike. As a Points relating to the Spatial Strategy but not to a specific section Development and would like to participate at the oral part of the result, the initial document was subject to consultation and also Scrutiny by Growth 2008 - 2026 examination to justify and clarify the document Members. Along with the findings of the SA, it was considered that the While we agree with the principles and acknowledge the aims of the Spatial Strategy, we have grave submitted in response to the Core Strategy. assessment needed to be made more objective, and to have more doubts that they are deliverable by the means outlined in the CS. For reasons described in this important criteria weighted. document, the Spatial Strategy is ineffective and unsound. This work was completed using measurable points to underpin each Distribution of Sustainable Development and Growth, p.27 criterion, and scores attributed to each criteria by residents in a survey of the citizens panel. A revised assessment was then prepared. This assessment is now considered to be objective and sound, whilst clearly still Points relating to Distribution of Sustainable Development and Growth but not to a specific contentious because it cannot possibly give everyone the answer that they section want.

The method of determination of appropriate sites for development in the CS is a very contentious It is recognised that the Core Strategy previously contained land to the issue. The points/scoring system employed to assess the sites was flawed and the surveys should North of Daws Heath Road as an option. This was replaced by proposals to not have been carried out by CPBC officers. Castle Point residents can perceive that they are not redevelop the frontage of Manor Trading Estate for residential purposes. impartial and a third party professional consultancy or an independent panel would have been more The site was removed from the Core Strategy because it fulfilled a strategic appropriate - especially from the residents' viewpoint. Green Belt function in terms of separating Hadleigh from Rayleigh. As a result the removal of this site from the Core Strategy improved its The Core Strategy Further Preferred Options Report (2008) proposed the development of over 550 consistency with PPG2. homes on the green belt site north of Daws Heath road. Only days before CPBC ratification - to accommodate for a protest by residents who campaigned to ‘save the green belt' - the plan was The proposal to include an urban extension to the North West of hastily revised to remove this proposal and increase the housing allocations elsewhere. Although Thundersley in the Core Strategy was consulted on in the Spring of 2006. this shows flexibility in the plan, the decision was reactive, political, and not justifiably explained This proposal was objected to by statutory consultees and residents alike through robust evidence. Simply increasing the allocation of housing units in other already identified due to its unsustainable nature. The site is remote from the existing urban sites either indicates a lack of future growth planning detail, or that the original allocation numbers area and would generate extra traffic on key routes in and around the were not based on robust evidence. There is no evidence shown in the CS to justify, or even Borough. As a result, it sustains an objection from the County Highways document, the changes. Authority. Furthermore, it is clear that there is a general concern about Green Belt development throughout the Borough. This proposal seeks to The CS makes no mention of the options set out in the ‘Hickfort Plan'. This plan for development on develop an area of Green Belt far in excess of that required to meet green belt land to the east of Benfleet has never been before any committee or sub-committee, but housing needs beyond the urban area. This would therefore be contrary to has many aspects that are worthy of consideration. The vision of the plan is to relocate the poorly general views on Green Belt protection expressed by residents, rather than sited Manor Trading Estate and release a brownfield site suitable for over 2000 housing units. The a specific NIMBY response. new employment site would be adjacent to three major highway routes and between two main line railway stations, and is well positioned for any future large commercial development within the area. The Council recognises that Thorney Bay is being used for residential No justification has been made for dismissing this publicly supported option. caravan use. A significant proportion of the site is located within the consultation zone for The Calor Gas hazardous installation. Due to existing Details for the vision of Thorney Bay Park are severely lacking. Thorney Bay Park is a caravan site, planning permissions, the Council is unable to prevent the use of this site located in the south of Canvey Island. It is progressively expanding to include long-term rental of for residential purposes but does not support this use. mobile home style caravans, as stated on their website1: The Council does not therefore consider that it is appropriate to count In a nutshell, a long term rental on a caravan in Thorney bay Park offers excellent value-for-money these caravan units towards the Borough's housing supply. Policy CP9 with tons to keep you occupied. You'll also be surrounded by people just as delighted with their way addresses the issues regarding the redevelopment of this site for of life as you are. residential purposes in the future, but does not believe this is deliverable until such time as the hazardous installations at South Canvey cease operation. Like Kings Park Village, on the north of Canvey Island, transformed from being a recreational caravan site into a large residential home park, Thorney Bay Park is progressively reproducing the transformation. Unlike the homes at Kings Park Village, however, the homes at Thorney Bay Park With regard to the town centre, it is consistent with PPS3 and PPS4 to are not considered in the CS. If CPBC embrace and regulate the transformation from caravan site to seek residential development in town centres where there is increased residential park, hundreds of the required 5000 new homes in Castle Point will be provided. In failing access to public transport and services. This reduces the need for private to consider this reasonable alternative, the CS is unjustified and unsound. If homes on this site vehicles. The Canvey Town Centre Masterplan demonstrates that 200 continue to remain unaccounted for, there is a danger of populating Castle Point beyond its required units can be provided in the Town Centre Core. The Core Strategy is (and predicted) growth, and beyond its infrastructural provisions within the time frame of the CS. therefore considered sound in this regard. Unsustainable growth must be inhibited by the CS. It should be noted that CPBC is currently investigating the number of permanent residents on this site since effects of changes raised public With regard to growth at Charfleets Industrial Estate, this will be supported concerns. The findings will help in shaping the CS. by new road infrastructure providing additional access to the estate and reducing pressure on the congestion point where Northwick Road and Table 4: Spatial Distribution of Regeneration and Growth, p.28 Canvey Road meet. This location is therefore considered deliverable and therefore sound. Employment Growth and Regeneration With regard to the seafront, it is anticipated that leisure and supporting development (A3 - A5) will occur at ground floor level. However, in order to Canvey Town Centre is in great need of regeneration, including ‘a broad mix of retail, leisure and make such development viable and to improve the vitality of the seafront community services'; however, the imposition of 400 new homes within a small area together with area, particularly during winter months it is considered appropriate for the obvious increased demands of road traffic is unsustainable. residential accommodation to occur above ground floor level. This applies similar principles to town centre development and is therefore considered

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The Charfleets Industrial Estate is in need of regeneration - not only to attract new business, but also consistent with PPS3 and PPS4. to accommodate the businesses moving from the Point Industrial Estate; however, any further expansion of this site will attract more road traffic - especially heavy goods vehicles - which will With regard to the relocation of the Point Industrial Estate, a realistic increase congestion at the Waterside Farm roundabout. With no highways improvements planned to timescale has been included in the Core Strategy that recognises the support expansion, the plan is undeliverable. difficulties of relocating uses. As such there is an insufficient housing capacity to meet a five year supply without including Greenfield land. To Canvey seafront is in great need of regeneration, but to ensure it remains a leisure hub, residential this end, Greenfield land has been brought forward to ensure there is a five development must not be allowed within the traditional seaside frontage area. Castle Point has year supply. This is consistent with PPS3. already approved plans for 32 flats in this location which endangers the historic character of the area. The CS does not specifically discourage this type of development in this location - for this The land to the East of Canvey Road is identified for development to reason the plan is inappropriate. commence in the period 2009 to 2014. This is in order to ensure that there is a five year supply, and to support the delivery of community Housing Growth and Community Development infrastructure in this location. The sustainability assessment of sites identifies this as a sustainable location with good access to community facilities and jobs. The Green Belt in this location forms a crescent shape The CS does not clearly state that the whole Point Industrial Estate should be relocated within a infill and is not therefore considered to fulfil a strategic Green Belt function. minimal timeframe to ensure that the creation of brownfield land can be utilised for residential New open space will be created as part of the development, and a new development before Greenfield sites are used. In fact, Table 10 of the CS indicates that relocation nature reserve is due to open to the West of Canvey Road in March 2010. will be piecemeal and will ‘occur when a suitable site is found at West Canvey'. Table 23 of the CS The inclusion of this site as phased in the Core Strategy is therefore states the plan to develop green belt sites for housing from 2009. This is inappropriate and not considered appropriate and sound. consistent with aspirations to utilise previously developed land.

The proposed development to the West of Canvey Road (Frontage) can be Land to the East of Canvey Road is the last piece of natural green belt accessible to residents living accommodated to the south of the Dutch Cottage Museum with a gap of in deprived areas on the urban periphery. It is unjustified to consider this location for development around 50m left between the new development and the listed building this from 2009 (Table 23, CS) before previously developed sites. will ensure that the setting of the listed building is not affected by the development. Any proposed development on land fronting the west of Canvey Road must adhere to PPG15: Planning and the Historic Environment in order to protect the Dutch Cottage Museum. It is It is recognised that the road network in this location is busy, and as such unreasonable to believe that a 50 unit building ‘for older people', located to the south of the Dutch amendments to the highway network will be needed to accommodate Cottage Museum, will not overshadow the protected building. Other reasonable alternatives are development on this site, particularly in terms of road safety. Improvements lacking, deeming the plan unsound. The site is adjacent to one of the busiest road junctions on along Northwick Road for example will be necessary to provide safer Canvey Island with fast moving traffic and a history of accidents. Between Northwick Road, the main access to Morrisons and bus waiting facilities will need to be improved. route to Morrisons supermarket, and the Canvey Road dual carriageway which leads on and off of These will benefit users of this area more widely. The nearby industrial Canvey Island, the site is 30 metres away from Charfleets Industrial Estate. It is far from ideal to be estate is relatively less noisy in this location, as heavy industry takes place considered acceptable as a location for ‘specialist housing provision for older people' and is judged further south and many of the users in this location offer training facilities or as unsound planning. The development will cause local job losses as the land is currently home to use their sites for parking of working vehicles such as minibuses, the only garden centre on Canvey Island, which is also a central point that residents meet and ambulances, training lorries or cars for sale. There is also some light interact. If change of use goes ahead and the garden centre is displaced, then it will lead to industry in this location. Residential amenity is not considered to be a increased traffic leaving Canvey Island on already congested highways. This is not sustainable and problem in this location. is therefore unsound. This area suffers from antisocial behaviour in the form of off-road motorcycles speeding past the site, causing residents to fear for their lives. Neither Castle Point Council nor the police have been able to solve the problem, which raises the question of suitability as dwellings for It is recognised that the existing Garden Centre employs staff. However, an older residents. A more suitable site should be found, probably near to the town centre. This plan is elderly peoples scheme will also employ staff to support residents, not sound. particularly those with extra care needs. Such employment requires skills training and is less subject to seasonality than retail. As a result this proposal would continue to contribute towards employment in the The envisaged vocational college is essential for Castle Point to provide appropriate skills training for Borough. local jobs, especially with plans to reduce the number of secondary schools on Canvey Island. Replacing the existing school - built on green belt land - with a college and a children's play area provides the community with two, much needed community facilities; however, the green belt land The location of an elderly peoples scheme to the West of Canvey Road should not be utilised for housing development while other reasonable alternatives remain (Frontage) is not therefore considered unsound. unexplored. With regard to Castle View School, the vocational centre is currently Sustainable Growth and Environmental Conservation subject to a planning application. This will be funded by Essex County Council as a result of the demise of the Learning and Skills Council. Essex County Council are seeking to realise the value their assets in order to To provide for 650 new homes on previously developed land within the urban area of Canvey Island recover the costs of this scheme and therefore wish to deliver 50 dwelling is welcomed; however, there is no evidence to show where these sites are, the effects on the local units on the site, primarily using the footprint of the existing school. In infrastructure of building these new homes, nor any spatial planning strategy in the CS to sustain delivering this scheme the proposals are to retain the existing sports hall at these developments. This number of new homes, along with the proposed 800 in Benfleet, Hadleigh the site, and retain much of the playing fields. Development will therefore and Thundersley is far too many to propose with no spatial planning provided. This is unsustainable largely take place on previously developed land. The site has been subject and inappropriate. to sustainability assessment and is considered to be a sustainable development location due to its proximity to the existing residential area, The proposed ‘area of public open space...to the west of Canvey Island' is under consideration as an public transport routes and the town centre. Furthermore, it is not intertidal habitat creation site, but this fact is not acknowledged in the CS. considered to fulfil a strategic Green Belt function. The inclusion of this site in the Core Strategy is therefore considered to be sound.

The SHLAA has identified capacity for around 1450 dwelling units on smaller sites and main routes (outside Hadleigh and Canvey Town Centres) within the urban area. The policies set out in the Core Strategy will ensure that these units contribute towards sustainable development and infrastructure provision. The Core Strategy is therefore appropriate to Page 76 of 222

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include this provision.

The Environment Agency has recently submitted the Thames Estuary 2100 Plan to DEFRA for approval. This includes the creation of intertidal habitat to the West of Canvey Road in the period beyond 2070. As this is some time off it is appropriate to refer to the current creation of a nature reserve in this location. Furthermore, the creation of an intertidal habitat in the period beyond 2070 does not necessarily exclude public access but will perhaps change how people can use the site at different times of tide. The Core Strategy is therefore appropriate with regard to the inclusion of this project.

The proposed ‘area of public open space...to the west of Canvey Island' is under consideration as an intertidal habitat creation site, but this fact is not acknowledged in the CS. 395 Policy SS 2 WM Morrisons Mr Jason Lowes U J The third, fourth and fifth bullet points of the "Housing Growth and Community Development" section E The issues raised by these representations are The Core Strategy sets out a distribution of development that identifies the Distribution of Supermarket Plc Rapleys of the policy should be deleted, and replaced with the following single bullet point: fundamental to the soundness of the Core broad locations for growth in Castle Point to 2026. This is consist with Sustainable Strategy, and are sufficiently complex to warrant advice received from GO-East in 2007, and therefore the amendments Development and discussion at the examination. proposed by this consultee are not considered appropriate by the Council, "The Council will review the existing Green Belt boundary on Canvey Island, through the Canvey Growth 2008 - 2026 as this would mean that the Core Strategy fails to respond to this advice. Island Area Action Plan, to ensure that there is sufficient land available to meet the identified development requirements throughout the Plan period." The Council is confident that the Core Strategy is sound with regard to both issues raised regarding the evidence base. The first sentence of the second bullet in the "Sustainable Growth and Environmental Conservation" section of the policy should also be deleted for consistency. The SHLAA was prepared using detailed street level surveys. All landowners with potential sites were identified and written to. It is The reasons for the changes requested are as follows: recognised that a number of these landowners did not respond to this consultation, however the SHLAA considered deliverability over a period of Policy SS2 of the Core Strategy is unsound, as the Council's identification of three Green Belt 18 years, and therefore it is reasonable to assume that landowners may locations for residential development on Canvey Island is unjustified on the grounds that: not hold the same view of redevelopment later in the plan period that they did in 2008, particularly as the economy improves. Where no response was received, the potential contribution from a site was not included in the first • (i) The Council's Strategic Housing Land Availability Assessment (SHLAA) is flawed, as it five years of the plan period. Furthermore, a proportion of the development overestimates the capacity of the existing urban area on Canvey Island to accommodate from sites where no response was received was distributed on a non-site new housing, and specific bases to "never" coming forward for development. Therefore, the • (ii) The Council's evidence supporting the sites is unconvincing and does not provide SHLAA has fully taken into account the issue of uncertainty surrounding sufficient evidence that the most appropriate sites have been identified for release from such sites. the Green Belt. With regard to the industrial areas identified for redevelopment, the Council Both of these issues have been comprehensively discussed in previous representations, most is anticipating the receipt of an application for one of the sites in due recently on 19 th March 2009 (which are attached for information), albeit these representations course. As a result, the Council is confident that land is available from this predate the Council's revised Assessment of Sites on the Urban Periphery (September 2009). source, although it does recognise that it is harder to achieve such redevelopment in comparison to the development of a Greenfield Site. Castle Point Strategic Housing Land Availability Assessment (January 2009) The SHLAA is therefore considered sound, and will be updated regularly to ensure that it remains so. The document sought to identify potential housing sites from a variety of sources, including surveys to identify potential sites on main routes in Canvey Island, and an update to the Council's 2004 Urban Capacity Study. However, the surveys were carried out in November 2007, when there was With regard to Green Belt Sites, the Council has prepared a document more optimism in the housing market than in January 2009, and no allowance is made within the entitled Sustainability Assessment of Sites on the Urban Periphery (2008). SHLAA for any influence this change of economic circumstances might have on the intentions of the This was subject to consultation alongside the Further Preferred Options owners of the potential residential sites. Report and scrutiny by Members. As a result of this, the assessment was revised to build in comments that the scoring was not sufficiently objective and did not weight sustainability issues sufficiently. In order to overcome Further, approximately 48% of the dwellings identified in the Urban Capacity Study update were not this, clearer, more objective measures were attributed to each criterion, subject to a response from the relevant land owner, and in the case of the Main Route Survey, 33% and the results of a citizens panel survey were used to identify the of the units were not subject to a response. A lack of response would, if anything, indicate that the importance of each criterion. Each site was then rescored. With regard to owners of those sites no longer wished for them to be brought forward for residential development. land West of Canvey Road (Triangle) the sustainability score remained However, the SHLAA assumes that the same proportion of these units will be ultimately delivered for negative, and the position of this site in sustainability terms in relation to residential units as those units which had been subject to a response. These surveys are therefore other sites did not change. As a result, this location is not considered to be flawed in terms of methodology and by the passage of time, as indicate a level of potential housing a reasonable alternative. The Core Strategy is considered sound in significantly higher than is likely to be deliverable. excluding this site as a development location.

The SHLAA also identified two industrial estates on Canvey Island as being potentially suitable as residential sites. However, both sites are in multiple ownership, and it is recognised by the SHLAA that there is little evidence that a sufficient number of the owners have aspirations for residential development on the site to render either site realistically deliverable for residential use. Therefore, these sites cannot be relied upon to deliver housing during the plan period.

In conclusion, the SHLAA strongly indicates that the existing urban envelope of Canvey Island is

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unable to accommodate the growth in housing which is required by the Core Strategy. However, it over-estimates of the capacity of existing urban area of Canvey Island. Therefore, it is not possible to assess how many new residential units will be required on peripheral sites during the Plan period and, correspondingly, it is not possible to ascertain whether the sites identified will be sufficient to prevent pressure for further, uncontrolled development in the Green Belt.

Evidence Supporting the Identified Sites

The Scope of the Assessment - the assessment considers a number of criteria and factors against a number of identified potential sites. However, these criteria and factors do not reflect all of the issues that PPG2 advises should be the material factors when considering whether land should be included within the Green Belt. The assessment also appears to pay no regard to the importance of setting clearly defined boundaries for the Green Belt. These issues are discussed in further detail in the representations relating to the soundness of this element of the Core Strategy in terms of National Policy (which have been submitted alongside these representations).

As a result of the weighting, these two criterion would give a site that was previously developed in an inaccessible location a score of +6, whereas a well located site that was not previously developed would receive a score of -6 indicating - incorrectly - that the latter site was significantly more unsustainable than the former and less appropriate for removal from the Green Belt. This lack of prominence to accessibility issues is inconsistent with the principles of sustainable development, and is particularly inappropriate given that the Core Strategy identifies severe traffic congestion on Canvey Island at present. Therefore, as a result of the manner in which the assessment was weighted, the assessment cannot be relied upon to properly reveal which sites are the most Page 78 of 222

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sustainable to release from the Green Belt.

Conclusions

In summary, the Council has provided insufficient evidence to confirm the capacity of the existing urban envelope to deliver the housing numbers required and, correspondingly, the number of units which will be required outside the urban envelope (albeit the evidence strongly suggests that more housing will be required outside the existing settlement boundaries than is allowed for in the Core Strategy). Further, the Council has not provided sufficient and reliable evidence to indicate that it has chosen the best locations for accommodating housing in sites on the urban periphery. In these terms, all location specific references to potential housing sites in the Green Belt on Canvey Island should be removed. An updated SHLAA should be produced, and sites on the urban periphery assessed appropriately. 396 Policy SS 2 WM Morrisons Mr Jason Lowes U N The third, fourth and fifth bullet points of the "Housing Growth and Community Development" section E The issues raised by these representations are The Core Strategy sets out a distribution of development that identifies the Distribution of Supermarket Plc Rapleys of the policy should be deleted, and replaced with the following single bullet point: fundamental to the soundness of the Core broad locations for growth in Castle Point to 2026. This is consist with Sustainable Strategy, and are sufficiently complex to warrant advice received from GO-East in 2007, and therefore the amendments Development and discussion at the examination. proposed by this consultee are not considered appropriate by the Council, "The Council will review the existing Green Belt boundary on Canvey Island, through the Canvey Growth 2008 - 2026 as this would mean that the Core Strategy fails to respond to this advice. Island Area Action Plan, to ensure that there is sufficient land available to meet the identified development requirements throughout the Plan period." The Core Strategy is considered to be consistent with PPG2 through the exclusion of land to the West Of Canvey Road (Triangle) as a development The first sentence of the second bullet in the "Sustainable Growth and Environmental Conservation" location. section of the policy should also be deleted for consistency.

The site is visually prominent and clearly undeveloped. Its development The reasons for the changes requested are as follows: would, in the view of the Council constitute a significant incursion into the Countryside and would be a clear example of urban sprawl. As a result, Policy SS2 of the Core Strategy is unsound as the identification of three Green Belt locations for this would be contrary to PPG2 and undermine the strategic function of the residential development on Canvey Island is inconsistent with National Planning Policy. Green Belt on Canvey Island.

National policy in respect of the Green Belt is set out in Planning Policy Guidance 2: Green Belt, which was published in January 1995, and amended in March 2001.

PPG2 confirms that the purposes of including land in the Green Belt are as follows:

The PPG2 also sets out a number of benefits generated by Green Belt land, however, paragraph 1.7 confirms that the purposes of including land within Green Belt have paramount importance, and should take precedent over land use objectives. PPG2 also confirms the importance of setting clearly defined boundaries for the Green Belt, using readily recognisable features such as, inter alia, Page 79 of 222

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roads. The document also stresses that Green Belt boundaries should be drawn with the need to promote sustainable patterns of development in mind.

In these terms, the Core Strategy is unsound as it is not in compliance with national policy. However, removing reference to the three sites, and replacing them with a commitment to review Green Belt boundaries as part of the Canvey Island Area Action Plan would ensure that the Core Strategy is sound in this regard. 406 Policy SS 2 Mrs Olwyn Harris S J To the Planning Inspector from the E The Hands Off the Green Belt Group wish to be No response required as objection site not included in Core Strategy Final Distribution of Hands Off Our represented at the oral part of the examination Publication Document. Sustainable Green Belt to ensure that the views of many of the residents Hands Off Our Green Belt Group Development and of Daws Heath who wish the Core Strategy to be Growth 2008 - 2026 upheld, and the land north of Daws Heath Road In July 2008 a number of residents in the Daws Heath area of the Borough of Castle Point, in Essex to be protected, from the renewed attempts by became aware of the existence of a public consultation, which would lead to the development of a Barratt's building company to obtain planning Core Strategy for Castle Point. The strategy would include plans to develop areas to meet housing permission for a housing development, on green targets set by the government. belt land, which is out of keeping in scale and nature with this semi rural area. Residents were shocked to learn that many areas of hitherto undeveloped land across the borough had been assessed according to ‘sustainability criteria' and that, as a result, an area of green belt Our local councillors, by refusing to vote for a land currently known as Blake's Farm to the east of Rayleigh Road had been assessed as highly strategy that included the Daws Heath Site, suitable for development. Furthermore a farm next to Blake's Farm known as Cooke's Farm would recognised the important green belt function that be likely to be added to the original development, at a later date, resulting in a substantial area of this land plays in separating the Rayleigh and development right up to the border of the Little Haven Nature Reserve. Thundersley Communities. They shared the public's lack of faith in the effectiveness of the scoring system which placed the Daws Heath Residents also learned that the national development company, Barratts, would be applying to build site, previously not favoured for development, on Blake's Farm and many were angry to learn of these proposals which would substantially affect ahead of others in suitability in the draft Core the nature of this semi-rural area which contains the historic West Wood and the aforementioned Strategy of 2008. They further recognised the nature reserve, and forms part of a wild-life/open space corridor running between Rayleigh Weir and fierce opposition to its inclusion by local Leigh-on-sea. They felt that the council was carrying out a very low-key consultation process rather residents and leisure users of the Daws Heath than genuinely attempting to gain the views of the wider population in the Borough. area.

A local meeting called to discuss the proposed building was very well attended and a group was We feel that the Core Strategy is sound in that chosen to represent the Daws Heath population. As a result a vigorous campaign to defend the local the site was removed on the basis of research green belt ensued. A high proportion of residents over the wider area of Daws Heath displayed and fact finding during the consultation period posters for over a year and indeed many of those posters remain visible in the local area. A web site and the involvement of the local community in www.handsoffourgreenbelt.co.uk/ and a regular newsletter ensured that local people were alerted to bringing about a change in line with Council meeting dates and these meetings were well attended. The local press printed many overwhelming public opinion. articles. Two petitions containing 700 and 2000 signatures respectively were presented to the Council and one was presented to Parliament by our MP, Bob Spink. The group has had the continued support from Bob Spink throughout the campaign. The strength of feeling against the development was, and remains, high. I enclose a selection of the articles printed by The Evening Echo on this subject.

In addition the group, along with other bodies, carried out their own assessment of the greenbelt land using the criteria that were used by the Council. A full copy of our assessment is enclosed with this letter for your information. We believe you will see that the original assessment by the authority was fundamentally flawed and has several serious omissions and errors.

The Chief Planning Officer and the Chief Executive of the Council invited the group on two occasions to discuss the views of the residents and the group was invited to address the Council. At one of these meetings we presented our assessment of the greenbelt area and had a detailed discussion with the officers. As a result, this area of land, whilst not being fully removed from the Core Strategy, had its proposals for development substantially changed from residential and industrial use to 3 hectares of industrial use including the Fire Station, which was already built.

This final version of the Core Strategy was put before the Council with the changed development plan for the land. The residents campaign group, whilst still unhappy with development of greenbelt land in any format, felt that the document was more balanced and did maintain most of the greenbelt Page 80 of 222

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area. The document was voted in by the council.

The group have since learned of a meeting, which has taken place between Barratts and representatives of Castle Point Borough Council prior to the submission of a planning application for the area East of Rayleigh Road. The group do not know the details of this plan and therefore cannot comment specifically but the attached re-scoring report, which was the group's response to the original building proposals, should be broadly relevant to any new proposed development.

The group has heard from Councillors that Barratts recognise local opposition as very potent and have, over the Christmas period, instigated a market research operation designed to elicit responses from unsuspecting residents to further their cause. Residents will not have realised that their responses to general questions such as ‘Do you think there is sufficient affordable housing in Castle Point?' may be used to counter local objections to the building plans at Rayleigh Road East. Barratts have the resources to gain an advantage from the local farmers and to manipulate public opinion in order to effect a development which local people and a majority of their elected representatives do not support. Local democracy and our environment are under threat from big business.

We the HOOGB action group are strongly opposed to greenbelt land being used for development when other options are available. Indeed, since the Council carried out a survey of brownfield sites there has been a sharp economic downturn, which has lead to the demise of businesses and the consequent availability of extra sites for building. This is especially evident in Hadleigh Town centre, which is sorely in need of rebuilding projects, and offers easy access to good transport links, schools, shops, employment and medical services. We enclose a copy of our review of the scoring carried out by CPBC for this area of land showing our comments and reasoning why we felt the original scoring was incorrect.

The group can only hope that, in your capacity as the appointed inspector, you will carefully consider the residents' arguments and take a walk around not only the sites involved but also those close by, since developments will affect the semi-rural nature of the wider area. If this walk is taken in the winter months please imagine how our rural area looks in the other more attractive seasons of the year. We ask that you take due consideration of the feelings of the residents when reviewing the CS document, and hope you give the valuable areas of greenbelt within the Daws Heath area the protection they deserve by endorsing the document before you.

David Head

Chair of the Hands off the Greenbelt Group.

9 th January 2010 51 Table 4 Mr Barry Brazier U J It is proposed to develop land to the north of Kiln Road to provide about 250 new homes. W This consultee objects to the development of Greenfield land to the North Spatial Distribution of of Kiln Road. The primary objection is with regard to Wildlife Conservation, Regeneration and as there is a Local Wildlife Site designation covering this area. As a result, It is contended that this proposal is NOT JUSTIFIED, on the grounds that it is not the most Growth it is contended that the Sustainability Assessment of Sites on the Urban appropriate strategy when considered against reasonable alternatives. Periphery is incorrect in the score assigned to this development location.

Appendix D to an earlier consultation, ("Core Strategy Further Preferred Options Report 2007- The initial assessment was subject to consultation in 2008. As a result of 2021"), set out a Summary of Assessment of Locations against Sustainability Criteria. this, a revised assessment was carried out in 2009 that included weighting. Weighting was determined by the results of a citizens panel survey. Issues Whilst the tabulated form of these results was extremely clear and informative, it was apparent that of nature conservation were considered to be important to these the assessments entered against the criteria for each site were in some cases somewhat subjective consultees, and as a result nature conservation was weighted heavily. As a and inconsistent. result, the site to the North of Kiln Road did not score highly, however, it did score well in terms of many other criteria including access to town centre, access to services, and access to the public transport network. It was I commented on three specific examples. In each case I indicated the Core Strategy assessment, therefore considered appropriate to seek a smaller development than that followed on the line below with my assessment. proposed by the developer in this location - reducing the impact on the natural environment. The Core Strategy is therefore justified in including I included these examples to demonstrate how easily the results of such subjective assessment can land to the North of Kiln Road within the Core Strategy for the development vary when considered by different people. of 250 dwelling units.

In particular, I contended that development of land north of Kiln Road was not "neutral" in It is recognised that the Local Wildlife Site covers a substantial area North comparison to the Sustainability Criteria (as suggested by the Council's assessment), but among the of Kiln Road, whilst the development site is restricted to an area identified most harmful of all sites suggested, scoring a revised total of -6. for long-term housing to the East of this location.

I particularly drew attention to the following disagreements with the Core Strategy assessments - An application was made for this site in 2004/5. The Council were minded to approve the application subject to the submission of detailed ecological assessment. The results of this assessment were not submitted to the Assessment b - (Makes the best use of previously developed land, preferably within the existing Council until 2009. urban area, and protects open land from development) - this is not previously developed land, rather

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than protecting open land, actually develops it. The assessment submitted was very detailed, and indicated that a proportion of the site could reasonably be developed without harm to the Local Wildlife Site. Other areas could not be developed because of their Assessment d - (Contributes towards improvements in infrastructure and community facility provision wildlife interest. in the wider area for the wider community, where appropriate) - developing 310 houses in this location will do nothing towards improving infrastructure, rather will contribute to overloading transport, utility service and school infrastructure. Proposed "local centre" is unlikely to be viable As a result of this, Barratts have pursued development of a smaller given other local existing provision. It is noted that in this latest Final Publication Document, the proportion of the site, submitting an application in 2009. Opportunities have proposal is to provide 250 dwellings and there is no reference to a "local centre". been left to further develop other areas of the site that are not of nature conservation interest. The capacity of the site has been reduced from 310 to 250 as a result of the findings of the ecological surveys. Assessment f - (Supports the vitality and viability of local town centres) - is unlikely to support local town centre, more likely to access larger remote centres owing to semi-remote location (of this site) from local centres. The inclusion of this site, on the bases of the reduced capacity, is therefore consistent with PPS9, as protection of the natural environment has been afforded by this distribution. PPS9 is clear that the level of protection Assessment i - (Avoids, reduces and/or manages flood risk and the risks posed by climate change) - offered to nature conservation should be consistent with its designation. developing this Greenfield land will have a negative impact with regard to the risks posed by climate change. The consultee suggests that the removal of this site from the housing supply would leave a sufficient supply to meet the housing need of 5,000 Despite this, the Core Strategy still contains the proposal to develop this land, albeit now with "about units. It's removal would however make the Core Strategy inconsistent with 250" new homes in lieu of the total of 310 dwellings and a "local centre" previously intended. PPS3 because the identified supply would not be sufficiently flexible - this would also make the Core Strategy inconsistent with PPS12. It is acknowledged that this land was allocated in the 1997 Local Plan as "land safeguarded for long- term housing needs". However, this allocation was made over twelve years ago in accordance with a As a result, it is considered that the distribution identified in the Core recommendation of the Inspector following the Examination in Public into the Local Plan. In the Strategy is justified, and therefore the site to the North of Kiln Road should resultant Policy H5 the proviso was made that "until such time as reviews of the structure plan and not be removed as suggested by this consultee. local plan show that the land needs to be released for housing, the land would be kept free of development which would prejudice later comprehensive treatment. Valuable landscape and wildlife features will be protected" . Clearly the intention of the Inspector was to retain this land as undeveloped until it was demonstrated that release for housing became necessary or unavoidable.

Times have moved on since then, including the issue of various Planning Policy Statements. I believe that greater emphasis is now placed on conserving the natural environment and biodiversity than was in earlier policy guidance.

I believe that the housing requirements for the plan period can be met without releasing this land for development.

The total number of homes proposed under this Core Strategy is stated as 5,261, as compared to the requirement of 5,000. Without releasing this land a total of 5,011 would remain. Whilst acknowledging that this leaves little margin for failure of delivery of all remaining sites, I believe it is easily possible to make additional provision for housing delivery within the South Benfleet and Tarpots town centres in conjunction with the regeneration of these local area centres. I refer in separate Responses to the failure in this proposed Core Strategy to provide for the regeneration of these centres. Alternative locations for the required housing delivery are therefore available within the previously developed urban area.

This land is a pristine, classic "Greenfield" area and is situated largely on a Local Wildlife Site (LoWS) as identified in the Castle Point Wildlife Site Review documents.

The Castle Point Wildlife Site Review 2007, as listed in Appendix C "Robust Evidence Base" of the Document, describes this Wildlife Site CP23 as follows;

This Site has been identified in order to highlight the value of the last remaining contiguous blocks of old plotland habitat north of Kiln Road in Thundersley. By their very nature they represent a cross- over between old rural gardens and the open countryside and they exemplify the type of habitat targeted by the urban habitats Local BAP, providing a green "oasis" within an increasingly urbanised surrounding. ... They ensure that wildlife is still close at hand in east Thundersley as well as helping to provide the last tangible wildlife corridor linking the open spaces of Daws Heath to the east and the Thundersley Glen/Coombe Wood corridor to the west.

If this land is released for development, the residue of this Wildlife Site will become severely degraded, to the point of total destruction, not only by the direct loss of most of the habitat, but also by the pressure imposed upon the residue by the neighbouring new development.

I draw particular attention to the following statements contained in the current Core Strategy Final Publication Document which relate to the intention to protect biodiversity (wildlife) sites from development;

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• a) "Due to the extent of the natural environment in Castle Point and the protection afforded to it by ... PPS 9 ... Biological (sic) and Geological Diversity are both highly relevant in Castle Point ..." - paragraph 2.2.

• b) Appendix C contains a list of "robust evidence" to inform and develop "robust policies" - paragraph 2.27. This evidence includes in Table 32 the Castle Point Wildlife Site Reviews of 2002 and 2007 which describe the Local Wildlife Site concerned.

• c) The Spatial Portrait of Castle Point describes the Borough's role in the Sub-region as a "green area forming a central location in the sub-regional network of green spaces" - table 2 - Role in the sub-region.

• d) This portrait also refers to the natural environment having a "network of local wildlife sites which are distinctive to the local landscape" which thread together the SSSI, SPA and Ramsar sites - table 2 - Natural Environment.

• e) The spatial vision for Castle Point contains the statement that "The natural ... environment will be well managed ... supporting a range of high quality habitats" - paragraph 4.3 - fourth paragraph.

• f) The Core Strategy Aims and Objectives include the objective to "Ensure that new development makes prudent and efficient use of land and natural resources, and that infrastructure is sufficient to prevent harm to the natural environment" - table 3.

• g) The Core Strategy Aims and Objectives include the objective to "conserve and enhance local landscape character and biodiversity assets" - table 3.

• h) The Principles of Sustainable Development and Growth state that PPS1 is clear that the most appropriate way of achieving sustainable development is to achieve a balance between development and environmental protection. - paragraph 5.4.

• i) It is also stated that new homes are delivered ... with limited impact on the natural environment. - paragraph 5.6.

• j) This section also states that the area has a "mosaic of habitats ... that need protecting from development" and that "sites of nature conservation interest are protected and enhanced" - paragraph 5.9.

• k) The table setting out proposals for "Spatial Distribution of Regeneration and Growth" contain the statement that "Sites of ecological importance will be protected and enhanced" - table 4.

• l) The proposals for Green infrastructure state that "the Core Strategy will aim to maintain, enhance, restore or add to biodiversity ... conservation interests. Developments that would result in significant harm to biodiversity ... interests will not be permitted ..." - paragraph 6.11. "Care should be taken to avoid development that may harm the ... grassland habitats across the Borough" - paragraph 6.12. The text suggests that, although these aims relate specifically to Living Landscapes, the principle should apply "across the Borough" - paragraph 6.12

• m) Policy CP2 contains the proposal to work with partner organisations to "Work together to conserve and enhance nature conservation ... assets to ensure targets for ... biodiversity protection ... are achieved".

• n) Reference is made within table 19 Local Design Context (final category -Biodiversity) to the "range of habitats including woodland, grassland and marshland habitats" and the Objective is stated to "minimise loss of natural habitats" - table 19, objective 13.

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been identified against strict criteria ... These sites sit between a number of sites of European and national importance and therefore support these significant wildlife locations. To this end, the Council will extend a high level of protection to these sites and resist developments that will cause adverse impacts that cannot be neutralised through mitigation or compensation. The importance of LoWS is recognised by NI 197 ... This indicator forms part of the Borough's Local Area Agreement ... and protection of LoWS from the adverse effects of development is important ..." - paragraph 13.17.

• p) Policy DC15 - 2 states that "Local Wildlife Sites (LoWS) must not be subject to significant adverse impacts as a result of development proposals".

• q) The "Monitoring and Implementation" section sets out targets for monitoring the Development Control Policies. Included in table 21 is a target to have an area covered by Local Wildlife Site designation of "at least 671.7 ha". This equates to the total of all those sites contained in the Wildlife Site Review 2007, INCLUDING the area to be lost to the proposed development of "about 250" homes to the north of Kiln Road.

It is clear from the above that the Core Strategy proposed for adoption sets out positive intention to preserve Local Wildlife Sites. It is equally clear that to develop this land for housing is contrary to this stated intention. The proposed Core Strategy is therefore inconsistent with itself.

There is no need to release this land for housing as alternative locations within the urban area are available (as stated earlier) to meet any shortfall in the identified overprovision (5,011) of housing sites as compared to the stated requirement of 5,000.

A Planning Application to develop this land was submitted in 2004 to build 310 homes and has never been determined. One of the concerns reported to the Planning Committee at that time was that "biodiversity issues" needed to be resolved and that failure to resolve these issues would give rise to a recommendation for refusal. To date no resolution of these biodiversity issues has been achieved, demonstrating that it is not possible to develop this land without causing major harm to the natural environment. A fresh Planning Application was submitted in 2009 to build 150 homes on part of the land. Natural England have responded to this Application stating that "the loss of a County Wildlife Site on this scale cannot be mitigated".

This proposal, to build "about 250" homes on land north of Kiln Road, Thundersley, must therefore be deleted from the Core Strategy Policy SS2. The land should be re-designated as Green Belt to safeguard the conservation interests for future generations. 52 Table 4 Mr Barry Brazier U E It is proposed to develop land to the north of Kiln Road to provide about 250 new homes. W This consultee objects to the development of Greenfield land to the North Spatial Distribution of of Kiln Road. The primary objection is with regard to Wildlife Conservation, Regeneration and as there is a Local Wildlife Site designation covering this area. It is contended that this proposal is NOT EFFECTIVE, on the grounds that National and Regional Growth Planning barriers relating to biodiversity conservation take precedence. In particular, The Local Wildlife Site covers a substantial area North of Kiln Road, whilst the development site is restricted to an area identified for long-term PPS9 contains in its "Key Principles" at point (vi) a series of sequential tests to which local planning housing to the East of this location. authorities should adhere. I believe that this proposal fails the first of these tests and the intention to develop this land should therefore be deleted from the Core Strategy . An application was made for this site in 2004/5. The Council were minded to approve the application subject to the submission of detailed ecological "(vi) The aim of planning decisions should be to prevent harm to biodiversity ... interests. Where assessment. The results of this assessment were not submitted to the granting planning permission would result in significant harm to those interests, local planning Council until 2009. authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm." The assessment submitted was very detailed, and indicated that a proportion of the site could reasonably be developed without harm to the It is acknowledged that this land was allocated in the 1997 Local Plan as "land safeguarded for long- Local Wildlife Site. Other areas could not be developed because of their term housing needs". However, this allocation was made over twelve years ago in accordance with a wildlife interest. recommendation of the Inspector following the Examination in Public into the Local Plan. In the resultant Policy H5 the proviso was made that "until such time as reviews of the structure plan and local plan show that the land needs to be released for housing, the land would be kept free of As a result of this, Barratts have pursued development of a smaller development which would prejudice later comprehensive treatment. Valuable landscape and wildlife proportion of the site, submitting an application in 2009. Opportunities have features will be protected" . Clearly the intention of the Inspector was to retain this land as been left to further develop other areas of the site that are not of nature undeveloped until it was demonstrated that release for housing became necessary or unavoidable. conservation interest. The capacity of the site has been reduced from 310 to 250 as a result of the findings of the ecological surveys. Times have moved on since then, including the issue of various Planning Policy Statements. I believe that greater emphasis is now placed on conserving the natural environment and biodiversity The inclusion of this site, on the bases of the reduced capacity, is therefore than was in earlier policy guidance. consistent with PPS9, as protection of the natural environment has been afforded by this distribution. PPS9 is clear that the level of protection offered to nature conservation should be consistent with its designation. I believe that the housing requirements for the plan period can be met without releasing this land for

The consultee suggests that the removal of this site from the housing Page 84 of 222

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development. supply would leave a sufficient supply to meet the housing need of 5,000 units. It's removal would however make the Core Strategy inconsistent with PPS3 because the identified supply would not be sufficiently flexible - this The total number of homes proposed under this Core Strategy is stated as 5,261, as compared to would also make the Core Strategy inconsistent with PPS12. the requirement of 5,000. Without releasing this land a total of 5,011 would remain. Whilst acknowledging that this leaves little margin for failure of delivery of all remaining sites, I believe it is easily possible to make additional provision for housing delivery within the South Benfleet and As a result, it is considered that the distribution identified in the Core Tarpots town centres in conjunction with the regeneration of these local area centres. I refer in Strategy is consistent with national policy, and therefore the site to the separate Responses to the failure in this proposed Core Strategy to provide for the regeneration of North of Kiln Road should not be removed as suggested by this consultee. these centres. Alternative locations for the required housing delivery are therefore available within the previously developed urban area, which if developed would result in no harm to biodiversity interests.

This land is a pristine, classic "Greenfield" area and is situated largely on a Local Wildlife Site (LoWS) as identified in the Castle Point Wildlife Site Review documents.

The Castle Point Wildlife Site Review 2007, as listed in Appendix C "Robust Evidence Base" of the Document, describes this Wildlife Site CP23 as follows;

The East of England Regional Policy 2008 states in its "Visions and Objectives" the Objective ((v) third bullet) "To improve and conserve the region's environment by: protecting and where appropriate, enhancing biodiversity through the protection of habitats and species ..."

Policy ENV3 specifically requires Planning Authorities to ensure that the region's wider biodiversity is protected by ( inter alia) " ensuring that new development minimises damage to biodiversity ... by avoiding harm to local wildlife sites ..."

Providing housing on this site will destroy the existing habitat of this Local Wildlife Site.

The proposal is clearly contrary to The East of England Plan 2008 "Visions and Objectives".

• e) The spatial vision for Castle Point contains the statement that "The natural ... environment will be well managed ... supporting a range of high quality habitats" -

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paragraph 4.3 - fourth paragraph.

• g) The Core Strategy Aims and Objectives include the objective to "conserve and enhance local landscape character and biodiversity assets" - table 3.

• i) It is also stated that new homes are delivered ... with limited impact on the natural environment. - paragraph 5.6.

• k) The table setting out proposals for "Spatial Distribution of Regeneration and Growth" contain the statement that "Sites of ecological importance will be protected and enhanced" - table 4.

• o) The "Landscape and Natural Features" section contains the following statements; • i) "the Council will ensure that appropriate weight is attached to designated sites of ... local importance;" - paragraph 13.16. • ii) "At the local level Local Wildlife Sites (LoWS) have been identified. These sites have been identified against strict criteria ... These sites sit between a number of sites of European and national importance and therefore support these significant wildlife locations. To this end, the Council will extend a high level of protection to these sites and resist developments that will cause adverse impacts that cannot be neutralised through mitigation or compensation. The importance of LoWS is recognised by NI 197 ... This indicator forms part of the Borough's Local Area Agreement ... and protection of LoWS from the adverse effects of development is important ..." - paragraph 13.17.

• p) Policy DC15 - 2 states that "Local Wildlife Sites (LoWS) must not be subject to significant adverse impacts as a result of development proposals".

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stated intention. The proposed Core Strategy is therefore inconsistent with itself.

This proposal, to build "about 250" homes on land north of Kiln Road, Thundersley, must therefore be deleted from the Core Strategy Policy SS2. The land should be re-designated as Green Belt to safeguard the conservation interests for future generations. 53 Table 4 Mr Barry Brazier U N It is proposed to develop land to the north of Kiln Road to provide about 250 new homes. W This consultee objects to the development of Greenfield land to the North Spatial Distribution of of Kiln Road. The primary objection is with regard to Wildlife Conservation, Regeneration and as there is a Local Wildlife Site designation covering this area. It is contended that this proposal is NOT CONSISTENT WITH NATIONAL POLICY, on the grounds Growth that National and Regional Planning policies relating to biodiversity conservation take precedence. The Local Planning Authority has given NO REASONING to justify their departure from National and The Local Wildlife Site covers a substantial area North of Kiln Road, whilst Regional policy. In particular, the development site is restricted to an area identified for long-term housing to the East of this location. PPS9 contains in its "Key Principles" at point (vi) a series of sequential tests to which local planning authorities should adhere. I believe that this proposal fails the first of these tests and the intention to An application was made for this site in 2004/5. The Council were minded develop this land should therefore be deleted from the Core Strategy . to approve the application subject to the submission of detailed ecological assessment. The results of this assessment were not submitted to the Council until 2009. "(vi) The aim of planning decisions should be to prevent harm to biodiversity ... interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any The assessment submitted was very detailed, and indicated that a alternative sites that would result in less or no harm." proportion of the site could reasonably be developed without harm to the Local Wildlife Site. Other areas could not be developed because of their wildlife interest. It is acknowledged that this land was allocated in the 1997 Local Plan as "land safeguarded for long- term housing needs". However, this allocation was made over twelve years ago in accordance with a recommendation of the Inspector following the Examination in Public into the Local Plan. In the As a result of this, Barratts have pursued development of a smaller resultant Policy H5 the proviso was made that "until such time as reviews of the structure plan and proportion of the site, submitting an application in 2009. Opportunities have local plan show that the land needs to be released for housing, the land would be kept free of been left to further develop other areas of the site that are not of nature development which would prejudice later comprehensive treatment. Valuable landscape and wildlife conservation interest. The capacity of the site has been reduced from 310 features will be protected" . Clearly the intention of the Inspector was to retain this land as to 250 as a result of the findings of the ecological surveys. undeveloped until it was demonstrated that release for housing became necessary or unavoidable. The inclusion of this site, on the bases of the reduced capacity, is therefore Times have moved on since then, including the issue of various Planning Policy Statements. I consistent with PPS9, as protection of the natural environment has been believe that greater emphasis is now placed on conserving the natural environment and biodiversity afforded by this distribution. PPS9 is clear that the level of protection than was in earlier policy guidance. offered to nature conservation should be consistent with its designation.

I believe that the housing requirements for the plan period can be met without releasing this land for The consultee suggests that the removal of this site from the housing development. supply would leave a sufficient supply to meet the housing need of 5,000 units. It's removal would however make the Core Strategy inconsistent with PPS3 because the identified supply would not be sufficiently flexible - this The total number of homes proposed under this Core Strategy is stated as 5,261, as compared to would also make the Core Strategy inconsistent with PPS12. the requirement of 5,000. Without releasing this land a total of 5,011 would remain. Whilst acknowledging that this leaves little margin for failure of delivery of all remaining sites, I believe it is easily possible to make additional provision for housing delivery within the South Benfleet and As a result, it is considered that the distribution identified in the Core Tarpots town centres in conjunction with the regeneration of these local area centres. I refer in Strategy is consistent with national policy, and therefore the site to the separate Responses to the failure in this proposed Core Strategy to provide for the regeneration of North of Kiln Road should not be removed as suggested by this consultee. these centres. Alternative locations for the required housing delivery are therefore available within the previously developed urban area, which if developed would result in no harm to biodiversity interests.

This land is a pristine, classic "Greenfield" area and is situated largely on a Local Wildlife Site (LoWS) as identified in the Castle Point Wildlife Site Review documents.

The Castle Point Wildlife Site Review 2007, as listed in Appendix C "Robust Evidence Base" of the Document, describes this Wildlife Site CP23 as follows;

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old plotland habitat north of Kiln Road in Thundersley. By their very nature they represent a cross- over between old rural gardens and the open countryside and they exemplify the type of habitat targeted by the urban habitats Local BAP, providing a green "oasis" within an increasingly urbanised surrounding. ... They ensure that wildlife is still close at hand in east Thundersley as well as helping to provide the last tangible wildlife corridor linking the open spaces of Daws Heath to the east and the Thundersley Glen/Coombe Wood corridor to the west.

Providing housing on this site will destroy the existing habitat of this Local Wildlife Site.

The proposal is clearly contrary to The East of England Plan 2008 "Visions and Objectives".

• g) The Core Strategy Aims and Objectives include the objective to "conserve and enhance local landscape character and biodiversity assets" - table 3.

• i) It is also stated that new homes are delivered ... with limited impact on the natural environment. - paragraph 5.6.

• j) This section also states that the area has a "mosaic of habitats ... that need protecting from development" and that "sites of nature conservation interest are protected and Page 88 of 222

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enhanced" - paragraph 5.9.

• k) The table setting out proposals for "Spatial Distribution of Regeneration and Growth" contain the statement that "Sites of ecological importance will be protected and enhanced" - table 4.

• p) Policy DC15 - 2 states that "Local Wildlife Sites (LoWS) must not be subject to significant adverse impacts as a result of development proposals".

The Local Planning Authority has provided no justification for setting aside National and Regional policy in respect of biodiversity conservation.

This proposal, to build "about 250" homes on land north of Kiln Road, Thundersley, must therefore be deleted from the Core Strategy Policy SS2. The land should be re-designated as Green Belt to

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safeguard the conservation interests for future generations in accordance with the spirit of PPS9 and East of England Regional Policy 2008. 54 Table 4 Mr Barry Brazier U E It is proposed to develop land to the north of Kiln Road to provide about 250 new homes. W The County Highways Authority have not objected to the inclusion of the Spatial Distribution of site to the North of Kiln Road in the Core Strategy on highways grounds. Regeneration and Furthermore, they did not object to the Planning Application for this It is contended that this proposal is NOT EFFECTIVE as there is no sound infrastructure delivery Growth proposal, subject to contributions towards highway improvements in the planned. vicinity of the site. The Core Strategy is therefore deliverable and effective in terms of including this site in the distribution of development. Access to and egress from the proposed development can only reasonably be via the A13, Kiln Road. This is a single carriageway road currently subject to a 40 mph speed limit. This road is a major local distributor road, carrying a large amount of commuter traffic during peak hours, There are major traffic bottlenecks to the west (Tarpots - Sadlers Farm) and to the east (Hadleigh town centre). The other busy exit route from this part of Thundersley (A129, Rayleigh Road northwards from the Victoria House roundabout) is also heavily congested during peak hours. Although it might be possible to provide another access northwards from the proposed housing site, via The Chase, this would only give access to the congested Rayleigh Road, achieving no benefit regarding the easing of traffic flows.

The A13, Kiln Road, is also a major route giving access to King John school (a large comprehensive school with an integral sixth form college) and to the SEEVIC sixth form college which has approaching 1,000 students travelling from a wide region.

At times, the entire road network comes to a standstill, due to sheer volume of traffic. One incident, or a set of roadworks, can (and does) cause chaos.

The Core Strategy proposes NO infrastructure improvements to deal with the current local problems. Additional peak hour traffic generated by an additional 250 homes, discharging onto the A13 and A129 will exacerbate the problems.

No major housing development should be sited where there is no easy access and egress.

This is the wrong location for a major housing development unless significant road infrastructure improvements are implemented in advance. Bearing in mind the existing constraining traffic bottlenecks to the west (Tarpots - Sadlers Farm) and to the east (Hadleigh town centre), together with the overloaded Rayleigh Road northwards to the A127, it is impossible to visualise a solution.

This proposal to develop land to the north of Kiln Road to provide about 250 new homes should therefore be deleted from the Core Strategy 57 Table 4 Mr Barry Brazier U E It is proposed to develop a community hub on public land and adjacent vacant land to the north of W The land proposed for the creation of a community hub North of Kiln Road Spatial Distribution of Kiln Road to deliver a wide range of community and leisure services. is currently identified as a College and as Local Government on the Regeneration and Proposals Map. A significant part of this site is already developed providing Growth leisure, council offices and a college, however one field remains open and It is contended that this proposal is NOT EFFECTIVE as a regulatory barrier may arise preventing is currently used by students and employees of the Council during summer development of the proposed site. months for siting out. There is the potential for this field to be used to provide a healthcare centre for Thundersley. It is recognised that this will This intention is laudable, but the location for this is crucial. The only "public land" obviously result in the loss of a field, however, a further field to the north of this is identifiable in this area is the open land to the rear of the Council Offices, known as Runnymede identified in the local plan as public open space. The Council intend to Paddocks. retain the allocated public open space.

Since previous Responses to draft Core Strategy consultations were submitted, an Application has This consultee has made an application to the County for the two fields been made under The Commons Act 2006 to register this land as a new Town or Village Green. This referred to above to be granted village green status. The Council is Application has now been publicised and the legal process of considering the matter is on-going. contending the application for the southern most field, given its use as set Should the Application be granted, it would appear that no building will be able to be carried out on out above is not consistent with the requirements of this legislation. this "public land". Therefore, the feasibility of developing this facility on this land remains in doubt. It is recognised that town centres are good locations for community Furthermore, vacant land to the east of Runnymede Paddocks is included within the Local Wildlife services, however it is not practical to relocate the current facilities at the Site CP23, whilst that to the north is Local Wildlife Site CP16. All of this land falls within the current Kiln Road Site to a town centre. The development of stronger links Green Belt. Therefore, Planning policy (local, regional and national) may also be a barrier to any between the existing facilities is therefore essential, and the provision of a proposal to build a community hub in this location. healthcare centre would compliment existing facilities well.

Alternative, better, locations for this Community Hub are available. The Core Strategy is therefore considered sound in proposing a community hub North of Kiln Road. The Spatial Portrait of Castle Point refers, in table 2 (Healthcare facilities), to the intention to provide a new healthcare facility located in the "Thundersley/Hadleigh area". Paragraph 6.3 states that "Community facilities should be located in town centres or other accessible locations to maximise community access and build a sense of local community identity." I would suggest that the town centre regeneration of Hadleigh provides an ideal opportunity to locate this much needed facility in a town centre. Possible sites include the former (now vacant) fire station, the vacant "Crown" public Page 90 of 222

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house, the vacant former Land Rover and car showroom opposite the vacant fire station, and the existing bus depot at Victoria House Corner which would be better re-located to an employment area. Other parts of Hadleigh are also in need of re-generation and this facility could provide a focus for inward investment into the town centre.

To build this community facility remote from a town centre will not contribute towards building "a sense of local identity" as called for in paragraph 6.3 of the Core Strategy. A revised location in a town centre should be selected. This would overcome any uncertainty concerning the feasibility of building this Community Hub on land to the rear of the Council offices and adjacent Green Belt Local Wildlife Sites. 60 Table 4 Mr Jonathan U J I don't believe that the target of 4000 homes to be built in the borough before 2026 is either justified W The East of England Household Growth Model prepared by Anglia Spatial Distribution of Pinnock or sustainable. The current demonstrated strain on local infrastructure, especially the road network Polytechnic University to inform the East of England Plan projected that Regeneration and which is very regularly congested, should have provided a clear indication that Castle Point cannot 3,800 homes would be required in Castle Point to meet housing need by Growth cope with any additional housing. I haven't seen any evidence from the East of England Authority to 2021. New sub-national population projections based on 2006 data support their demand on the local authority to build 4000 homes in this period. suggest that the population of Castle Point will increase to around 98,000 by 2026. There is therefore a need to provide around 4,000 homes in the period 2001 to 2021 to meet housing needs, and ensure that demand does Furthermore, I believe that the Green Belt within the borough should be protected from any not outstrip supply to the detriment of local people earning local wages. development as it is a highly valuable asset which cannot be recovered once developed. There is The Core Strategy is therefore justified in seeking to deliver the quantum of insufficient justification in the Strategy to support any development in our local Green Belt and even development set out in the East of England Plan. if it were proven justifiable, the Strategy should demand that all possible brownfield sites should be utilised before any consideration is given to developing on the Green Belt. It is recognised that this increased housing will have an impact on infrastructure, and therefore infrastructure policies are set out in the Core Strategy - policies CP1 - CP4.

With regard to the need for Green Belt development, the SHLAA, supported by street level surveys, demonstrates that it is not possible to meet the housing requirement in the Urban Area. The urban area is tightly bound by the Green Belt, and as a result, it is necessary to therefore consider how Green Belt locations can be used to contribute towards housing supply without affecting the strategic function they play. It is considered that the Core Strategy is sound in identifying Green Belt development locations that do not affect the overall strategic function of the Green Belt. 208 Table 4 Miss Carrie Williams U N We feel that the Core Strategy is also not consistent with national policy set out in PPS3 because W We would prefer written representations, but will The Council note that the Environment Agency is generally supportive of Spatial Distribution of The Environment Policy H1 might not be able to demonstrate the delivery of a flexible supply of land for housing if any happily attend the EiP at the Inspector's (or the findings of the sequential test undertaken in accordance with PPS25. Regeneration and Agency of the Flood Zone 3 sites are found to be undeliverable and undevelopable, for example, on the Council's) request. The Environment Agency were consulted throughout the preparation of this Growth grounds of safety. assessment.

In order to make this document sound, an exploration of the reasonable alternatives for housing Nonetheless a query is raised as to deliverability of the plan as a result of should be included to ensure the flexibility of the housing supply in the borough. the potential for development locations in Flood Risk Zone 3 becoming undeliverable. The Council is confident that landowners are willing to deliver their development proposals, and therefore from the perspective of In addition, PPS25 requires new development to be steered to those areas of lesser flood risk this consultee, the issue of flood risk management is a concern. Policy CP5 where sites are reasonably available. The PPS25 Sequential Test document that supports this Core sets out how the Council will deal with flood risk management as part of Strategy clearly indicates a number of sites in Flood Zone 1 that are deemed to be reasonably development proposals. This has been further enhanced as a result of this available but these have not been included in this policy. consultation to include reference to community refuges. The Council is therefore confident that with additional work with emergency planners that In order to make this document sound, the reasons for omitting these sites should be clearly stated the development locations on Canvey Island are deliverable in terms of and fully justified by the evidence. flood risk management. Furthermore, the Core Strategy contains flexibility in terms of the total housing supply planned for.

Reasonable alternatives were given consideration during earlier rounds of consultation on the Core Strategy. It is not therefore necessary to include a discussion of these in the final document.

As a result, the Council believes that the distribution of development identified in the Spatial Strategy can be delivered and is therefore consistent with the requirements of PPS3 and PPS12. The Core Strategy is therefore considered to be sound with regard to the issues raised by this consultee. 87 Community Mr Richard Inman U E We recommend that you reconstruct the paragraph to make clear the link between developer W Minor Amendment to paragraph 6.2 page 30. Infrastructure GO-East contributions, the schedule of infrastructure (Table 5) and the mechanism for calculating/collecting Page 91 of 222

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contributions, as detailed in Policy MI3. 17 Policy CP 1 Helen De La Rue U E Provision of local facilities for culture and leisure should be addressed on an appropriate scale to E This policy seeks the improvement of leisure provision in the Borough. It Delivering Community East of England accommodate current and future communities. also seeks the retention of community buildings, including community halls, Infrastructure Regional Assembly which provide space for cultural activities. The policy therefore responds to these aspects of community infrastructure. 88 Policy CP 1 Mr Richard Inman U E The policy is comprehensive and schedules much of the infrastructure the Borough will seek. You W It is intended that the projects listed will be delivered by 2021. The projects Delivering Community GO-East may want to consider why the latest scheduled project should be complete by 2021, yet the Core listed in the second set of bullet points are expected to take longer to come Infrastructure Strategy will be dated to 2026. to fruition and may be delivered in the period up to 2026. 148 Policy CP 1 Mr Andrew Dutton MS GABRIELLE S J 1.1. Policy CP1 sets out the timetable for delivering community infrastructure and whilst it is E Persimmon Homes (Essex) ltd are the This representation relates to the phasing of land to the East of Canvey Delivering Community Persimmon Homes ROWAN recognised that there should be an emphasis on the early delivery of key community infrastructure landowners of a key site (land to the east of Road in relation to the early requirements for community infrastructure in Infrastructure Ltd PEGASUS projects, it is necessary to ensure that housing delivery also reflects this timeframe. Appendix A of Canvey Road, Canvey Island) which is an this location. The landowner seeks for the phasing in the housing trajectory PLANNING GROUP the Core Strategy Final Publication Document sets out the housing trajectory for the identified sites. integral part of the delivery of the Core Strategy, to be amended to align with the delivery of this infrastructure. Land to the East of Canvey Road is forecast to deliver only 100 houses prior to 2014, 200 houses therefore they should be included within all between 2014 -2019 and then the last 100 houses between 2019-2026. This phasing is not in relevant discussions. 400 units are identified for the East of Canvey Road. These are phased to accordance with the proposed community infrastructure delivery programme. It will be necessary to be delivered as follows: increase the initial housing delivery in order to ensure the projected community projects are

delivered in the preferred timescale. • 100 units between 2009 and 2014 1.2. Table 10 on page 63 of the document also sets out the priority for delivery of community • 200 units between 2014 and 2019 facilities and states that the timing of development to the East of Canvey Road should ensure • 100 units between 2019 and 2026. delivery of community facilities "as a priority". This would entail the early release of the land for development purposes. This phasing has not been put in place to curtail development, but to take account of the fact that this site does not currently benefit from planning 1.3. The site can make an immediate and meaningful contribution to the provision of community consent, thus delaying commencement on site during the first five years of infrastructure and it is inappropriate to consider delaying its release and related potential to realise the plan period. It is considered that delivery will not realistically commence community aspirations. There is no justification in the evidence base for that suggested phasing. on site until at least 2012, and that the delivery rate will be in the region of 40 to 50 dwelling units per annum, resulting in the phasing distribution set It is necessary to adjust the projected site delivery forecast for Land to the East of Canvey Road, out in table 23. Canvey Island in Appendix A to reflect the community infrastructure delivery as set out in Policy CP1. This adjustment to phasing will improve the effectiveness and soundness of the Core Strategy, The Council is prepared to consider amendments in the phasing of reflecting the priority assigned to the housing and community hub at page 63 of the Final Publication development on this site, if the landowner can effectively demonstrate that Document. the delivery rate will be greater than 40 to 50 dwelling units per annum. 210 Policy CP 1 Miss Carrie Williams U E We consider this Core Strategy unsound because policy CP1 is not consistent with other policies W We would prefer written representations, but will Minor amendment to policy CP1 to include requirement to design in safe Delivering Community The Environment and statements within this DPD. Policy CP5 states that the Council intends to work with the happily attend the EiP at the Inspector's (or refuge where practical. The supporting text has also been amended in this Infrastructure Agency Environment Agency in ensuring the effective implementation of the Thames Estuary 2100 Plan. The Council's) request. regard. TE2100 plan highlights the difficulties associated with evacuating Canvey Island during a breach flood event and recommends that a strategy for safe havens and floodplain management is implemented by the council. New/improved Community Infrastructure represents a good opportunity to offer safe refuge to local residents during a flood event and therefore act as a safe haven where evacuation off the Island is not achievable. Paragraph 6.35 of this Core Strategy DPD backs up this view that emergency planning will play an important role in flood risk management into the future and that places of safe refuge are likely to be required.

This policy should be amended to include the provision of safe refuge during a flood event in areas identified by the emerging Castle Point Emergency Plan in the bullet points under the paragraph beginning "Further provision of new community facilities and renewal of existing facilities..." or potentially in the following set of bullet points within policy CP1. 211 Policy CP 1 Miss Carrie Williams U J We consider this Core Strategy unsound because policy CP1 fails to capture an important aspect of W We would prefer written representations, but will Minor amendment to policy CP1 to include requirement to design in safe Delivering Community The Environment the Thames Estuary 2100 Plan recommendations. The TE2100plan highlights the difficulties happily attend the EiP at the Inspector's (or refuge where practical. The supporting text has also been amended in this Infrastructure Agency associated with evacuating Canvey Island during a breach flood event and recommends that a Council's) request. regard. strategy for safe havens and floodplain management is implemented by the council. New/improved Community Infrastructure represents a good opportunity to offer safe refuge to local residents during a flood event and therefore act as a safe haven where evacuation off the Island is not achievable. Paragraph 6.35 of this Core Strategy DPD backs up this view that emergency planning will play an important role in flood risk management into the future and that places of safe refuge are likely to be required.

This policy should be amended to include the provision of safe refuge during a flood event in areas identified by the emerging Castle Point Emergency Plan in the bullet points under the paragraph beginning "Further provision of new community facilities and renewal of existing facilities..." or potentially in the following set of bullet points within policy CP1. 301 Policy CP 1 Mr George Whatley U E Delivering Community Infrastructure W In order to expand on this submission as The evidence available does not support this representation. The first four Delivering Community Canvey Green Belt necessary. As representatives of the Canvey projects specifically listed for Canvey Island have full funding identified. Infrastructure Campaign Greenbelt Campaign, and following our Meanwhile, funding has been identified for the refurbishment of Waterside Secure financing without over demand of Developer Contributions Referendum which clearly indicated the Farm in its current location, negating the need for a new leisure centre until concerns of the community of Canvey Island at least the end of the plan period. 1. The Core Strategy does little to proactively implement schemes for Canvey Island Meanwhile, work on the Canvey Town Centre Masterplan has given Page 92 of 222

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2. This policy sets out more of a plan of intent (wish list) consideration to the need for renewing the Paddocks community hall, and potential improvements to youth centre provision and library provision in the town centre. The masterplan will be supported by an implementation 3. The policy clearly identifies issues that need to be addressed causing problems for the existing strategy to facilitate its delivery. community of Canvey Island in order to maintain the present sustainability.

As a result of a reduction in public spending, the second PCT Healthcare This policy CP1 is ineffective and clearly not deliverable due to the lack of unsecured funding. Centre for Canvey Island has been delayed in its delivery. However, due to Existing infrastructure unfortunately has been neglected and it is unsound to rely on developer health inequalities in this part of the Borough, the PCT are looking to contribution as a remedial response. ensure that it is delivered as early as possible, with completion anticipated in 2014.

As a result, policy CP1 is not over demanding on developer contributions for its delivery as stated in this representation. The main purpose of developer contributions with regard to new development will be to mitigate the impacts of growth on community infrastructure. 319 Policy CP 1 Mr Roy Lewis S E The broad approach of the Policy is supported, particularly the inclusion of the Building Schools for E Essex County Council would wish to attend the Minor Amendments to policy CP1 as requested by Essex County Council. Delivering Community Essex County the Future (BSF) proposals for the school sites within the Borough. These are key infrastructure oral part of the examination to further elaborate Infrastructure Council projects that support the Spatial Vision and Community Strategy for the Borough. In terms of delivery its representations on the Core Strategy; to of these key educational projects the current BSF programme would deliver the opening of the provide the wider sub-regional/ regional context schools as follows, for matters included within the Core Strategy; and to provide technical assistance on matters relating to delivery of County Council services. • o The new Castle View School, Canvey Island:- January, 2012. • o Cornelius Vermuyden School, Canvey Island:- January, 2012. • o The co-location of the Deanes School and Glenwood School, Thundersley:- September, 2013. • o The Appleton School, Benfleet:- September, 2013. • o The King John School, Benfleet:- September, 2013.

In addition, delivery of the Canvey Island Vocational Centre is currently programmed for September 2011. 342 Policy CP 1 Cllr U E Community Infrastructure, p.30 E As elected representatives of Castle Point Sure Start: There are three Sure Start Centres on Canvey at Northwick Delivering Community Borough Council residents, and with multiple Park School, Furtherwick Park School and Tewkes Creek Nursery. Infrastructure Martin representations made for consideration, CIIP Points relating to Community Infrastructure but not to a specific section would like to participate at the oral part of the Fit for Purpose: The Council is aware of programmes such as the Primary Tucker examination to justify and clarify the document Care Trust Programme and the Building Schools for the Future Canvey Island We are disappointed that no provision is given for Sure Start Children's Centres on Canvey Island submitted in response to the Core Strategy. programme, both of which are freeing up other sites for redevelopment. Independent Party even though two of these facilities have been provided for on the mainland. To be consistent with the However, small community halls may come forward for redevelopment. CS spatial portrait, provision should be shared equitably between Canvey Island and the mainland, The purpose of this policy is to retain these halls unless a new hall/facility is i.e. one for each area. built to replace it - at which point the hall site could be reused. The reuse of individual sites such as this is not a strategic issue and therefore should not Section 6.4, p.30 be addressed in the Core Strategy. The Core Strategy is therefore appropriate in this regard. Where there is current recognition of a requirement to replace existing community facilities, these should be specified and any alternative uses identified. If a facility is known to be unfit for purpose, Education Formula: The County Council's education formula is a separate the vision for its future most definitely should be planned for in the CS. Not to do so is inappropriate. matter and should be raised with them when such matters are consulted on in the future. However, it seems perfectly credible that the formula assumes that a 3 bedroom house would contain 2 adults and 2 children as Any future strategic programmes of infrastructure replacement (community or other) should identify this is the perfect level of occupation for such a property. Where such alternative uses for existing provision BEFORE the new provision is in place. Otherwise, any homes are over occupied it is likely that their are also such homes that are requirements necessary for the alternative use cannot be identified and provided for. This is basic under occupied nearby. The Core Strategy is therefore appropriate in planning and must be implemented to enable effective planning. relying on the County to identify schooling needs into the future.

Policy CP1: Delivering Community Infrastructure, p.31 Vocational Centre: Planning approval is currently being sought for the vocational centre with SEEVIC seeking delivery in 2011. Essex County Building Schools for the Future - Castle View School Redevelopment Council have agreed to fund the Vocational Centre, but will be seeking to realise their assets at this site once Castle View School has closed and the vocational centre has been established. The school footprint will become In principle we agree with the new development programme, but disagree with Essex County vacant, and it is the intention that this part of the site is reused for Council's education formula which calculates the number of school places required for the future. It is residential development. This is consistent with the principles of PPS1 and not credible, for example, to imply that a three bedroom home will only accommodate two adults and PPS3. The Sustainability Assessment of Sites on the Urban Periphery two children. considers this to be a suitable location for residential development given its proximity to community facilities, the town centre on Canvey, and public We believe that predictions for future need have been underestimated and will leave schools transport routes. The vast proportion of the playing field will be retained at oversubscribed, leading to children having to leave Canvey Island to be schooled elsewhere and an this site, as will the sports hall. This proposal is therefore also consistent increase of traffic on an already over stretched road infrastructure. with PPG17.

PCT Healthcare Centre: The location identified by this consultee is incorrect. The proposed location for the second healthcare centre is further Page 93 of 222

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ECC/SEEVIC/CPRP - Canvey Island Vocational Centre south on Canvey Road, adjacent to existing residential development at the Dutch Cottage and the proposed housing location to the east of Canvey Road. The proposed location is close to Cornelius Vermuyden School and We consider this project justified, and is welcomed on condition that the centre is built on the existing land will be retained in this location for a replacement sports centre. Access Castle View site ‘developed land' - not the playing fields or green belt land surrounding it. This to the site will be from Canvey Road, which is served by public transport - project has previously encountered funding issues and we are concerned that it may be contributions may be sought to improve connections to this site. undeliverable as funding could be withdrawn even if the project is approved through the planning Walking/cycling access will also provided from Third Avenue, where current process. It is reported that funding can be raised by sale of the surrounding school land proposed for healthcare facilities are located. The existing site on Third Avenue is too housing development in the CS. Public opinion suggests that the local community objects to the sale small to meet the PCTs needs. The Council has been unable to identify of this land for housing development and there is no credible evidence that challenges this view. alternative locations at West Canvey to accommodate the second PCT (industrial sites within Charfleets were considered unsuitable). Locating the PCT/LIFT - Primary Healthcare Centre at West Canvey second PCT within the town centre is also not appropriate as this is where the first PCT is located to serve the East and Central parts of the Island. The location for the PCT healthcare centre identified in the Core Strategy is This location is too far out of the community reach for Canvey Island residents and is deemed therefore appropriate based on accessibility of the site and the lack of fundamentally flawed. It is situated near the busy road intersection at Waterside roundabout, reasonable alternatives. Somnes Avenue, and Canvey Road. Residents of Castle Point will have to travel by road leading to more traffic on and around Waterside roundabout. We acknowledge the need for this facility but it is in the wrong location. Section 6.3 clearly states that ‘Community facilities should be located in town Waterside Farm Sports Centre: It is unclear as to why an objection to this centres or other accessible locations'. It is not credible to suggest that this location will ‘maximise policy has been raised. It was agreed that the word "renewal" would be community access' or ‘reduce the need for multiple journeys' and as no reasonable alternatives have used with regard to Waterside Farm in order to provide some flexibility been considered, the CS is not justified and therefore, unsound. regarding the future of the sports centre. Since this time a decision has been made to refurbish the centre, investing £1.5m and increasing its lifespan for over 10 years. The survey results were used by the Cabinet to Renewal of Waterside Farm Sports Centre make this decision (appended to the report and therefore publicly accessible), supporting the use of the word renewal in the Core Strategy. When the Castle Point Policy and Development Groups split into task and finish groups, the group responsible for leisure centres were told that a structural survey was taking place at Waterside Farm The Paddocks: As with Waterside Farm, the word renewal has been used Sports Centre. To this day there is still no evidence of the survey or results produced and we to provide some flexibility with regard to whether the community centre is therefore object to this contentious issue. The group felt they had no input into the findings and replaced or refurbished. The Cabinet, with access to surveys has recently outcomes. An amendment (from Cllr. Martin Tucker) added to the document suggesting decided to invest around £500,000 in refurbishing the community hall for refurbishment rather than renewal was accepted by the joint policy and development group, but is use in civil ceremonies, extending its lifespan. The Core Strategy is not seen within the CS. Although some engagement with councillors was made, many decisions therefore considered sound in seeking the renewal of this building. have been dismissed or ignored. We find this part of the policy unjustified because the recently commissioned structural survey of Waterside Farm sports centre has never been published for scrutiny by councillors.

Renewal of The Paddocks

The Paddocks is the community hub for Canvey Island. The building and surrounding land facilitates cultural events, shows, and clubs. It is perfectly located next to the town centre with ample parking provision for the new Primary Healthcare Centre. It is vital this facility is refurbished (not renewed) in line with Runnymede Hall on the mainland, i.e. by 2014 and not 2016 as proposed. There is no justification not to do this, proving the CS to be unsound. As no structural survey has been made on The Paddocks to suggest refurbishment is not a viable policy, then renewal is unjustified and the CS is unsound. 360 Policy CP 1 Mr Graham Bracci U E Delivering Community Infrastructure W In order to expand on this submission as The evidence available does not support this representation. The first four Delivering Community Canvey Green Belt necessary. As representatives of the Canvey projects specifically listed for Canvey Island have full funding identified. Infrastructure Campaign Greenbelt Campaign, and following our Meanwhile, funding has been identified for the refurbishment of Waterside Secure financing without over demand of Developer Contributions Referendum which clearly indicated the Farm in its current location, negating the need for a new leisure centre until concerns of the community of Canvey Island. at least the end of the plan period. 1. The Core Strategy does little to proactively implement schemes for Canvey Island Meanwhile, work on the Canvey Town Centre Masterplan has given 2. This policy sets out more of a plan of intent (wish list) consideration to the need for renewing the Paddocks community hall, and potential improvements to youth centre provision and library provision in the town centre. The masterplan will be supported by an implementation 3. The policy clearly identifies issues that need to be addressed causing problems for the existing strategy to facilitate its delivery. community of Canvey Island in order to maintain the present sustainability.

As a result of a reduction in public spending the delivery of a second PCT This policy CP1 is ineffective and clearly not deliverable due to the lack of unsecured funding. Healthcare Centre on Canvey Island has been delayed. However, due to Existing infrastructure unfortunately has been neglected and it is unsound to rely on developer health inequalities in this part of the Borough, the PCT seek to deliver this contribution as a remedial response. facility as early as possible. The PCT believe they will have this second centre complete by 2014.

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Secure financing without over demand of Developer Contributions Referendum which clearly indicated the Farm in its current location, negating the need for a new leisure centre until concerns of the community of Canvey Island. at least the end of the plan period. 1. The Core Strategy does little to proactively implement schemes for Canvey Island Meanwhile, work on the Canvey Town Centre Masterplan has given consideration to the need for renewing the Paddocks community hall, and 2. This policy sets out more of a plan of intent (wish list) potential improvements to youth centre provision and library provision in the town centre. The masterplan will be supported by an implementation 3. The policy clearly identifies issues that need to be addressed causing problems for the existing strategy to facilitate its delivery. community of Canvey Island in order to maintain the present sustainability. As a result of a reduction in public spending the delivery of a second PCT This policy CP1 is ineffective and clearly not deliverable due to the lack of unsecured funding. Healthcare Centre on Canvey Island has been delayed. However, due to Existing infrastructure unfortunately has been neglected and it is unsound to rely on developer health inequalities in this part of the Borough, the PCT seek to deliver this contribution as a remedial response. facility as early as possible. The PCT believe they will have this second centre complete by 2014.

216 Green Infrastructure Miss Carrie Williams U J Under the sub-heading "Opportunities in the Natural Environment" you fail to capture opportunities to W We would prefer written representations, but will Minor Amendment to paragraph 6.14 page 33. The Environment reduce/manage flood risk by making space for water and developing multi-functional areas of happily attend the EiP at the Inspector's (or Agency greenspace. For example, the Thames Estuary 2100 Plan has identified West Canvey Marshes as a Council's) request. potential area for habitat creation which could also offer some protection from tidal flooding in the future. Also, with the surface water drainage issues that are apparent on Canvey Island, opportunities to provide strategic drainage areas would be welcomed.

In order to make this document sound, we would suggest some additional wording in this section to capture opportunities for flood risk management and multi-functional greenspace. 218 Green Infrastructure Miss Carrie Williams U E Under the sub-heading "Opportunities in the Natural Environment" you fail to capture opportunities to W We would prefer written representations, but will Minor Amendment to paragraph 6.14 page 33. The Environment reduce/manage flood risk by making space for water and developing multi-functional areas of happily attend the EiP at the Inspector's (or Agency greenspace. For example, the Thames Estuary 2100 Plan has identified West Canvey Marshes as a Council's) request. potential area for habitat creation which could also offer some protection from tidal flooding in the future. Also, with the surface water drainage issues that are apparent on Canvey Island, opportunities to provide strategic drainage areas would be welcomed.

This section is therefore not internally consistent with paragraphs 6.38 and 6.39 on surface water flooding.

Also, paragraph 6.37 identifies that coastal squeeze will be a problem into the future and therefore opportunities to provide compensatory habitat should be highlighted in this section in order to comply with the EU Habitats Directive and also the general aims of the Thames Estuary 2100 Plan.

In order to make this document sound, we would suggest some additional wording in this section to capture opportunities for flood risk management and multi-functional greenspaces. 219 Green Infrastructure Miss Carrie Williams U E Under the sub-heading "Opportunities in the Natural Environment" you fail to capture opportunities to W We would prefer written representations, but will Minor Amendment to paragraph 6.14 page 33. The Environment reduce/manage flood risk by making space for water and developing multi-functional areas of happily attend the EiP at the Inspector's (or Agency greenspace. For example, the Thames Estuary 2100 Plan has identified West Canvey Marshes as a Council's) request. potential area for habitat creation which could also offer some protection from tidal flooding in the future. Also, with the surface water drainage issues that are apparent on Canvey Island, opportunities to provide strategic drainage areas would be welcomed.

This section is therefore not internally consistent with paragraphs 6.38 and 6.39 on surface water flooding.

In order to make this document sound, we would suggest some additional wording in this section to capture opportunities for flood risk management and multi-functional greenspaces.

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137 Policy CP 2 Mr Jonathan S E The decision not to allow major development in the vicinity of the A127/A130 junction (north of New W No response required. Protecting and Pinnock Thundersley) is welcome as it is a valued green space and should be protected as such. It will help Enhancing Green to maintain a green corridor between the borough and two other boroughs (Basildon and Infrastructure Rayleigh/Rochford). 220 Policy CP 2 Miss Carrie Williams U E AND JUSTIFIED W We would prefer written representations, but will Minor Amendment to policy CP2 to link to flood risk management and Protecting and The Environment happily attend the EiP at the Inspector's (or climate change adaptation. Enhancing Green Agency Council's) request. We consider this Core Strategy unsound because policy CP2 is not consistent with other policies Infrastructure and statements within this DPD. Policy CP5 states that the Council intends to work with the Environment Agency in ensuring the effective implementation of the Thames Estuary 2100 Plan. The TE2100plan highlights that coastal squeeze will be an issue into the future and this is also picked up in paragraph 6.37.

This policy should therefore include in the final set of bullet points wording along the lines of:

"Seek opportunities to identify areas of potential habitat creation in order to compensate for habitats lost through the process of coastal squeeze"

This policy also fails to capture opportunities to reduce/manage flood risk by making space for water and developing multi-functional areas of greenspace. This is especially important considering the surface water drainage issues identified in paragraphs 6.38 and 6.39 on surface water flooding.

This policy should therefore include in the final set of bullet points wording along the lines of:

"Identify opportunities to effectively manage flood risk by making space for water in multifunctional green spaces." 224 Policy CP 2 Petroplus Refining Miss Sally Fordham S E Policy CP2 aims to protect and enhance Castle Point's ‘Green Infrastructure'. The Green E We believe it is necessary to attend the oral part No response required. Protecting and and Marketing Drivers Jonus Infrastructure includes public open space, Sites of Special Scientific Interest (SSSI), and areas of the examination as the Coryton Oil Refinery Enhancing Green Limited (Petroplus) valued for their natural environment. complex plays the role of an international, Infrastructure national and regional gateway. Petroplus wishes for this role to be explicitly recognised and Petroplus supports the objectives of Policy CP2 that aim to protect and enhance green infrastructure explicitly protected in the Castle Point Core in Castle Point, and would object strongly to any proposals to remove these designations or to Strategy. weaken or delete this policy.

In particular, Petroplus supports the protection of West Canvey Marshes Strategic Green Grid which includes Canvey Wick SSSI and Holehaven Creek SSSI, as important parts of the Borough's Green Infrastructure. Petroplus considers that any development of informal recreation and education opportunities at Canvey Wick SSSI to support its status as a SSSI, should be of low intensity. 264 Policy CP 2 Ms KATHARINE U J The East of England Plan refers in policy ENV1 to Local Development Documents defining green W Minor Amendments to policy CP2 and the supporting text as recommended Protecting and FLETCHER infrastructure ‘....based on analysis of natural, historic, cultural and landscape assets'. This section by English Heritage. Enhancing Green ENGLISH should be broadened to encompass the historic environment. There are many opportunities for Infrastructure HERITAGE enhanced public appreciation, as well as protection, of heritage assets within green infrastructure, which often provides the context and setting for designated historic sites.

Recommendations for changes to text:

• - Amend title preceding para 6.8 to read: ‘Green infrastructure and landscape assets' • - Para 6.8, add to end: ‘Historic sites and features within green infrastructure provide interest and are complemented by the landscape which provides their context and setting'. • - Amend title preceding para 6.11 to ‘Conserving the natural environment and historic assets' • - Add new para after 6.12: ‘There are significant historic assets within the Borough's green landscape. These include Hadleigh Castle, a nationally important and well-preserved medieval royal castle, with considerable archaeological potential and outstanding visual and amenity value.' • - Amend title preceding para 6.13 to ‘Opportunities in the Landscape' • - Para 6.15, amend the second sentence, as follows: ‘...but without careful planning has the potential to cause harm to wildlife, natural habitats and important historic monuments.' • - Para 6.16, amend to: ‘The Olympic proposals, along with other proposals for recreation in the landscape, must be carefully assessed with regard to their potential impact on nearby areas of wildlife conservation and historic assets, including their settings.' • - Para 6.16, amend final sentence to read: ‘....with the requirements set out in the development control policy DC15: The landscape and natural features and policy DC17: Historic Environment.'

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Recommendations for changes to policy CP2:

• - Policy CP2, amend title to ‘Protecting and enhancing green infrastructure and landscape' • - Policy CP2, amend the introductory paragraph to read: ‘...whilst protecting the integrity of biodiversity and historic environment interests, the following key projects...' • - Policy CP2, add an additional bullet to the second group of bullet points: ‘Conserve and enhance the historic environment, to ensure targets for the protection, management and enhancement of assets are achieved' [as set out in Table 9]. Alternatively the penultimate bullet could be amended to read: ‘Conserve and enhance nature conservation, geological, historic and landscape assets to ensure that targets for SSSI condition, biodiversity and historic environment protection, and landscape enhancement are achieved; and' • - Policy CP2, amend final paragraph to read ‘Developer contributions towards green infrastructure projects, including conservation of natural and historic features in the landscape, will be sought in accordance with policy MI3, as appropriate.'

287 Policy CP 2 Dr Philip Pearson U J Concern over the proposed Olympic Mountain Biking Venue (Policy SS1 and Policy CP2) W The Olympic Mountain Biking event will take place in 2012. It is proposed Protecting and RSPB that a trial event takes place in 2011 to ensure that the track and venue are Enhancing Green appropriate. The RSPB is concerned about the potential adverse effects on Benfleet and Southend Marshes SPA Infrastructure that may be caused by the proposed Olympic Mountain Biking Venue at Hadleigh Country Park. The RSPB is of the opinion that the Council will need to thoroughly assess any adverse effects on the As a result, work on this project is well underway, and therefore detailed SPA caused by this specific project. We therefore support Proposed Publication Recommendation 1 work on project level ecological assessments has already been in the HRA that will require " the biodiversity impacts of the Olympic Mountain Biking Event and its undertaken. A strategic level HRA is not therefore necessary given the legacy to be fully assessed by Essex County Council before its development commences in order to progress already been made at the project level. ensure that the event, or its legacy, does not cause harm to the Benfleet and Southend Marshes SPA ." We remain concerned, however, that this project has simply been deferred to the project-level without any specific measures to avoid adverse effects to the SPA being proposed within the HRA (please see our comments above on deferring decisions). 289 Policy CP 2 Dr Philip Pearson U E Creation of a Country Park west of Canvey Road (Policy SS 2 and Policy CP 2) W Minor amendment to reference to West Canvey Marshes in table 6 and Protecting and RSPB policy CP2 to reflect the aspirations of the RSPB. Enhancing Green The Core Strategy refers to a country park being developed to the west of Canvey Road (A130). Infrastructure Much of this area is being developed by the RSPB as the South Essex Marshes nature reserve and not as a country park: this should be corrected within the Core Strategy. Public access is being created and engagement with the local community will be a high priority, but the site will be managed for its biodiversity. Consequently, the types of recreation that will be allowed on the site will be limited and this should be more fully reflected in the policy or supporting text. 302 Policy CP 2 Mr George Whatley U J Protecting and Enhancing the Green Infrastructure E In order to expand on this submission as The council does not accept that these comments make Policy CP2 Protecting and Canvey Green Belt necessary. As representatives of the Canvey unsound. The preamble to Policy SS2 indicates that the land east of Enhancing Green Campaign Greenbelt Campaign, and following our Canvey Road has a green belt allocation on the local plan. None of the No further development on Canvey Island greenbelt land. Infrastructure Referendum which clearly indicated the other comments are justifiable objections to the policy. concerns of the community of Canvey Island. 1. This policy represents a net loss of greenbelt infrastructure on Canvey Island

2. There has been an omission of an ecological study for the Dutch Village area

3. This policy will be in direct conflict with Sporting England

4. This policy will be in direct conflict with Natural England

5. This policy will be in direct conflict with the Environment Agency

6. This policy purports to provide marshland access as an open public space facility. This is considered to be a misconception as a facility for all Canvey Islanders

7. This policy relies heavily on unsustainable developer funding

8. Provisions of mountain bike facility has been given a disproportionate value

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inserting the word ‘multi-functional' before the words ‘green infrastructure' in the first and to provide technical assistance on matters sentence; relating to delivery of County Council services. • the importance of the historic environment in the Borough by amending the first bullet of the second paragraph of Policy CP2 by inserting the words ‘, historic environment' after the word ‘geological'. • proposals for the Thames Estuary Path by addition of a bullet in paragraph 1; • the benefit of Street Trees, especially in town centres, by addition of a bullet in paragraph 1; • the contribution of Green Infrastructure to Sustainable Urban Drainage Systems.

344 Policy CP 2 Cllr Martin Tucker U J Policy CP2: Protecting and Enhancing Green Infrastructure, p.35 E As elected representatives of Castle Point West Canvey Marshes are owned by the RSPB. The RSPB are currently Protecting and Canvey Island Borough Council residents, and with multiple developing the marshes as a nature reserve with freshwater habitats. It is Enhancing Green Independent Party representations made for consideration, CIIP expected that the site will open to the public as a nature reserve in the It is presumptuous to consider ‘Further development of a sub-regional park covering West Canvey Infrastructure would like to participate at the oral part of the Spring 2010. The land is not 'public amenity land' as identified in this Marshes' as a deliverable key project while there are contesting plans for the site. The West Canvey examination to justify and clarify the document representation. Marshes site is currently being considered for use as ‘intertidal habitat creation/replacement' by the submitted in response to the Core Strategy. Environment Agency within the Thames Estuary 2100 Plan which will seriously jeopardise the CS vision. To ignore this major conflict of ideas raises concern over the soundness of this CS key The Thames Estuary 2100 Plan identified West Canvey Marshes as a project. It has been reported, though not verified, that the Environment Agency could delay making potential intertidal habitat replacement area in the consultation draft its decision for ten years, but this is still relevant to this CS. published in the Spring 2009. As a result of local concerns regarding this proposal, and in discussions with the RSPB, the Environment Agency have revised their proposals on this matter to include this site as a potential Intertidal habitat creation/replacement on the West Canvey Marshes site will result in the loss of 254 intertidal habitat replacement area only in the third epoch of the plan - ha of ‘Greenfield' public amenity - 23% of Canvey Island's total ‘greenspace'. In addition to the CS expected to be beyond 2070. The final version of the Thames Estuary 2100 plan for developing public amenity ‘Greenfield' land to the East of Canvey Road ‘to provide a Plan was submitted to DEFRA for approval in January 2010. community hub...and up to 400 homes' there will be minimal public amenity greenspace remaining. This does not satisfy the aspirations made in the first paragraph of Policy CP2 ‘to provide an enhanced network of green infrastructure...that creates high quality living landscapes, and enhances As a result, a 60 year period exists in which West Canvey Marshes can opportunities for recreation', making this part of the CS Plan unsound. operate as a nature reserve as intended by the Core Strategy, and therefore its inclusion as a deliverable project within the Core Strategy is reasonable. Policy CP2: Protecting and Enhancing Green Infrastructure, p.35

Beyond 2070, the sea defences in this location may be realigned to create It is a general expectation that developers contribute towards the community in which they develop, intertidal habitat, if the sea-level has risen as projected. This will mean that and is welcomed for ‘green infrastructure projects and nature conservation'; however, Policy MI3 of the site will flood, with levels determined by the changing tide. These the CS also expects developers to contribute towards many other aspects of the community which is changes will not necessarily prevent the public using West Canvey arguably unsustainable, i.e. developments become less economically viable with an increase of Marshes as a nature reserve, however movement patterns within the site expected contribution. There must be more detailed guidance on how the contributions will be will need to be changed to enable flooding and ensure public safety. There managed so assurance is given that funds are allocated equitably. are many examples of areas of public access in intertidal location in Essex.

With regard to land to the East of Canvey Road, where development is proposed, this land is privately owned by Persimmon Homes and is not therefore 'public land'. As part of the proposals for the development of this location is expected that the Council will receive a further 14ha of public open space from the landowner linking up to Council owned land further north. This will help to establish a green link running north-south to the East of Canvey Road, to the benefit of new residents, and existing residents of the Dutch Village area.

As a result, it is contended that the opening paragraph to policy CP2 can be achieved through the delivery of the Core Strategy, and that therefore policy CP2 is sound.

With regard to Developer Contributions, policy MI3 is clear how developer contributions will be identified, baring in mind economic viability. The Canvey Area Action Plan will set out detailed infrastructure requirements for larger sites on Canvey. Meanwhile, the developer contributions guidance will be used to identify priorities for smaller sites. The Core Strategy is therefore considered clear and sound in this regard. 349 Policy CP 2 Mr George Whatley U E Policy CP2 should be altered to read:- E In order to expand on this submission as The council does not accept that the representation justifies the alteration Protecting and Canvey Green Belt necessary. As representatives of the Canvey of Policy CP2 as proposed. Enhancing Green Campaign Greenbelt Campaign, and following our Land abutting Canvey Road to be protected from future development, and to be given recognition as Infrastructure Referendum which clearly indicated the Ancient Landscape. The land to the west of Canvey Road has an Ancient Landscape concerns of the community of Canvey Island. designation in the Local Plan. The designation of the land to the west of Canvey Road in the Local Plan was made because of the distinctive There is no justifiable evidence demonstrated that exceptional circumstances exist to promote the characteristics of that area as set out in Policy EC19. The land to the east development of Greenbelt land on Canvey Island. During the deliberations on sites to be included in of Canvey Road does not have the same characteristics and does not the Borough's LDF the options of readily available infill sites and the redevelopment of tired trading therefore justify the same allocation. None of the other comments in the estates have been disregarded. representation justify an alteration to the designation of ancient landscapes in the borough Page 98 of 222

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The strategic value of the land East of Canvey Road remains unmeasured. It is allocated for Green Belt purposes on the adopted Local Plan. It was however, noticeably omitted from the Borough's Ecology Survey of 2007. Compiler Luke Bristow, Countryside and Ecology Officer, has confirmed in an email that the CPBC's Chief Planning Officer failed to request the area's inclusion amongst those sites to be surveyed.

However, just some thirty yards to the west and separated only by Canvey Road, exists a 254 ha site known as Canvey West Marsh.

This site is allocated as greenbelt but more importantly as Ancient Landscape. The 26.7 ha, East of Canvey Road, site is of an identical appearance. These are the last remaining large areas of Canvey landscape created by the Dutch during the 1620's.

There is a distinct probability that Canvey West Marsh will be allowed to flood for ecological and strategic purpose, under the Thames 2100 plan. Strategically it would form a London flood plain, whilst ecologically it would conform to a European Community ecological restoration directive. This would mean the loss of some 75% of the greenbelt of Canvey Island. Casting the utmost importance on retaining other Canvey Road greenbelt sites, especially East of, as it would be the largest of the few sites remaining from the original Dutch workings.

The encroachment by development onto the Land East of Canvey Road would significantly alter the three Estates known as, the Dutch Village Estate, the Saints Estate and the Avenues Estate creating a single Urban Sprawl.

The individual character of each Estate would be threatened. The vista would be dominated by the new development, as being on a flood plain, buildings would need to be of at least three storeys. Firstly to sequentially comply with PPS25 and also to be economically viable as a high percentage will need to be "affordable".

The Land East of Canvey Road maintains an open character and provides visual and general recreational amenity to the surrounding residential development. The opportunity for "access to all" to open local countryside for general recreation on Canvey Island will be lost. Unlike the current RSPB site on Canvey West Marsh the Land East of Canvey Road allows for more informal recreation. East of Canvey Road contains contrasting areas that allow various activities. These include ball games, dogs may be exercised and socialised off lead, and youngsters can experience the open air and countryside. Far better for anti-social behaviour to take place on open land, rather than in residential areas.

Canvey West Marsh RSPB site has an accessibility problem due to the entrance being located directly onto a roundabout where the intended regenerated Charfleets Industrial Estate traffic using Roscommon Way and the heavy commuter route, the busy dual carriageway, Canvey Road will converge. The Marsh itself is unsuitable for the vulnerable as leaving the pathways could lead to the dangers of the ditches and creeks.

There are no formal parks on Canvey Island. Other recreational areas are dominated by a golf course and football pitches. The lack of other available space is emphasised by the problems of finding relocation space for one single playing area for the Youth Football Club under threat of eviction from the pathway of the Roscommon Way extension. No suitable green area being available it has been allocated space on existing playing fields, in so doing, losing one existing football pitch.

It is noticeable that a number of other greenbelt sites within the borough were considered, and rejected, for development. Indeed the Baker Associates Report October 2009 states:

4.7 Part of the SA was to review the sustainability assessment method used by Castle Point to help select sites for allocation. The review of the outcomes of the site assessment revealed the site scoring highest against the assessment sustainability criteria has not been allocated. This site is Greenfield land to the east of Rayleigh Road. Neither the DPD or site assessment process gives a justification for this site not being allocated. The SA suggests that the allocation of this site could have preferable implications for sustainable development than other allocations.

However nowhere will the effect of urban coalescence be more damaging than on Canvey Island. This part of the Borough is some 30% more densely populated than the Mainland towns.

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Evidence of brown field sites not being thoroughly investigated was highlighted when the Council's Special Policy and Development Group, set up to specifically consider the Core Strategy Document, called, on the 9th July, for a list of such sites to be produced for their following meeting. Notes from their following meeting show that the list was not produced for consideration.

The schedule for releasing the land alongside Canvey Road shows this is the Borough's Planners first, rather than the last resort for development.

Although suffering from a high water table and liable to winter water logging the land East of Canvey Road supports a wide variety of wildlife. There is evidence of the presence of protected species. One, three acre field abutting Holland Avenue has been allowed to develop into a dense forest of Hedgerow bushes to a height of some fifteen feet over the last thirty-three years. Singularly the largest, and possibly only area of its type, on Canvey. This has attracted to the Island some uncommon species of bird life, for the protection and feed it offers.

During the course of the Middle Ages much of Canvey Island was enclosed by sea walls to protect the marshland from rising sea levels. From this time the present pattern of "inned" land developed. The irregular pattern of small fields reflect the pattern of creek and rills that existed before enclosure. These irregular pattern of fields derived from saltings created in the Middle Ages still characterises the green belt landscape abutting Canvey Road today. Whilst the dykes, created by the Dutch in the 1620's, are suffering from neglect

and a lack of regular maintenance, they still perform, to some extent, their original intention of draining the area of surface flood water, particularly from the nearby Dutch Village Estate, 70% of which has un-adopted and un-made up roads without any drainage system at all.

Availability of funds should also be shown, so as to prove true intent to protect and develop Canvey Wick SSSI.

The failure to stop motor bikers damaging vast areas and the County Council cutting a vast swathe of contentious roadway across this important site casts doubt on the Borough Council's resolve to enhance the green infrastructure and the well being and quality of life of the residents of this part of the Borough.

Evidence extracted from:

Planning Application CPT/128/09/FUL.

Planning Application CPT/377/08/TEL.

2001 U.K. Census

Notes of the Special Policy Development Group 9th July 2009

Notes of the Special Policy Development Group 9th September 2009

Planning Policy Guidance 2 Green belts

Correspondence from Luke Bristow, Countryside and Ecology Officer via Email dated 27/07/09

Sustainability Appraisal of the Castle Point Borough Local Development Framework

Core Strategy and Development Control Policies Development Plan Document - October 2009 Baker Associates 362 Policy CP 2 Mr Graham Bracci U J Protecting and Enhancing the Green Infrastructure E In order to expand on this submission as The council does not accept that these comments make Policy CP2 Protecting and Canvey Green Belt necessary. As representatives of the Canvey unsound. The preamble to Policy SS2 indicates that the land east of Enhancing Green Campaign Greenbelt Campaign, and following our Canvey Road has a green belt allocation on the local plan. None of the No further development on Canvey Island greenbelt land. Infrastructure Referendum which clearly indicated the other comments are justifiable objections to the policy. concerns of the community of Canvey Island. 1. This policy represents a net loss of greenbelt infrastructure on Canvey Island

2. There has been an omission of an ecological study for the Dutch Village area

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