Draft New Local Plan FAQ's

Questions

What is a Local Plan?

Local planning authorities have a statutory right under the Town and Country Planning Act, as amended, to prepare a local development plan for their area. Decisions on planning applications should be taken in accordance with the policies set out within the local development plan, unless other material planning considerations indicate otherwise. The NPPF is a material planning consideration.


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What are the Tests of Soundness?

The Tests of Soundness are set out at paragraph 182 of the National Planning Policy Framework (NPPF). There are four tests which are as follows:

  • Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
  • Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
  • Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
  • Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
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Why is the Council preparing a New Local Plan?

The current Local Plan for Castle Point was adopted in 1998 having been prepared in the early 1990’s. The housing proposals set out within the Adopted Local Plan only ran to 2001 and are therefore significantly outdated. Furthermore, the Adopted Local Plan reflects policy considerations of that time, and does not address important local issues that have emerged more recently such as flood risk and the need to respond to climate change.

As the Local Plan is out of date and silent on a number of local issues, the policies in the NPPF will need to be considered and applied when applications for development (especially housing development) are made in Castle Point. The presumption in favour of sustainable development will be applied unless the potential for significant harm can be demonstrated. This reduces the control the local Council and local residents have over where development does and does not go. A New Local Plan will improve the control local people have over the location, design and layout of development proposals.

Furthermore, without a plan each application and its need for infrastructure provision such as schools, roads and GPs has to be considered on an individual basis and justified in each case. This makes it difficult to secure infrastructure contributions and improvements arising from the cumulative impacts of development. A New Local Plan will allow for the full impacts of growth to be assessed and for infrastructure needs to be fully and appropriately planned for. Again, a New Local Plan will put local people in control of infrastructure provision.


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How is a Local Plan prepared?

A local plan is prepared using evidence. Evidence can take various forms but includes studies and assessments prepared by the Council such as the Green Belt Boundaries Review, studies and assessments prepared with others such as the Thames Gateway South Essex Strategic Housing Market Assessment, and studies and assessments prepared by others such as Experian Economic Growth Forecasts.

Once a local plan has been prepared, it is the subject of an examination by an inspector appointed by the Planning Inspectorate. That inspector will consider whether the tests of soundness set out in the NPPF have been met.

Evidence will be key to the Inspector making a determination that the test of soundness have (or have not) been met.


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Why does the draft New Local Plan propose to build 200 homes per year?

The NPPF requires local planning authorities to prepare local plans that deliver sufficient housing to meet the full, objectively assessed need for housing within the area. National Planning Practice Guidance, indicates that the starting point for determining the full, objectively assessed need for housing within an area should be the Department for Communities and Local Government Household Projections. The most recently published full set of Household Projections (2010) indicates a requirement for around 350 homes per year in Castle Point. 2011 Interim projections and the average of projections for the period 2004 to 2011 indicate the need for 320 homes per year in Castle Point.

The National Planning Practice Guidance also indicates the need to take into account the requirements of business in terms of labour supply, and the need to consider the requirement for affordable housing when determining objectively assessed need.
 
Therefore, the full objectively assessed need for housing in Castle Point is at least 320 homes per year, but could be as high as 500 homes per year.
 
The draft New Local Plan sets a target of just 200 homes per year. This is due to supply issues. The capacity to accommodate housing in Castle Point is restricted due to the physical size of the borough, and also the need to protect wildlife and ensure space for water in the event that a flood event occurs. Overall, the Council’s assessment of housing supply only identifies sufficient capacity to deliver around 200 homes per annum.

In planning for 200 homes per year, the Council is therefore doing all it can to accommodate its full, objectively assessed need for housing having regard to environmental constraints. A lower level of provision would not demonstrate that the Council was doing all it can to accommodate growth and the Government’s planning inspector may not therefore consider the New Local Plan to be compliant with national planning policies in the NPPF.


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Where does the draft New Local Plan propose that new homes should be built?

The Council has used a raft of evidence to identify those sites where housing development should occur.

The NPPF requires local planning authorities to identify sites where housing can be delivered now, or developed in the medium to longer term. To be considered deliverable or developable, the sites must be suitable for housing, and must have a reasonable prospect of being developed at the time envisaged.
 
Evidence collected to identify suitable sites has included a Sustainability Appraisal of Sites, Transport Modelling, a Strategic Flood Risk Assessment and Sequential Test, a Surface Water Management Plan, a Wildlife Site Review, a Green Belt Boundary Review, a Green Belt Landscape Assessment and a Green Belt Functions Assessment.
 
Information has also been sought on the landownership and developer interest in sites, and on the viability of development, in order to determine whether sites will be available for development during the period of the plan.
 
The results of these assessments have been used to identify the following sites for inclusion in the draft New Local Plan:
  • Small sites within the existing urban area – 950 homes
  • Land off Kiln Road, Thundersley – 450 homes
  • Land at Thorney Bay Caravan Park, Canvey Island – 600 homes
  • Land at Point Road, Canvey Island – 160 homes
  • Land off Scrub Lane, Hadleigh – 64 homes
  • Land at the former Castle View School, Canvey Island – 50 homes
  • Land between Felstead Road and Catherine Road, Benfleet – 200 homes
  • Land East of Rayleigh Road, Hadleigh – 430 homes
  • Land South of Daws Heath, Hadleigh – 180 homes
  • Land South of Eastwood Old Road, Eastwood – 50 homes
  • Land West of Glebelands, Thundersley – 100 homes
  • Land West of Benfleet, Benfleet – 800 homes
  • Land off the Glyders, Benfleet – 35 homes
  • Land East of Canvey Road, Canvey Island – 275 homes
  • Land fronting Canvey Road, Canvey Island – 50 residential care beds
  • Land at North West Thundersley – 400 homes

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Why does the draft New Local Plan propose to build some homes in the Green Belt?

The full, objectively assessed need for housing in Castle Point is at least 320 homes per year.

If sites within the Green Belt are excluded from consideration for housing purposes, it would only be possible to accommodate around 1,975 homes (99 homes per year) in Castle Point. This is substantially less than the full, objectively assessed need for housing.
 
The NPPF expects, in circumstances where the needs for development cannot be met, for Green Belt boundaries to be reviewed in order to identify whether it is possible for additional development to be accommodated.
 
The Council has therefore prepared a Green Belt Boundary Review which identifies the potential to accommodate some housing within the Green Belt whilst maintaining its overall strategic purpose of preventing neighbouring towns from merging by preventing urban sprawl.

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What is affordable housing?

Affordable housing is social rented, affordable rented and intermediate housing, provided to eligible households whose needs are not met by the market. Eligibility is determined with regard to local incomes and local house prices. Affordable housing should include provisions to remain at an affordable price for future eligible households or for the subsidy to be recycled for alternative affordable housing provision.


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Why does the draft New Local Plan seek for 20% of new homes to be affordable?

The Council has worked with its neighbours to prepare a Strategic Housing Market Assessment (SHMA). This assessment has determined the need for affordable housing in each area having regard to house prices and income levels. It shows that the need for affordable housing in Castle Point is very high - 73% of all new homes to be delivered.

The Council has also had a Whole Plan Viability Assessment prepared. This has considered the impact the provision of affordable housing has on the viability of development and the potential to seek the provision of other infrastructure such as roads, schools and GP surgeries.
 
This demonstrates that 35% affordable housing provision is just about viable in Benfleet, Hadleigh and Thundersley. It is not viable on Canvey Island.
 
It also demonstrates that lower levels of affordable housing provision will allow other infrastructure to be secured.
 
The Council has therefore decided to seek 20% affordable housing provision in order to allow other infrastructure provision to occur. Not all the need for affordable housing will be met by the New Local Plan.
 
Different levels of affordable housing requirement are expected in Benfleet, Hadleigh and Thundersley (25%) and on Canvey Island (15%). This different reflects the ability to provide affordable housing on Canvey Island without affecting development viability.

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How will the proposals for housing in the draft New Local Plan impact on traffic?

Without improvements to the road and public transport networks, new housing will make traffic congestion worse. Therefore, each housing site will be required to make improvements to the local highway network.

Of greatest significance is the proposal that Land West of Benfleet will provide a new route into the west of Benfleet from the A130 Canvey Way, reducing pressures on the Tarpots junction. To accommodate this, Canvey Way will be dualled from Sadlers Farm to this new junction.
 
Proposals are also included to improve traffic flows along the A129 Rayleigh Road in association with development to the East of Rayleigh Road.

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How will the proposals for housing in the draft New Local Plan impact on the capacity of schools, especially having regard to the proposed closure of the Deanes School?

The School Planning Team at Essex County Council has modelled the proposed housing growth in Castle Point in order to determine the likely need for additional school places.

They have determined that their may be additional need for primary school places in Benfleet and Hadleigh. The policy for Land West of Benfleet therefore includes the requirement for land to be made available for a primary school and nursery. Meanwhile, there are proposals to rebuild Hadleigh Junior School which will enable flexibility to be built into the supply for Hadleigh.
 
Due to the planned extensions of the Appleton and King John Schools it is expected that the needs for secondary school places in the Benfleet, Hadleigh and Thundersley area will be met in the period to 2031, even if the Deanes School were to close. This will however limit the number of children that can come into the area from Southend and Basildon to go to school.

Any additional demand for secondary provision on Canvey Island will meanwhile be accommodated within the Castle View and Cornelius Vermuyden Schools.


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What improvements to the road network and public transport provision are proposed in the draft New Local Plan?

In addition to those road improvements associated with specific housing proposals, there are also a number of other improvements to the local road and public transport network proposed in the New Local Plan. These include:

  • Widening of Somnes Avenue eastbound to accommodate evening peak time traffic flows;
  • The extension of Roscommon Way to Western Esplanade;
  • The North Thames Link Road;
  • A130 passenger transport corridor improvements; and
  • Improved public transport access to employment areas in Basildon and Southend.

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How will the proposals for housing in the draft New Local Plan impact on the capacity of GP surgeries?

It has been assessed that housing growth will result in the need for up to 7 additional individual GP’s in Castle Point. The proposals for three sites – Land West of Benfleet, Land off Kiln Road and Land East of Canvey Road include the requirement to make space for GP provision to address this demand for additional capacity.


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How will the proposals for housing in the draft New Local Plan impact on access to open space and the countryside?

None of the housing proposals set out in the New Local Plan are on areas of public open space.

New large scale (3ha+) housing proposals will be required to make provision of open space at a rate of 200m2 per house. Therefore, new housing developments will increase the provision of open space within the borough.

Where housing proposals are nearby to areas of countryside, the policies for that site will include a requirement for landscaping to ensure that the development fits into the landscape. Where possible, there will also be a requirement for new footpaths to link the urban area to the countryside better.


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Why does the draft New Local Plan propose to deliver 2,100 jobs and 10,000m2 of employment floor space?

Economic modelling indicates that Castle Point is an area of economic growth. Experian modelling shows that around 2,100 jobs will be created in Castle Point in the period 2011 to 2031. This will require approximately 10,000m2 of floorspace for businesses to grow and develop.


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Where does the draft New Local Plan propose to deliver new jobs?

Land has been allocated since 1998 at West Canvey for economic growth purposes. There are approximately 15ha of land for employment growth allocated to the east of Morrisons Supermarket and to the south of Charfleets Industrial Estate.

The Council’s Employment Needs Assessment identified the need for a site of approximately 4-5ha in size to accommodate employment growth in the Benfleet, Hadleigh and Thundersley area. A 4ha site to the east of Manor Trading Estate has therefore been identified.


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Why does the draft New Local Plan propose to deliver 11,650m2 of retail floorspace?

The Council’s Retail Needs Assessment sets out a detailed analysis of current and projected future shopping trends within Castle Point. It concludes that the population growth associated with the provision of 200 homes per annum will give rise to demand for additional shopping provision requiring 3,300m2 for convenience goods (food) and 8,350m2 for comparison goods (non food).


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Why does the draft New Local Plan propose to deliver retail growth within Canvey and Hadleigh town centres?

The NPPF expects most additional retail provision to occur within town centres in order to support their vitality. It sets out a sequential test, whereby out of town centre developments may only occur where it can be demonstrated that no suitable sites exist within town centres.

The Canvey and Hadleigh Town Centre masterplans demonstrate that through the regeneration of these centres, there is the potential to secure at least 11,000m2 of additional retail provision within these centres. Therefore, there is no need for out of centre provision.
 
The Retail Needs Assessment included a health check of the town centres in Castle Point. It concluded that these two centres were in the most need of investment in order to improve their vitality.

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How does the draft New Local Plan propose to address the issue of empty shops?

The draft New Local Plan proposes that the reuse of a shop for non-retail uses is permitted where it has been vacant for 6 months or longer. Where this is in the middle of the town centre the non-retail use will only be permitted on a temporary basis. In other locations the non-retail use may be permanent but would need to have an active frontage (shop windows etc) to fit in with surrounding shopping provision.


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How much of the current Green Belt extent will be retained by the proposals in the draft New Local Plan?

The proposals in the draft New Local Plan will maintain 92% of the current extent of the Green Belt.


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How will the proposals in the draft New Local Plan ensure wildlife is protected?

The proposals in the draft New Local Plan seek a net gain in wildlife (also known as biodiversity).

Those sites designated for nature conservation purposes at the European level (Special Protection Areas) and at the national level (Sites of Special Scientific Interest) will be afforded the highest level of protection. Proposals which would result in harm to these sites, and which cannot be mitigated on-site, will be refused.
 
For sites which are identified as being locally important (Local Wildlife Sites) off-site compensation may be acceptable, if every effort has been made to mitigate impacts on-site in the first instance. Where off-site compensation is made, it is expected that this will be of an equivalent habitat and managed to achieve a good quality over a period of at least 20 years.

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How will proposals in the draft New Local ensure that historic features are protected?

The proposals in the draft New Local Plan seek to protect historic assets from harm.

The highest level of protection will be afforded to those assets designated at a national level i.e. listed buildings and scheduled ancient monuments.
 
A local list of historic assets has also been prepared identifying locally significant historic assets where they contribute positively towards the quality of the local environment. The Council will seek to protect these from harm.

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How will the proposals in the draft New Local Plan ensure that the quality of the environment in Castle Point is protected and improved?

In terms of the natural landscape, the proposals in the draft New Local Plan include three areas of Historic Natural Landscape where development will be controlled in order that impacts are managed and/or avoided.

In terms of the urban environment, design policies have been prepared which seek high quality design including the provision of landscaping features.
 
For the identified housing sites, it is proposed that masterplans or design briefs will be prepared for each site to ensure that they are well designed and contribute to the quality of the environment in the local area.

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How will the proposals in the draft New Local Plan ensure that the health and wellbeing of residents is improved?

A review of the community infrastructure needs of the existing and projected population has been undertaken to ensure that residents have access to the facilities they need to enjoy a good quality of life. Generally, there is good access to facilities in Castle Point, although there is a particular need for additional sports facilities including a new sports hall in the Benfleet, Hadleigh or Thundersley area, and an indoor (lawn) bowls centre.

The draft New Local Plan recognises these requirements and seeks to secure the provision of these facilities through the plan. However, at this stage specific sites have not been identified. There are several potential opportunities for the provision of these facilities that will need to be considered as the plan is progressed through its delivery phases.

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How will the proposals in the draft New Local Plan ensure that the risk posed by flooding is managed and reduced?

The Council has prepared a document called a Strategic Flood Risk Assessment. This identifies the likelihood of flooding in different parts of the borough and the potential extent of flooding should a flood occur. This document mainly focuses on flooding from rivers (fluvial flooding) and the sea (tidal flooding).

The Council has also worked with other organisations to prepare a Surface Water Management Plan. This document identifies those parts of the borough at risk of surface water flooding.
 
The information in these two documents has been used to identify where development should be directed initially to avoid flood risk. However, due to the extent of the need for housing, the documents have also been used to identify the need for flood resilience and flood resistance measures on those sites at risk of flooding from one source or the other.
 
Where there is a risk of flooding, it is therefore expected that new homes will be constructed to keep residents safe should a flooding event occur.
 
Furthermore, in order to reduce surface water flood risk to nearby properties also, the use of sustainable urban drainage techniques is also required.
 
The Council is also working with Essex County Council to secure funding for surface water management improvement works in the Benfleet and Thundersley areas.

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What provision for young people is proposed through the draft New Local Plan?

The draft New Local Plan recognises the requirement for specific provision of facilities for young people. However, Castle Point is not a provider of youth services.

Youth services in Castle Point are provided by Essex County Council and the voluntary sector including local groups as well as established national organisations such as the Scouts, ATC etc.
 
Essex County Council has recently significantly reduced the budget for youth service provision across the County. Meanwhile voluntary groups are reliant on fund raising and grant support. As a consequence these organisations do not have long-term plans and it is very difficult to identify specific projects that the New Local Plan can support the delivery of.
 
The draft New Local Plan therefore sets out a policy which supports ‘education, skills and learning provision’ including youth projects where such proposals would support the local economy, enable local people to better access employment opportunities and/or provide opportunities for community activity and engagement, reducing social isolation.
 
This approach enables the Council to support youth projects which contribute towards the well-being of local young people as and when they come forward.

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How do the proposals in the draft New Local Plan address the risks posed by the Oil and Gas Storage Installations at South Canvey?

These two installations have all the necessary consents for the products they store and the activities that they undertake. It is not within the power of the Council to change this existing situation.

The owners of these installations have indicated commitment to these sites. The Oil Storage installation is currently the subject of significant investment by its owners.
 
The draft New Local Plan therefore envisages the ongoing operation of these installations throughout the period of the plan.
 
However, due to the proximity of these installations to the resident population, it is proposed in the draft New Local Plan that any application for these sites will be expected to bring about a reduction in risk to the resident population.
 
Furthermore, the draft New Local Plan proposes that any development within the proximity of these installations will be considered against the advice of the Health and Safety Executive. Where the Health and Safety Executive advise against development, development will not be permitted.