What is the Local Plan / The Castle Point Plan?

A Local Plan (The Castle Point Plan) is a long-term plan which sets out a positive vision for the area and identifies where and how development should take place in the future. Having a Local Plan helps to ensure that the entire area is considered and that the delivery of development accords with the needs of that area. There is a requirement by Government for Local Plans to be kept up to date.  The Castle Point Plan is a 17-year plan covering the period 2026 to 2043 that will include: 

• Identifying where development should be located, including housing, infrastructure and commercial
• Policies to safeguard the environment and enable climate change mitigation 
• Policies to secure high-quality design
• Specify requirements on housing need within the Borough 

Regulation 19 Consultation: Opened 1 Aug 2025 - Closes 26 Sep 2025 

Regulation 19 is the next stage in the development of the Castle Point Plan. It takes into account previous consultation feedback and evidence-based documentation produced to support the production of the Castle Point Plan Draft (Regulation 19) Document. 

Comments can be made using the online portal: https://consultation.castlepoint.gov.uk/cpplan/   This contains the Castle Point Plan Regulation 19 Draft, and comments should be targeted to specific sections of the document, for example a specific policy or paragraph number.  Alternatively, comments can be made using the Castle Point Plan Regulation 19 Draft Consultation Response Booklet. This can be returned to the Council by email to: [email protected]  or by post to Castle Point Plan, Planning Department, Castle Point Borough Council, Kiln Road, Thundersley, Benfleet, Essex SS7 1TF.   

The Castle Point Plan Regulation 19 Consultation Response Booklet is available on the Council website, the Council Offices, Waterside Leisure Centre and all local libraries.  Comments should be made on whether the Castle Point Plan as a whole or in part is legally compliant and meets the test of soundness. Details of what these mean and how to complete the form can be found on the online portal and within the Response Booklet.   

Comments must be submitted no later than 23:59 pm on Friday 26th September 2025.  At the end of the consultation period, all moderated comments will be published. The Council will then submit the Castle Point Plan, supporting documents and evidence and all comments received to this consultation to the Secretary of State, who pass them to a Planning Inspector for independent examination.   

AUGUST 2025

Dame Rebecca Harris MP Regulation 19 Consultation Response

As the Member of Parliament for Castle Point, I have always stood firmly alongside local residents in defending the character, integrity, and resilience of our Borough. The Regulation 19 consultation represents a vital opportunity to shape a Local Plan that reflects not only the needs of our communities but also their values and aspirations.

Castle Point is a unique and tightly constrained area. We are blessed with beautiful open spaces, a rich natural environment, and a strong sense of local identity. But we also face serious challenges, particularly around flood risk, infrastructure capacity, and the pressure to accommodate growth. These issues are especially acute on Canvey Island, where the risks of tidal and surface water flooding are well known, and in parts of Benfleet and Hadleigh, where drainage infrastructure is under strain. Also, significantly there are effectively only three highways access routes in and out of the Borough for all its almost 100K residents, Sadlers Farm, the A13 towards Southend, or Rayleigh Weir.

I welcome the Council’s decision not to include any of the Green Belt sites that are so treasured by local residents in the first draft of this plan. This is a victory for residents and a testament to the strength of community feeling. Our Green Belt is not just a planning designation, many local Green Belt sites are a cherished part of our landscape and heritage. They must be protected wherever possible. However, for reasons I will detail later in this response, I fear that the Plan in its current form will render this attempt at protection by the Council meaningless.

That said, I do believe there is a case for a carefully considered exception in the site known as North West Thundersley, or colloquially as the expanded ‘Blinking Owl Site’. This site offers a rare opportunity to deliver much-needed housing in a sustainable and accessible location, without undermining the wider function of the Green Belt. It is a pragmatic solution to a difficult problem, and I support its inclusion in the Plan as a way to increase the soundness of the plan whilst allowing for the better protection of other more accessible Green Belt sites residents treasure, a significant decrease in planned housing density on Canvey Island, and creating an extra highway access for the Borough onto the wider road network.

I would also like it to be acknowledged that, although the Council’s approach to engagement has been broadly constructive and the consultations on the Plan well-advertised, many residents have found the Regulation 19 consultation difficult to engage with due to its length and complexity. It is vital that, where possible, this is made more accessible for residents, so that all voices in our community can be heard and understood. Hence why, although I have attempted to answer all the questions in the consultation, I would like this document treated as my main response, as it is far easier for me to outline the strength of my views and include greater detail in this format than it is by engaging with the formal consultation questionnaire online.

The key points I wish to raise in this response regarding the draft plan are:

• Castle Point faces serious challenges, including surface water flooding, infrastructure strain and pressure to accommodate growth.
• The proposed allocation of over 3,300 homes to Canvey Island is excessive given its environmental and infrastructure constraints.
• The Council’s removal of several Green Belt sites is commendable and reflects strong community engagement.
• North West Thundersley offers a sustainable and strategic location for growth and should be included in the Plan to better protect Green Belt sites and enable a considerable decrease in proposed housing numbers on Canvey Island.
• The plan lacks a demonstrable five-year housing land supply, critically undermining its credibility and resilience.

 Legal Compliance of the Plan

For the Castle Point Plan to be legally compliant, it must satisfy the statutory obligations set out in the Town and Country Planning Act 1990, the Planning and Compulsory Purchase Act 2004, and the National Planning Policy Framework (NPPF, December 2024). While I recognise the effort that has gone into preparing the Regulation 19 draft, there are several areas where, in my view, the Plan does not yet meet the legal tests of soundness and compliance, and these must be addressed before submission for examination.

A key statutory requirement is the ‘Duty to Cooperate’. This is not a procedural formality but a legal obligation requiring sustained and meaningful engagement with neighbouring authorities and statutory bodies on strategic matters. Paragraph 28 of the NPPF is explicit in its expectation that Statements of Common Ground should be used to evidence this cooperation. In Castle Point’s case, the absence of clear and binding agreements on cross-boundary infrastructure and housing distribution is a serious concern. Without demonstrable cooperation, the Plan risks being found unsound on procedural grounds alone.

The Sustainability Appraisal, which underpins the Plan’s spatial strategy, also falls short of what is required. Paragraph 32 of the NPPF requires that plans be informed by a robust and proportionate evidence base. Yet the strategic alternative of North West Thundersley, an option that could deliver sustainable growth in a well-connected location, has not been adequately assessed. While the Sustainability Appraisal acknowledges the option, it is given nowhere near enough consideration and the assessment of it lacks the depth of analysis applied to other alternatives. There is no transparent comparison of its sustainability performance, nor a clear justification for its exclusion. This omission undermines the credibility of the appraisal and raises legitimate questions about whether all reasonable alternatives have been properly considered.

The Plan’s approach to biodiversity and environmental protection also requires strengthening. Paragraph 180 of the NPPF makes clear that development should not proceed where it would result in significant harm to biodiversity or protected sites unless that harm can be fully mitigated. While the draft Plan identifies a range of mitigation measures, it does not yet provide enforceable delivery mechanisms. Without clear implementation pathways, these measures risk remaining theoretical rather than practical.

Perhaps most critically, the Council has not yet demonstrated a deliverable five-year housing land supply, as required under paragraph 78 of the NPPF. This is not a technical detail; it is a fundamental test of the Plan’s credibility. Policy SP3 in the Plan does not provide a deliverable five-year supply of housing land for either the Government’s housing targets, or indeed the Council’s own lower assessed need. The absence of a transparent and evidenced supply not only weakens the Plan’s position but also leaves all of Castle Point’s Green Belt, which possibly could be developed, critically vulnerable to speculative development, particularly areas that are environmentally sensitive or poorly served by infrastructure.

In summary, while the Regulation 19 draft represents progress, in my view, the draft plan is not yet legally compliant. The Plan must be revised to address these shortcomings, particularly in relation to the Duty to Cooperate, the treatment of strategic alternatives, the enforceability of mitigation, and the evidencing of housing supply. These are not academic concerns; they are the legal safeguards that ensure development is sustainable, justified, and in the public interest.

Soundness of the Plan

To be found sound at examination, the Castle Point Local Plan must satisfy the four statutory tests of soundness as defined in paragraph 35 of the NPPF. These are, positively prepared, justified, effective, and consistent with national policy. While I acknowledge the considerable work undertaken by Castle Point Borough Council, I remain concerned that the Plan does not yet meet these essential criteria in full.

There is absolutely no doubt that the housing target for Castle Point imposed centrally by the Government is impossible to meet. It would in fact be impossible for our Borough to cope with a number of houses anywhere near that target without losing its character and causing critical failure of the local infrastructure residents rely on every day. However, in order to successfully argue its case for a lower housing figure, the Council has to produce the strongest possible evidence that it cannot meet the Government’s target and needs to show it has considered every viable alternative. I think significant work is still required from the Council to meet both these vital requirements, to successfully secure the acceptance of a significantly lower housing figure than the proposed target.

The Plan proposes to deliver only around 53% of the Government’s housing target, representing a shortfall of approximately 5,446 homes over the 17-year plan period. This gap has not been robustly justified. Although to many residents and observers it is obvious that our area cannot meet the Government’s impossibly high housing target, the strongest possible evidence must be presented to explain and prove exactly why. Environmental constraints and infrastructure limitations are cited, but national policy requires that such constraints be clearly evidenced and that all reasonable alternatives be fully explored. It is absolutely imperative that this is addressed for the plan in its current form to be found sound. The exclusion of North West Thundersley undermines the claim that the Plan has been positively prepared.

The Sustainability Appraisal fails to assess North West Thundersley in any meaningful depth. The analysis is superficial and lacks the comparative rigour applied to other locations. This omission risks rendering the Plan unsound under paragraph 35(b) of the NPPF.

The five-year housing land supply is not convincingly demonstrated, and reliance on constrained sites casts doubt on deliverability.

Paragraphs 159 and 161 of the NPPF are clear that development should be directed away from areas at highest risk of flooding. The current strategy does not reflect this principle even though flood risk on Canvey is subject to very effective mitigation, the unique adaptations to Sustainable Urban Drainage Systems (SUDS) necessary to not upset the balance of the island’s already complex drainage network are not sufficiently taken into account in the Plan. Many of the SUDS’ measures routinely deployed on housing sites elsewhere in the country are simply not appropriate for Canvey Island’s unique geography and drainage infrastructure. The island’s low elevation, high groundwater levels, tidal influence and reliance on pumped discharge mean that infiltration-based systems such as soakaways, infiltration trenches, permeable paving that depends on infiltration, and unlined attenuation basins would be ineffective at best – and dangerous at worst. These systems rely on water soaking naturally into the ground, yet Canvey’s ground conditions make this highly unlikely and risk creating new flooding or groundwater contamination problems. Similarly, swales designed primarily as infiltration features would not function as intended and could fail under high tide or storm conditions. Any on-site drainage solutions that cannot be mechanically discharged or connected into a properly managed and maintained system would pose an unacceptable risk. The Council’s plan must reflect this reality and ensure that all new developments on Canvey use only those SUDS types that are compatible with its tidal regime, high groundwater, and pumped network, not shoehorn in the same infiltration-based measures used elsewhere without regard to the local constraints.

In summary, the Plan must be revised to provide a more robust justification for its housing shortfall, reassess the exclusion of North West Thundersley, strengthen delivery mechanisms, and align more closely with national policy.

Site allocations for strategic housing growth – Concerns and Alternatives

The spatial strategy proposed in the Plan places disproportionate pressure on Canvey Island, despite its well-documented flood risk and infrastructure limitations. The allocation of over 3,300 homes is excessive and difficult to justify.

North West Thundersley offers a far more suitable location for strategic growth. It benefits from superior transport connectivity, greatly lower flood risk, and strong public support. The site is composed largely of plotlands and industrial units, and its development would affect fewer residents. Its exclusion is not adequately justified in the Council’s evidence base.

The Sustainability Appraisal fails to assess North West Thundersley as a reasonable alternative. This omission risks rendering the Plan unsound under paragraph 35(b) of the NPPF. A revised spatial strategy should reduce the housing burden on Canvey Island and incorporate North West Thundersley.

Canvey Island’s geography and infrastructure present significant planning challenges, particularly related to flood risk. I welcome the Council’s commitment to requiring Sustainable Urban Drainage Systems (SUDS) in all new developments. However, SUDS must be designed with a full understanding of Canvey’s unique drainage context. The slow release of retained water can have negative cumulative effects if not properly accounted for.

The lack of a third access point to Canvey because of its unique geography remains a strategic weakness. It is deeply regrettable that the Council abandoned work on the ‘Canvey Third Access Task Force’ in 2022. Had this work continued, a viable solution could have been identified and included within the Plan period.

The housing allocation to Canvey Island should be reduced and made contingent upon robust flood resilience measures, including a comprehensive drainage strategy unique to Canvey Island and renewed exploration of a third access route.

North West Thundersley offers a more suitable alternative, with better connectivity, lower flood risk, and infrastructure-led potential.

Five-year Housing Supply and Green Belt Protection

Castle Point Borough Council deserves credit for adopting a brownfield-first approach. This aligns with national policy and reflects local priorities. However, the Plan must demonstrate that brownfield opportunities are deliverable and capable of contributing meaningfully to housing supply.

The failure to demonstrate a deliverable five-year housing land supply within this plan, as mandated by the NPPF, is a serious concern. Without it, the Borough remains exposed to speculative development on all Green Belt land where development is possibly viable. This is, I believe, a fatal flaw in the Plan as it stands and needs addressing immediately. Having a five-year supply of housing to meet local need is crucial to the soundness of the plan, but it is also a very robust defence against speculative planning applications, something that the local Green Belt site’s residents desperately need the protection of in the face of ever-growing numbers of speculative planning applications and appeals.

Green Belt land provides flood attenuation, biodiversity, and recreational value. Its protection is essential. I commend the Council for removing several treasured Green Belt sites from consideration for development. However, I fear that gesture made on behalf of concerned residents will be rendered meaningless, providing little or no actual defence of those Green Belt sites that residents want to see preserved if the Council does not include a viable five-year supply of deliverable housing into the plan and better evidence its case for a lower housing target. I am concerned that either the Planning Inspector is likely to direct the Council to include a quantum of deliverable Green Belt sites to meet the need, which is likely to see a greater rush of speculative planning applications on Green Belt while the Council decides which ones to include, or the Secretary of State may decide to take plan-making powers away from Castle Point Borough Councillors entirely.

Although most local Green Belt sites should be protected from development in the plan, North West Thundersley represents a carefully considered exception. It offers infrastructure-led growth in a sustainable location and would relieve pressure on more vulnerable areas. As a new settlement, it could be built to different style specifications to the rest of the Borough (e.g. three- or four-story town houses) that would allow for gentle densification compared to other residential settlements in the Borough.

Recommendation to include North West Thundersley in the plan as a strategic housing growth site

The exclusion of North West Thundersley from the Castle Point Plan is not only a strategic oversight, it is a missed opportunity to deliver sustainable, infrastructure-led growth in a location that is demonstrably more suitable than many of the sites currently proposed. The area, particularly the Blinking Owl site, has long been recognised in previous capacity studies as capable of accommodating up to and over 5,000 homes. This scale of development would not only relieve pressure on Canvey Island but also contribute meaningfully to closing the gap between Castle Point’s current housing trajectory and the Government Assessed Need.

The current Plan places disproportionate reliance on Canvey Island, despite its well-documented flood risks and infrastructure constraints. By contrast, as previously discussed, North West Thundersley offers a strategic growth location with lower flood risk, stronger transport connectivity, and greater public support. It is situated on higher ground, adjacent to the A127 corridor. These characteristics align with the principles set out in paragraphs 8, 11, and 20 of the NPPF (2024), which require that development be directed to locations that are sustainable, resilient and capable of supporting necessary infrastructure.

Claims that the North West Thundersley site is not viable due to policy restrictions by the local highways authority are unjustified in the plan and do not withstand scrutiny. Essex County Council is currently investing over £59 million in the Fairglen Interchange upgrade, in partnership with the Department for Transport and the South East Local Enterprise Partnership. This scheme includes new slip roads, signalised junctions, and pedestrian/cycle infrastructure, all designed to accommodate future housing and economic growth in South Essex.

Additionally, Essex County Council’s own infrastructure planning documents acknowledge that the A127/A130 corridor will come under increasing pressure due to planned growth, and that long-term options for further expansion remain viable, subject to funding and strategic coordination. There is no formal policy from Essex County Council opposing new junctions in principle. On the contrary, their planning approach is growth-responsive and designed to support development where it is justified and properly planned.

It is also important to clarify that, under the Duty to Cooperate provisions of the Planning and Compulsory Purchase Act 2004, and as reinforced by paragraphs 24–28 of the NPPF, Essex County Council would be legally obliged to engage with Castle Point Borough Council if North West Thundersley were included in the Plan. Their role would be to assess feasibility, cost and mitigation – not to veto strategic growth proposals. The Planning Inspectorate has consistently advised that infrastructure constraints must be addressed through joint working and evidence-based planning, not through informal objections.

Furthermore, while a portion of the site lies within the Green Belt designation, its inclusion can be justified under paragraph 143 of the NPPF, which allows for Green Belt release where exceptional circumstances are demonstrated. In this case, the circumstances are clear: Castle Point faces a significant housing shortfall, and North West Thundersley offers a location where growth can be delivered safely, sustainably, and with minimal environmental impact. The site is composed largely of ‘Grey Belt’ plotlands, light industrial units, and inaccessible land, and its development would affect fewer existing residents than other Green Belt sites. It is precisely the kind of strategic release that the NPPF envisages - one that protects more sensitive areas by concentrating growth where it can be properly supported.

In summary, the Plan should be modified to include North West Thundersley as a strategic growth location. This would not only improve the Plan’s soundness under paragraph 35, but also reflect a more balanced, evidence-led, and community-supported approach to development across Castle Point. It is a solution that meets the tests of sustainability, deliverability, and public interest — and one that should be embraced, not dismissed.

Conclusion and Recommendation to Modify the Plan

The Castle Point Plan is a defining document for our Borough. The Council should be commended for prioritising brownfield sites and engaging positively with residents throughout the Regulation 19 process.

However, I believe the Plan requires significant revision to meet the tests of soundness. Castle Point has significant infrastructure vulnerabilities, particularly in Canvey Island. The allocation of over 3,300 homes on the island must be reconsidered.

The Plan falls short in demonstrating a deliverable five-year housing land supply. Strengthening the brownfield strategy and including North West Thundersley would improve resilience and deliverability. Essex County Council is investing in infrastructure and would be legally obliged to cooperate. North West Thundersley offers a strategic opportunity for sustainable growth.

I also encourage the Council to release a more accessible version of the consultation. Many residents have found the Regulation 19 process difficult to engage with due to its length and complexity. A more user-friendly approach would help ensure that all voices are heard.

I urge Castle Point Borough Council to modify the Plan before submission to the Planning Inspectorate. With the right adjustments, this Plan can secure a future for our local area that is sustainable and in the best interests of current and future residents of our Borough. 

References:

§  National Planning Policy Framework (NPPF), December 2024:
“Paragraph 28: Strategic policies should be informed by agreements over the delivery of strategic priorities, including Statements of Common Ground to show how these have been addressed.” (p. 9)

§  National Planning Policy Framework (NPPF), December 2024:
“Paragraph 32: Plans should be informed by a proportionate evidence base, including robust assessments of reasonable alternatives.” (p. 11)

§  National Planning Policy Framework (NPPF), December 2024:
“Paragraph 180: Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and mitigating harm to biodiversity.” (p. 36)

§  National Planning Policy Framework (NPPF), December 2024:
“Paragraph 78: To maintain supply, local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing.” (p. 16)

§  National Planning Policy Framework (NPPF), December 2024:
“Paragraph 35: Plans should be positively prepared, justified, effective, and consistent with national policy.” (p. 12)

§  National Planning Policy Framework (NPPF), December 2024:
“Paragraphs 159 & 161: Local plans should apply a sequential approach to steer development away from areas at highest risk of flooding. Development in such areas should only be allowed where it can be made safe without increasing flood risk elsewhere.” (p. 29)

§  National Planning Policy Framework (NPPF), December 2024:
“Paragraph 143: Local plans should define Green Belt boundaries clearly and release Green Belt land only in exceptional circumstances.” (p. 24)

§  Essex County Council Infrastructure Plan, 2024:
“The Fairglen Interchange upgrade, involving £59 million investment, is underway to improve junction capacity, pedestrian and cycling infrastructure, and accommodate planned growth on the A127 corridor.” (p. 7)

§  Planning and Compulsory Purchase Act 2004:
“Section on Duty to Cooperate: Local planning authorities must engage constructively, actively and on an ongoing basis with other authorities on strategic planning matters.” (p. 14)

PREVIOUS...

AUGUST 2024 - the first stage of the Consultation for the Local Plan

Castle Point Plan Draft (Regulation 18) Consultation- Rebecca submitted her views on the local plan options consultation online. My full submission is at the bottom of this page.

My Main Points are as follows:

1. A large number of the brownfield sites identified as options for development are parts of key community infrastructure and should be removed as options at the earliest possible opportunity. These include a fire station, a police station, several supermarkets, large council owned town centre car parks, churches, two community halls, three libraries, health centres in Benfleet, Thundersley and Canvey and USP (formerly SEEVIC) College. Under no circumstances should these key pieces of community infrastructure be demolished in favour of residential development, and I am frankly baffled at their inclusion in this consultation.
2. The Council should look to preserve the Green Belt sites on the urban periphery of our Borough that local residents clearly attach a great deal of value to. The protection of fields in the Green Belt used for farming and grazing should be a priority of the plan. I am pleased that the Council is looking to preference brownfield land for development. However, if the Labour Government effectively force you to allocate Green Belt for development, the ONLY site in Castle Point that should be considered for residential development by the Council is what is listed in the plan as the North West Thundersley site. This site is shielded from the rest of the Borough by Woodside Hill encompassing Woodside Park, which should be retained in its entirety and enhanced. Various capacity studies in the past have identified the site as suitable for several thousand units of the Borough’s housing need, and its density could be intensified to ensure other Green Belt sites are protected. Its realisation would affect existing residents far less than any other Green Belt site on the urban periphery of our Borough. As it is mainly plotlands, light industry and sites that cannot be accessed or viewed by residents, its utility as Green Belt is minimal especially when compared to other Green Belt sites listed as options in this consultation. However, if it is to be included into the plan, the Council should absolutely guarantee that a much needed extra road access into and out of the Borough and onto the wider road network via the A127 or the A1295 should be included. The Council should also examine the viability of moving Manor Road Trading estate to the area instead and redesignating the area for residential development. This would remove the problem of lorries heading to and from the estate having to traverse local residential roads.
3. I am also very concerned that the Council are asking residents whether they support development on a large number of both brownfield and Green Belt sites before their ‘deliverability’ has been established, or even before the Council have asked if the owners are willing to actually build homes on their site. The deliverability of all sites will have to be determined before Councillors are presented with options for site selection, but I believe the deliverability, or at least the availability, of sites should have been determined before the public consultation. Residents will feel deceived if they take the time and effort to either support or oppose the inclusion of specific sites local to them for development in the plan if those sites never had a prospect of being delivered in the first place. It also opens up the Council to the very serious risk that Councillors may include brownfield sites that are not deliverable into their site selections in an attempt to preserve Green Belt sites and reflect residents’ wishes, only to have their selections challenged at examination by developers looking to include their Green Belt sites for development instead. Undeliverable sites should be removed from consideration as soon as possible.

I am further concerned about this following the announcement by the new Deputy Prime Minister, that Castle Point is likely to face a housing target that would mean an extra 6000+ units built in our Borough. The Government may well look at the options presented in this document and believe that together they represent the true capacity of Castle Point for development, when it is in reality far from the case, many of these sites are undeliverable and our local infrastructure would be stretched beyond breaking point.

4. Brownfield development around our town centres should be supported as one of the main solutions for our local housing need that would also support our town centre businesses by growing the market on their doorstep. This however should not come at the expense of commercial land and employment sites and not at a density level that would put intolerable strain on local infrastructure. Some floors of flats above a ground floor reserved for commercial and employment activity should be the preferred solution for such sites as long as adequate and realistic parking can also be provided for the development.
5. The Council should submit a fifteen-year plan for development rather than a twenty-year plan. There is no legal requirement for the Council to submit a twenty-year plan and by adding five years to the length of the plan, it means that the Council have to accommodate five more years of housing need in their plan. In December last year you as the Council conducted your own local housing need study, as was permitted under the previous Government, which came up with a need of 255 homes a year. By adding another 5 years to the plan, you are having to find sites for 1275 extra homes that are not necessary. The Council should reduce the length of the plan to 15 years and plan for 1275 fewer homes.
6. I am personally very dismayed that the Council failed to use the lower assessed housing need figure they contained in the local housing need report they released in December 2023 to defend against recent speculative planning applications and appeals on Green Belt. It would have seriously strengthened their case. I understand the Council does not want to run the risk of the report being legally challenged before the local plan examination, but by then there may well be very little Green Belt left worth defending if developers keep exploiting this legal weakness.
7. Flooding needs to be a key concern of this local plan. Localised flooding is a key concern of many residents, particularly on Canvey, and special attention should be given to localised flood prevention measures and the capacity of the existing drainage system to take further runoff from development. Similarly, the Council has made no reference to any outcomes of the Section 19 Flood Report released in 2022 regarding the flooding of dozens of homes across Castle Point in Autumn 2021.
8. I am pleased that there are references to an additional road access for Canvey Island in the issues and options document. However, the Council should start actively seeking it now. The Council should immediately reinstate work on the Canvey West Access Taskforce that has been dormant for two and a half years, bring all the parties together and start planning now. I have always been willing to take funding requests to the Government but as of now the Council have not produced a single piece of paper for a proposal.

2024 Take part yourself

Castle Point Borough Council has set up a number of face-to-face events to answer residents’ questions and record their views on the Local Plan issues and options document they have published. This includes options for future development sites across the whole of Castle Point!

I know residents have strong feelings about possible development options in their area and it’s important everyone engages with the consultation events. This is after all about the future of the Borough!

Please do make it to one of Castle Point Borough Council’s local plan consultation events below if you can.

Canvey, 16th Aug 2024 - 19:00 to 20:30 - St Nicholas Church Hall &  21st Aug 2024 - 14:00 to 15:30 - St Nicholas Church Hall

Daws Heath: 9th Aug 2024 - 19:00 to 20:30- Daws Heath Social Hall & 5th September 2024 - 14:00 to 15:30 - Daws Heath Social Hall

Hadleigh: 22nd Aug 2024 - 19:00 to 20:30- Hadleigh Baptist Church

Benfleet: 7th Aug 2024 - 19:00 to 20:30 - Richmond Hall & 14th Aug 2024 - 19:00 to 20:30 - Richmond Hall

Thundersley: 6th Aug 2024 - 19:00 to 20:30 - St George’s Hall, 13th Aug 2024 - 14:00 to 15:30 - Castle Point Borough Council Offices,  15th Aug 2024 - 14:00 to 15:30 - Castle Point Borough Council Offices, 20th Aug 2024 - 14:00 to 15:30 - Runnymede Hall (behind the Castle Point Borough Council Offices) & 4th September 2024 - 19:00 to 20:30  - Runnymede Hall (behind the Castle Point Borough Council Offices)

A number of residents have raised concerns with me about the lack of consultation events on the eastern half of Canvey Island and in the eastern half of Hadleigh. I am writing to the Council and asking them to set up more events in those areas so face-to-face consultation is as accessible as possible to all local residents. Online consultation events will also be available, and I understand further details will be published by the Council in due course.

You can submit your views on the local plan options consultation online. You don't have to answer every single question.

View the options document

Rebecca Harris' Answers to questions on local plan issues and options document:

Q1. What are your views on the draft Vision for the Castle Point Plan?

I think the vision is good, but there should also be a commitment to the preservation of the semi-rural character of the Borough through the protection of the Green Belt treasured by local residents adjacent to the urban periphery. I am pleased to see mitigation of climate change and its effects in the vision, but I think it needs to be much more explicit about protecting residents from the dangers of flooding. There should also be greater emphasis on the provision of improved local infrastructure.

Q2. What are your views on the issues that need to be addressed on Canvey Island within the Castle Point Plan?

A lack of infrastructure, specifically a third road access for the island. I am pleased to see this recognised in the document but the Council should commit to recommencing work on the Canvey West Access Task Force to maximise the chances that an access is actually delivered in the plan period. The protection of residential properties and businesses from flooding should also be a key issue, as should the mitigation of the two top-tier COMAH sites on the island and the preservation of the local environment. The plan should not attempt to increase the residential density of the island without improvements to local infrastructure.

Q3. Do you have any comments on how we should improve access to and through Canvey?

I am pleased a potential third road access is listed in the local plan options document. I am however disappointed to see potential problems with it listed before a formal scoping has been done. The Council should recommence work on the Canvey West Access Task Force immediately and pursue a third road access for the island as the most important transport priority for the Borough. The fact work on the Canvey Third Access Taskforce that myself and many other residents campaigned so hard for, has been abandoned by the Council since 2022 is inexcusable. It has unnecessarily set back the timeframe for achieving a third road access by years. All the other minor potential transport improvements listed would be beneficial and should also be explored.

Q4. What changes or improvements would you like to see in Canvey Town Centre?

It needs to be more welcoming and become more of a destination for retail and experience-based economic activity like meals out and socialising with friends and family. More events would be beneficial as would an expansion of the market and improved parking. Ideally free parking for at least three hours to support local traders and increase footfall in the Council’s own shopping centre.  I would also like to see the loading bay area improved as it is an unsightly ‘Welcome to Canvey’ when approached from Elder Tree Road.

Q5. What type of development would you support within the Canvey Town Centre East development cluster? & Q6. What type of development would you support within the Canvey Town Centre West development cluster? & Q7. What type of development would you support within the Long Rd development cluster? & Q8. What types of development could be considered as appropriate within the South & East parts of Canvey Island? & Q13. Do you have any views about the potential Site Allocations in Canvey?

The Council should prioritise protecting the Green Belt. Please see the attached list of brownfield sites I think could be suitably redeveloped. Please take the notes attached to each individual site into account regarding the type and density of development I believe would be appropriate.

Q9. What improvements to the Seafront Entertainment Area would you like to see?

Improved access and improvements to the visual environment. I would support whatever practical improvements local business owners would suggest as they know what would improve the experience for their customer base better than anyone else. Whatever improvements are implemented however, they should also have the support of local residents who live in or nearby the area.

Q10. Do you have any comments on Canvey’s port infrastructure?

Ultimately the two top tier COMAH sites located on the Port of London Authority land should be relocated. Until then, the Council should do all they can to ensure the safety and security of the sites is maintained and the local environment is protected for the benefit of residents.

Q11. What improvements should be made to the South & West Canvey Wildlife Corridor?

Improvements that increase the biodiversity of the corridor and that improve access for local residents for recreational and educational purposes. Any improvements or changes to the condition of the landscape however should fully take into account any implications they may have for flood risk in the area.

Q12. What approach to development in the West Canvey Employment Area (Charfleets Industrial Estate and the Canvey Retail Park) would you support?

An approach that leads to more well-paid jobs on the island and that local residents fully support.

Q14. What are your views on the issues that need to be addressed in Benfleet within the Castle Point Plan?

Stretched local transport and roads infrastructure, the need to improve the local town centres as a destination for local retail and experience based commerce like eating out and socialising. Local green spaces should also be preserved and enhanced where possible. Flooding issues around the council-owned South Benfleet playing fields, and others identified to properties in the Section 19 report on the floods that took place in the Autumn of 2021. The Benfleet conservation area should also be improved and enhanced.

Q15. What changes or improvements would you like to see in South Benfleet Local Centre?

I think the environment of the town centre needs to be improved and made more inviting to ensure it is an attractive destination for local residents and for potential customers travelling through it.

Q16. What type of development would you support within the South Benfleet development cluster? & Q17. What type of development would you support within the Benfleet Station development cluster? & Q18. What approach should be taken to development in and around the South Benfleet Conservation Area?

Please see the attached list of brownfield sites I think could be suitably redeveloped. Please take the notes attached to each individual site into account regarding the type and density of development I believe would be appropriate.

Q19. What changes or improvements would you like to see in Tarpots Local Centre?

I think parking needs to be improved there as the bays actually along the south side of the Tarpots parade are too small. I would like to see general improvements to the environment in the area to improve its attractiveness as a local destination for convenience shopping and experience based commerce like eating out and socialising. Parking should be improved in general for the benefit of existing businesses and customers.

Q20. What type of development would you support within the Tarpots development cluster?

Please see the attached list of brownfield sites I think could be suitably redeveloped. Please take the notes attached to each individual site into account regarding the type and density of development I believe would be appropriate.

Q21. What types of development could be considered as appropriate within the Manor Trading Estate?

Ultimately, I believe the Manor Trading Estate should be relocated and the land should be redesignated for residential use. This would take many lorries and other heavy goods vehicles off residential roads in that part of Thundersley. However, if this is deemed unviable then development for employment uses that facilitate the creation of well-paid jobs and do not see an inappropriate increase in heavy goods traffic in the area should be encouraged. Ideally I would like to see a new road put in to the north of the trading estate connecting it to the A127 or the Rayleigh Spur roundabout.

Q23. What improvements should be made to the South Benfleet Playing Fields area?

Anything that improves the environment or the utility of the park for local residents should be considered. The capacity and function of the playing fields as a flood water storage area should be improved, and improvements that deal with persistent flooding issues around the north east of the park should be prioritised. The building in the park accessed via Brook Road that houses changing rooms, kitchens and a small seating area is a grossly underused community asset that could be used by far more local groups and for a range of purposes.

Q24. Do you have any views about the potential Site Allocations in Benfleet?

The Council should prioritise protecting the Green Belt. Please see the attached list of brownfield sites I think could be suitably redeveloped. Please take the notes attached to each individual site into account regarding the type and density of development I believe would be appropriate.

Q26. How should the management of Benfleet and Southend Marshes be approached in the Plan?

Expert advice should be sought on the matter with the aim of preserving and promoting local wildlife and the natural environment, whilst also maintaining any and all functions relating to the mitigation of local flood risk. Although part of the area is marked as Green Belt, as it is marshland inaccessible for many months of the year it should not be considered in calculations to determine the percentage of available Green Belt across the whole Borough allocated for development in each option of the plan.

Q27. What improvements should be made to the Hadleigh Castle Country Park area?

Improvements that enhance access and enjoyment for family-based outdoor recreation. This includes promoting learning about the unique history and environmental benefit of the area whilst preserving the local historical heritage of the area. I do not believe any of the farmland in the area should be considered for residential development.

Q28. What changes or improvements would you like to see in Hadleigh Town Centre?

I think the environment of the town centre needs to be improved and made more inviting to ensure it is an attractive destination for local residents and for potential customers travelling through it. Specifically, the Council should consult with residents and decide the future of the former Crown site in the town centre, and indeed work with residents, businesses and community groups to create and deliver a practical vision for the future of the whole ‘island site’ in the town centre.

Q29. What type of development would you support within the Hadleigh Central development cluster? & Q30. What type of development would you support within the Vic House Corner Roundabout development cluster? & Q31. What type of development would you support within the Hadleigh East development cluster? & Q32. What opportunities for improvements and development within the A13 corridor in Hadleigh are there? & Q33. Do you have any views about the potential Site Allocations in Hadleigh?

The Council should prioritise protecting the Green Belt. Please see the attached list of brownfield sites I think could be suitably redeveloped. Please take the notes attached to each individual site into account regarding the type and density of development I believe would be appropriate.

Q34. What are your views on the issues that need to be addressed in Daws Heath within the Castle Point Plan? The biggest issue in Daws Heath is the inclusion of two Green Belt sites, the site north of Daws Heath Road and South of Daws Heath Road, into the options document identifying them for possible development, when myself and hundreds of residents campaigned hard against development on the sites and the Council just fought and won two appeals against developers over them! These sites should not be developed and when other potential Green Belt sites have been excluded as possible options, I am sure many residents are confused and more than a little disheartened to see them being considered as development options.

Q35. Do you have any views about the potential Site Allocations in Daws Heath?

Please see the attached list of brownfield sites I think could be suitably redeveloped. Please take the notes attached to each individual site into account regarding the type and density of development I believe would be appropriate.

Q36. What are your views on the issues that need to be addressed in Thundersley within the Castle Point Plan?

The village feel of the area should be promoted and the town centre should be enhanced. The dire traffic issues along the Rayleigh Road around The Woodmans Arms and up to Rayleigh Weir needs to be addressed and the Common and surrounding area should be protected as a recreation space with immense utility for local residents.

Q37. What type of development would you support within the Kiln Rd development cluster? & Q38. What opportunities for improvements and development within the A13 corridor in Thundersley are there? & Q40. Do you have any views about the potential Site Allocations in Thundersley?

The Council should prioritise protecting the Green Belt. Please see the attached list of brownfield sites I think could be suitably redeveloped. Please take the notes attached to each individual site into account regarding the type and density of development, I believe would be appropriate.

Q41. What do you think the Castle Point Plan housing requirement need figure should be? Please select your preferred choice from the options below:

Other: 15 years rather than 20 years of the annual local housing need. Castle Point Borough Council does not need to submit a local plan that accommodates 20 years worth of development when the Government only mandates local authorities to find sites for 15 years worth of housing need.

I am personally very dismayed that the Council failed to use the lower assessed housing need figure they contained in the local housing need report they released in December 2023 to defend against recent speculative planning applications and appeals on Green Belt. It would have seriously strengthened their case. I understand the Council does not want to run the risk of the report being legally challenged before the local plan examination, but by then there may well be very little Green Belt left worth defending if developers keep exploiting this legal weakness.

Q42. Please rank the following options in your order of preference for delivering the housing growth we need: & Q43. Do you have any comments on the implications of the Options (for development) opposite? & Q44. Do you have another preferred option, which may include a combination of the above, or alternative land sources? & Q46. What types of development could be considered as appropriate within the North West of Thundersley area?

I have issues with all of these options and indeed the level of need currently planned for that necessitates them as per my answer to the previous question. That notwithstanding, I would prefer the Council keep development within the existing urban area. However as previously mentioned, if the new Labour Government effectively force the Council to consider Green Belt for development, either allocating the area NW of Thundersley for residential development, or moving Manor Trading estate there and redeveloping that for residential use, should be the only Green Belt option considered. Even then, it would have to come with a new road access onto the A127 or Rayleigh Spur roundabout/ Fairglen interchange to improve the borough’s access to the wider road network and not add further pressure to the already congested Rayleigh Weir and Sadlers Farm junctions.

I believe the potential housing capacity of that site is higher than indicated by the Council and believe it is indicated as such by other previous studies into the site. If as stated the Government do in effect force the Council to allocate the site for housing, then its housing density should be increased as necessary to meet all remaining need and ensure other Green Belt around the Borough that local residents cherish are protected.

Q45. What do you think about the sources of urban land identified, and how should they be managed if they are redeveloped, for example, should existing service capacity be retained on site or within the borough?

A large number of the brownfield sites identified as options for development are parts of key community infrastructure and should be removed as options at the earliest possible opportunity. These include a fire station, a police station, several supermarkets, large council owned town centre car parks, churches, two community halls, three libraries, health centres in Benfleet, Thundersley and Canvey and USP (formerly SEEVIC) College. Under no circumstances should these key pieces of community infrastructure be demolished in favour of residential development and I am frankly baffled at their inclusion in this consultation. The deliverability of all the brownfield sites will have to be determined before Councillors are presented with options for site selection, but I believe the deliverability, or at least the availability, of sites should have been determined before the public consultation. Residents will feel deceived if they take the time and effort to either support or oppose the inclusion of specific sites local to them for development in the plan if those sites never had a prospect of being delivered in the first place. It also opens up the Council to the very serious risk that Councillors may include brownfield sites that are not deliverable into their site selections in an attempt to preserve Green Belt sites and reflect residents’ wishes, only to have their selections challenged at examination by developers looking to include their Green Belt sites for development instead. Undeliverable sites should be removed from consideration as soon as possible.

Q47. Please rank the following outcome options in your order of preference to show what you feel should be delivered alongside new housing in the Plan: & Q48. Are there any other priorities not listed above which you feel should be delivered alongside new housing in the plan? & Q49. What benefits could justify increased density in new development in the borough? & Q50. Are there any other benefits that you think it would be appropriate for higher density development to deliver?

I think all the options listed are important and hard for local residents to rank against each other. I think any other priorities or benefits listed by local residents should be given the utmost consideration.

Q81. Do you have any views on protecting and enhancing the borough’s heritage assets as set out above?

Compared to most other districts, Castle Point has relatively few heritage assets and historical buildings given its long history of settlement dating back to Saxon times. Protection of what is left of the Borough’s local heritage should be a key part of the local plan proposals. This should include heritage buildings from more recent history, including the Canvey Transport Museum, the Edwardian era façade of Hadleigh Old Fire Station, the façade of the old Canvey Island Urban District Council Offices on Long Road, and the historic farm and accommodation buildings on Hadleigh Farm

Q90. How do you feel the risk of flooding should be managed in new development?

I think it is important that any new development should have to prove its resilience to flood risk, but also a thorough assessment of any downstream implications for the capacity of existing flooding infrastructure needs to be undertaken. The true capacity of some local flood risk assets is unknown and many of the assets are insufficiently mapped or not mapped accurately. The true capacity of flood risk assets downstream from all development sites should be fully explored and mapped so that developers, the Council, and local residents, can be absolutely sure that the flood mitigation measures put in place will not strain enough on existing assets to increase flood risk elsewhere.

Q97. Would you support seeking a higher than 10% Biodiversity Net Gain requirement? & Q98. Would you support the introduction of an Urban Greening Factor seeking to increase biodiversity in urban areas?

Yes.

Q110. Which of the following active travel infrastructure improvements would you be in favour of?

All of them are important.

Q112. What type of road infrastructure needs to be improved over the Plan period?

All the options listed are important but specific improvements to road access onto Canvey Island should be added as an option as well.

Q113. Which parts of the highway network should be prioritised for improvement? & Q114. Are there any new transport routes that you feel should be introduced to provide better/quicker routes to ease congestion?

There are currently only three ways into and out of the Borough, via Sadlers Farm, Rayleigh Weir, or East on the A13 and residential roads to Southend. As detailed in previous answers, a third road access for Canvey Island should be the number one transport priority of the plan and the Council should restart work on the Canvey West Access Taskforce immediately. The Council should also seek to secure another access onto the A127 or the Rayleigh Spur roundabout to ease congestion on existing routes.

Q118. What do you think about the proposed parking standards?

You do not describe them in detail in the document so it’s very hard for residents to answer this question! There should always be sufficient off-street parking for each development so local residential roads do not have to take the strain of extra parking from the development.

Q119. What measures would help to reduce the impacts of rat-running on unsuitable routes in the borough?

Although those options may help, the biggest thing that the new local plan could do to prevent ‘rat running’ on unsuitable roads is plan sensitively to minimise congestion on the main routes that residents attempt to avoid via rat running and actively allocate funds from local development to ensure they are improved.