Dear Persimmon and Redrow Homes,

I was very disappointed to read your consultation for your planned development at Jotmans Farm.

Residents and local councillors of all parties have fought hard against the development of this site since 2010. The Secretary of State REFUSED a planning appeal for development on this very site in 2017 (application ref: CPT/122/13/OUT) and despite appeals submitted on behalf of developers in the High Court, that refusal still stands. You are fully aware that the development of this site has no support within the local community.

The land is designated as Green Belt and the National Planning Policy Framework clearly states, “Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans”. Castle Point Borough Council rejected, almost unanimously, the last draft local plan brought to them by council planners that included Green Belt development earlier this year. Although the council has not had a local plan in place for some time, they are currently in the process of preparing another draft and I am sure they fully intend to adhere to Government policy while doing so. You should make the arguments you wish to make regarding the site in the emerging local plan process and let democratically elected politicians decide its suitability as a strategic site. You should not try to force the issue now with a planning application.

This September, several months after the last draft local plan was evaluated by the Planning Inspector, a report under Section 19 of the Flood Water Management Act 2010 was released by Essex County Council, acting as the Lead Local Flood Authority, into the flooding that occurred across the Borough on the 21st September 2021. One of the many recommendations in the report was that two key documents that form the basis of the evidence used by council planning officers regarding flood risk in Castle Point, the Local Flood Risk Management Strategy and Surface Water Management Plan (including existing hydraulic modelling), are reviewed and updated, with a particular focus on increasing risk due to climate change. The local Essex County Councillor for South Benfleet secured a public commitment from Essex County Council at their Full Council meeting on 11th October 2022 that this recommendation will be followed and work will begin imminently. This proposal is premature, and time should be given for Castle Point Borough Council to update their planning policies to take the report and any subsequent work into account. Not only does the Section 19 report show that the flood risk evidence used by planning officers in the last draft local plan is in desperate need of revision, but the concerns it raises about the existing drainage network mean it is unlikely you will be able to accurately determine the level of investment necessary for your proposed ‘Sustainable Urban Drainage Scheme’, to ensure it will not cause unacceptable strain on existing surface water management systems in Castle Point and exacerbate flood risk for existing properties. Indeed, I also doubt whether you will be able to accurately determine whether such a scheme is even possible given the inadequacy of the wider drainage network. The scale of your proposed development, and its location close to the outfalls of the entire drainage network for Benfleet into Benfleet Creek is of particular worry. Low-lying properties in the east of the existing Jotmans estate already suffer from residential flooding and flooding asset maps in that part of Castle Point are notoriously unreliable.

Whilst I disagree with your proposals as a whole, I appreciate your intention to include a primary school, healthcare facility and a residential home within the development, and indeed your efforts to include tree screening for existing residential properties. I also appreciate your plans to limit the traffic impact on the already congested road network in Benfleet. However, this development would put an absolutely unacceptable strain on the A130 for Canvey residents who need to enter and exit Canvey Island. Canvey has two routes on and off the island converging at the same roundabout at Waterside Farm. The inclusion of access to the A130 from this site would add to the regular congestion experienced by Canvey residents on this critical route. The fact that you may well intend to add an extra lane to parts of the A130 does not tackle the main cause of congestion on the A130, which is the capacity of Sadlers Farm Roundabout. No improvements to the traffic capacity of Sadlers Farm have been proposed with this development.

Finally, although I appreciate that you are undertaking some consultation with residents on your proposals, I am very disappointed at some of the arrangements you have made. The decision to hold your walk-in exhibition for one day during working hours is very disappointing, as a number of residents who would otherwise attend are unable to attend due to work or other commitments. I also believe that you should have done more to engage with residents on Canvey Island, who would also very much be affected by your proposals because they include highways access to the A130. When I raised this matter with you last week and offered to assist you in finding a suitable venue for an additional exhibition at the weekend, that would also be more accessible to Canvey residents, I was further disappointed that you declined my offer. Although you do indeed offer online 1-1 appointments, which admittedly may be more suitable for some, you say in your own material that slots are limited and there are a large number of residents that no doubt wish to express their opinion and ask further, and more detailed questions face to face.

I do hope you will take my comments and the comments of all the local residents who respond to this consultation on board. I urge you not to submit this application for the reasons above and to instead focus on developing smaller brownfield sites around the Borough that will provide homes for local people, without seeing the loss of undeveloped Green Belt that residents truly treasure.

Kind regards,

Rebecca Harris MP

Member of Parliament for Castle Point