Ahead of the submission deadline for the Castle Point Plan Draft (Regulation 19) Consultation, Dame Rebecca Harris - Member of Parliament for Castle Point - has submitted further comments to the Council outlining her concerns about the proposals.
Rebecca responded to the full consultation last month and you can find her comments here: www.rebeccaharris.org/new-draft-local-plan-2023-2043
The latest submission focuses on the proposed 'Grey Belt' sites to be included within the Plan.
You can find her full letter to the Council below:
"Dear Castle Point Borough Council,
Please add these comments to the previous submission on your Regulation 19 Draft Local Plan. My opinion about the ‘Soundness’ and ‘Legality’ of the plan have not changed.
For several decades now residents across Castle Point have fought tirelessly to protect our Green Belt from inappropriate development. Time and again local people have stood together to defend fields, woodlands and open spaces that give our Borough its unique character and identity. These battles have often been long and difficult, but our communities have prevailed because the case for preservation has always been strong.
The Government’s so-called “Grey Belt” is intended to capture parcels of Green Belt land that are derelict, fragmented, or of genuinely low environmental and amenity value. It was never meant to include land that is open, valued by communities, or performing the very purposes that the Green Belt is meant to serve.
There is no doubt that if the Council’s draft plan is found unsound, which I believe to be very likely because of the points outlined in my previous submission, the Inspector will direct the Council to look at what they have identified as ‘Grey Belt’ sites for development to attempt to better meet local housing targets. I fear that by classifying large areas of Castle Point as “Grey Belt” the Council are inviting the Planning Inspector to do the very thing residents have fought against for decades, release treasured Green Belt for development by mislabelling it as expendable. For that reason I set out below a site-by-site rebuttal to the Council’s classifications, explaining clearly why these parcels should not be treated as Grey Belt and why each continues to merit Green Belt protection.
West of Canvey Road (GB1)
The Council claim the parcel lies adjacent to the urban edge and therefore makes a weaker contribution to openness¹.
West of Canvey Road is essential to the integrity of Canvey Island’s landscape. Far from being derelict, it provides a critical buffer between residential areas and hazardous COMAH-designated industrial sites. The land also performs a floodplain function in a borough where surface water and tidal flooding are already major concerns. Its open aspect gives relief from urban intensity and provides resilience against climate challenges. Reclassifying such a strategically important piece of land as Grey Belt is wholly inappropriate and contrary to the NPPF’s requirement to safeguard land from encroachment².
East of Canvey Road (GB2)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be is that it is adjacent to existing built area was and previously considered for development, therefore seen as lower value¹.
This parcel is wrongly characterised. East of Canvey Road provides separation between industrial uses and residential communities. Its open nature prevents ribbon development along this strategic road and offers necessary land for drainage and flood resilience. Canvey is already over-allocated with housing in this draft plan, to designate such land as Grey Belt ignores the island’s unique vulnerability and the strong evidence from Essex County Council’s Section 19 Flood Report³.
Land South of Charfleets (GB3)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be the proximity to Charfleets industrial estate and perception of reduced “connectivity”¹.
Land South of Charfleets forms a vital open break preventing sprawl from overwhelming this industrial area. Its greenery offsets industrial activity, provides amenity value and performs drainage functions. To downgrade it because of industrial adjacency is to misunderstand Green Belt policy, the NPPF explicitly highlights safeguarding the countryside from encroachment as a key purpose².
Land off Glebelands (GB4)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that this is one of the small peripheral parcels of Green Belt land that make less of a contribution to strategic openness¹.
Glebelands is a green wedge that separates built form and protects the rural character of its surroundings. It is valued by residents for informal recreation and ecological richness. Parcel size is irrelevant, the NPPF sets no minimum thresholds and many small Green Belt sites perform critical local functions. To mark this as Grey Belt is to apply arbitrary tests not supported by national policy. I stood shoulder to shoulder with residents to fight previous attempts to develop part of this site at planning appeal stage. I am disappointed that those victories could be rendered meaningless by now designating it ‘Grey Belt’.
West of Benfleet (Jotmans) (GB5)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be based on somewhat fragmented ownership of the whole site (although large parts are in single ownership) and adjacency to existing residential development¹.
The Jotmans fields are one of the most important open landscapes in Castle Point. They prevent coalescence between Benfleet and surrounding areas, retain visual openness and support biodiversity corridors. Fragmented ownership does not diminish value, indeed it may reduce development pressure. Residents have repeatedly resisted speculative schemes here, demonstrating it’s continued community importance. Just as with Glebelands, I stood shoulder to shoulder with residents to fight previous attempts to develop part of this site at planning appeal stage and then the High Court. I am disappointed that those victories could be rendered meaningless by now designating it ‘Grey Belt’.
Land between Felstead Road and Catherine Road (GB6)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that its irregular shape and limited access diminish its strategic contribution¹.
Shape and access are not tests of Green Belt worth. This parcel prevents outward sprawl from nearby roads and maintains openness in a heavily developed part of the Borough. It also supports biodiversity and drainage in an area prone to surface water flooding. To mark it as Grey Belt is to ignore its real-world function.
The Chase (GB12)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that it is adjacent to residential development and the fact that has been assessed as having a lower contribution to the functions of Green Belt in SLAA¹.
The Chase is an important open space separating built form and providing amenity value. It preserves the pattern of settlement and is highly visible to local residents. To release this parcel would set a precedent for creeping infill that undermines the wider Green Belt.
East of Rayleigh Road (GB13)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that it is on the edge of the current settlement boundary and, previously promoted for development¹.
This land provides the rural setting of Rayleigh Road, preventing the blurring of urban boundaries. It supports biodiversity and acts as an accessible green corridor. Past promotion for development does not negate its current Green Belt functions. I stood with residents and the Council to fight against and win an appeal to prevent development on this site only last year. That victory should not be rendered meaningless by it being classified as ‘Grey Belt’ now.
North of Grasmere Road (GB15)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that it is a promoted site in SLAA and that is adjacent to and area of high housing noted¹.
These open fields prevent sprawl and retain a strong settlement boundary. They also provide informal recreation for nearby residents and support biodiversity. To call this Grey Belt is to undervalue the clear openness and function it provides.
East of Manor Trading Estate (NR3)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that the adjacent trading estate diminishes openness¹.
This parcel is a buffer between employment and housing, mitigating noise and pollution. It safeguards residents’ quality of life while preventing encroachment. Its role as a barrier to industrial creep is precisely the kind of function the Green Belt is meant to serve.
Land North of Thundersley Church Road & East of Downer Road North (GB19)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that it is on the edge of the current settlement and land promoted through the call for sites¹.
This land forms a distinct wedge of open countryside that prevents coalescence, supports biodiversity and protects Thundersley’s semi-rural setting. Its importance is recognised by residents who have fought repeated attempts to develop it.
Land to the rear of 329 Benfleet Road (GB23)
The Council’s justification for classing it as ‘Grey Belt’ land seems to that it is a small parcel promoted in call for sites¹.
Small parcels often have high value. This one prevents ribbon development and protects neighbour amenity. It should not be downgraded merely for its size.
Land off Shipwrights Close (GB24)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that it is a ‘gap’ site adjacent to housing¹.
This parcel prevents settlement creep and maintains green relief for residents. Loss would encourage incremental erosion of the Green Belt.
Land between Glen Haven and Ye Oaks, Bassenthwaite Road (GB26)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that it is on the edge of a plot promoted for development¹.
This site maintains the clear transition from settlement to countryside. Its openness is important locally. Downgrading it risks creeping coalescence.
Land Adjacent 298 Church Road (GB27)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that is was identified as a small parcel available for development in call for sites¹.
This land contributes to the green setting of Church Road. Small parcels can be disproportionately important to character.
Land off Glyders (GB31)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that it is an edge-of-settlement parcel¹.
Glyders prevents sprawl and supports biodiversity. Its downgrade is unjustified. I also believe this was also not a site featured in the regulation 18 consultation as a possible Green Belt development site. It would be unfair to local residents to consider it ‘Grey Belt’ out of the blue now.
Grandview Stables, Grandview Road (GB34)
The Council’s justification for classing it as ‘Grey Belt’ land seems to be that Green Belt used for equestrian purposes can be seen as less open and accessible and therefore make a lower contribution to the functions of Green Belt¹.
Grandview Stables is a classic rural land use. It preserves openness and supports recreation. It should not be downgraded.
The Council’s classification of these parcels as “Grey Belt” is unjustified and dangerous. None of the sites above meet the Government’s suggested criteria for such a label, they are not derelict, they are not redundant, and they are not expendable. Each makes a clear and demonstrable contribution to the Green Belt purposes set out in the NPPF.
By applying the “Grey Belt” label the Council are not protecting the Green Belt but putting it at risk. Should the Plan be found unsound, these will be the first sites the Inspector turns to. That is why I urge the Council to review their classifications and to give the residents who live around each site the explicit opportunity to argue against the label before the examiners are invited to reassign their fate.
Most importantly, I reiterate that the Borough’s housing needs cannot and should not be met by sacrificing these vital sites. A better and more balanced alternative, infrastructure-led growth at the appropriate location, namely North West Thundersley (the Blinking Owl site), is available and would protect the Borough’s most treasured open spaces while also giving the Plan a realistic prospect of being found sound. I think it is profoundly wrong and dishonest to not classify all or if not significantly more of the site as ‘Grey Belt’ when it features far more derelict, underused and plotland sites that provide little or no amenity to local residents.
I urge the Council to further consult with local residents specifically around ‘Grey Belt’ sites who many not be aware of the significance of the label and the implications of it if the Council’s plan is found flawed and unsound by the Inspector.
Kind Regards
Rebecca
References
- Housing Capacity Topic Paper (August 2025), pp.39–46. Table 13.10: list of Grey Belt parcels and commentary.
- “Land adjacent to settlement edge with reduced openness…” (p.40).
- “Fragmented ownership reduces contribution to Green Belt purposes.” (p.41).
- “Equestrian land considered less open.” (p.44).
- National Planning Policy Framework (Dec 2024)
- Para 138: Green Belt serves five purposes including preventing sprawl and safeguarding countryside.
- Para 143: Green Belt boundaries should only be altered in exceptional circumstances.
- Para 147: Inappropriate development is harmful and should not be approved except in very special circumstances.
- Section 19 Flood Investigation Report – Castle Point (Essex County Council, 2022)
- “Surface water flooding across Canvey Island demonstrates the severe limitations of drainage infrastructure.” (p.12).
- “Increased impermeable surfaces will exacerbate flood risk.” (p.23)."
