Dear Vistry,

I was very disappointed to read your consultation for your planned development at the Glyders.

I was also disappointed not to be specifically invited to give my own views on the consultation as the local MP. No doubt this is because you would be unlikely to like what I have to say.

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.

I reject entirely the premise you put forward in your material that “the principle of developing the land off Glyders has been established”. It most certainly has not! In your material, you base this argument on the fact that the Planning Inspector found the last plan ‘sound’ in draft form. This argument is fatally flawed for two reasons. Firstly, although the Planning Inspector found the draft plan ‘sound’, the Green Belt boundaries remain in place unless a local plan altering them is adopted. As you yourself acknowledge, this did not happen. The inspector did not, as you indicated in your material, ‘release’ your site for development, but instead stated that the draft plan it featured in was sound. That draft plan has not been adopted by the council, so its protected status as Green Belt remains entirely unchanged. Secondly, the inspector only agreed that exceptional circumstances exist to justify Green Belt development because of arguments put forward as ‘evidence’ by council planning officers. That ‘evidence’, along with the rest of that draft plan, has been withdrawn and I understand new evidence is being prepared.

This September, several months after the 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. Essex County Council made a public commitment at its 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 site is adjacent to Benfleet Downs, which is regarded in planning terms as a ‘Site of Special Scientific Interest (SSSI)’ because of its abundant wildlife and biodiversity. In your material published so far, you have made no mention of the guidance you should have received from Castle Point Borough Council regarding applications close to SSSI sites, or indeed any guidance you sought or received from Natural England regarding how you are going to ensure your proposals do not affect the site during construction or after completion. Residents and I expect to see this information. Any development that negatively affects an SSSI site in Castle Point is unacceptable.

Finally, regarding road transport, all vehicles entering or exiting your proposed development site will have to join the B1014, either at Essex Way or Benfleet High Street by Benfleet Station. This highly congested route is one of two routes on and off Canvey Island. Roadworks or problems on the road frequently cause not just South Benfleet, but all of Canvey Island to grind to a halt as well. Development such as this, which causes extra traffic on that route, should not be considered until the transport infrastructure for Benfleet and Canvey has been significantly improved.

Thank you very much for consulting with local residents on your proposals and giving them the chance to express their opinion on them. 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