Please find the following objections: -

10 off Unsound Reasons.
1. Highway and Traffic Implications

Proposals for moving employment to out of town locations, at either end of the district, with no existing public transport links, are contrary to government policy PPG4 & PPS1. It also contravenes the Core Strategy's stated aims of reducing carbon emissions; reliance on car transport and
providing "an integrated network of cycle paths".

The Core Strategy also contravenes its own policy T1 and is unsound.

2. The Transport Evidence Base has not been re-evaluated following the decision to impose extra housing on the Eldon Way & Foundry Industrial Estates. ECC Highways have confirmed that the B1013 is running at 72% of its maximum theoretical capacity) and the effect of extra housing in Hockley (as well as Hawkwell) has not been re-evaluated and it is unclear what improvements will be required and whether they can be physically achieved.

Thus the proposals are not founded on a robust and credible evidence base and are unsoun

3. RDC are proposing to scatter housing across the district in around 12 or sites but no detailed consideration has been given to the implications for highways across the District. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts

It is clear that (i) the combined impact of scattering houses across the District and (ii) relocating Eldon Way/Foundry Industrial Estates with no public transport services will exacerbate existing problems. It is clear that the extent of improvements required is both unknown and not funded and the proposal is unsound.



4. PPS12 4.9 states "The infrastructure planning process should identify, as far as possible: infrastructure needs and costs". Neither needs nor, especially, costs have been identified and the Core Strategy is therefore unsound.

The Core Strategy proposes to fund infrastructure improvements through use of Standard Charges. However, no detail is provided and no attempt made to identify the likely scale of such charges. It is therefore unclear if use of Standard Charges is financially viable.

5. SERT is put forward as a solution to reducing car use but it will only skirt the edge of the district and the Core Strategy acknowledges there is only "potential" to do so in the future. SERT is not realistic or reliable a solution and the proposal is therefore unsound.

6. Previous consultations ignored by RDC:
The Hockley Parish Plan (dated 2007). The proposals ignore the 95% rejection rate of respondents to RDC's own Hockley Area Plan (HAAP) Consultation (2009), which included specific proposals for Eldon Way (although HAAP did not even mention the adjoining Foundry Industrial Estate). Why have a consultation and ignore it?

Thus the proposals are not founded on a robust and credible evidence base and are unsound

7. RDC not consulted on proposals to relocate the Eldon Way and Foundry Industrial Estates

EW; CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" absolutely no consultation on concept of moving EW businesses entirely

FIE; has never even been previously mentioned in any plan version; CS states omission was due to typing error!

Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

Thus proposals are not founded on a robust and credible evidence base and are unsound.

8. The Core Strategy proposals pre-empt the next stage of the HAAP consultation and neither defines its status relevant to the other plan and subsequent priorities.

There are also inconsistencies between the Core Strategy & HAAP.

If a decision is taken as part of the Core Strategy, to relocate all the existing businesses on the two estates, it will set a legal precedent which HAAP will need to follow and renders the next stage of HAAP virtually redundant. Particularly given the 95% rejection rate of respondents to the
previous round of HAAP such an approach is entirely undemocratic and unsound

9. PPS12, 4.6, states that Cores Strategies should be flexible and "should be able to show how they will handle contingencies"
Several large planning applications have already been submitted to RDC proposing developments outside the Core Strategy which
does not indicate how such applications will be handled and does not comply with PPS12. Neither have RDC been able to advise
residents how such changes will be made and the strategy is unsound.

10. The CS misrepresents the findings of The Retail & Leisure Study (R&LS) 2008.

The CS states "The R&LS states Hockley has great potential and has a need for additional convenience floorspace".

Whereas, the R&LS actually states:

1) "does not lend itself to a food store capable of retaining a significant proportion of main food shopping expenditure.
2) "there is no immediate capacity for additional floor space."
3) "recommend that focus be maintained on developing Hockley's existing strengths."
4) " the Council may wish to consider reclassifying Hockley from a town center, to a district center".