Paragraph 11.32 states that 18.1h of employment land will be de-allocated. However, Policy ED3 states that 'other approriate
uses' may include a proportion of employment uses. This means that the net loss of employment land could be less than 18.1h. If the net area is less, and the potential alternative uses are wider than just residential, the potential residential yield of 795 units (see Breakdown of Trajectory by Source p57) may be significantly less.

The Core Strategy does not deal with the issue of the timing inter-relationship between Policy ED3 and Policy ED4. There are a range of outcomes, the most extreme of which are

(a) the ED3 'deallocated' sites are redeveloped for other uses very quickly, but the new ED4 employment sites come forward more slowly. In these circumstances, there could be a severe reduction in the availability of employment land in the District with associated adverse affects on the local economy

(b) the ED3 'deallocated' sites are not redeveloped for other uses but the new ED4 sites come forward quickly. In these
circumstances there could be an excess supply of employment land in the District.

The Core Strategy should explicitly recognise these potential outcomes and include the contingencies that would be put in place to
avoid either an over supply or under supply of employment land.

Policy ED4 also does not consider the nature of the employment sectors which the deallocated ED3 sites serve compared to those which the new ED4 sites will serve. By definition, the employment sites proposed to be deallocated are poor quality industrial areas containing low grade premises. However, this also means these are inexpensive premises which are well suited to new start up firms or those types of firms which cannot afford high rental premises. In contrast, the new ED4 employment sites will be newly
built premises which will inevitably command a much higher rental which most of the firms displaced from the ED3 sites will not be able to afford. The Core Strategy should deal with this issue by providing evidence that there are sufficient other low rental premises available in Rochford District to accommodate displaced businesses. There is a danger that the Core Strategy proposals will have unintentional adverse consequences in removing a tier of low value employment accommodation and providing no viable replacement for the displaced occupiers.

Policies ED3 and ED4 need to be reassessed
- to deal with the timing interrelationship between Policies ED3 and ED4
- to confirm that sufficient low value employment premises remain in the District to accommodate the firms displaced from
the deallocated ED3 sites. If insufficient land remains, the sites proposed to be deallocated will need to be reassessed to see whether some would be more appropriately retained in low value employment use. This in turn, could impact on the housing yield anticipated from the ED3 sites.

It is considered that our participation at the oral part of the public examination would assist the Inspector for two main reasons
- Sellwood Planning has a detailed knowledge of the Rochford area, appeared at the last Local Plan Inquiry and was a participant at the RSS public examination. This direct knowledge of the local area and the statutory Development Plan may be of assistance to the Inspector
- Sellwood Planning has experience in promoting major schemes through Core Strategies (eg. 7,000 dwellings in Ashford, 5,750 dwellings in Dover, 2,500 dwellings in Horsham and 1,200 dwellings in Newmarket) and the emerging body of evidence of what constitutes a sound Core Strategy and what is unsound. Our experience indicates that, in a number of respects, the submitted Core Strategy is unsound in its present form.