Object

Hockley Area Action Plan Submission Document

Representation ID: 28362

Received: 11/12/2012

Respondent: Hockley Residents Association

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The council inappropriately pre-determined the outcome of the HAAP, stating the Core Strategy authorised this, despite 2 specific council resolutions to the contrary.

Full text:

Under the Freedom of Information Act (FoI), residents obtained a copy of the council's contract for the current stage of the HAAP and were dismayed to discover that the council had already secretly predetermined their requirements from the study.

"Contract 2944, Consultancy - Pre-submission drafts of the Hockley, Rayleigh & Rochford Area Action Plans (AAP's)" details the council's requirements for the next stage of the three area action plans.
(See http://hockleyresidents.co.uk/Other/ (HAAP Contract 2944, Consultancy)

Page 10 states (inter alia): " The pre-submission HAAP must conform to the Rochford District Core Strategy (2011), with particular regard had to Policy RTC6. In summary, consultants will be expected to produce a plan which will deliver .................:
 Redevelopment of Eldon Way / Foundry Industrial Estate for a variety of uses more appropriate for a town centre location, including residential, commercial, employment and leisure.
 A public space within a defined centre".
Thus there are clearly pre-defined, major deliverables - deliverables which are contrary to the clearly expressed views in the previous two consultations and in responses to Core Strategy consultations. The council has ignored all these consultations. This is confirmed by the absence of any analysis of the last HAAP consultation (see 3.4.1 below), despite the volume of responses, making a mockery of the consultation process.

It should also be noted that, in this case, the council has in fact 'pre-determined' the outcome, which is contrary to what it told us when we asked it to "highlight" highways issues. The council cannot have this both ways!

The council has confirmed that the decision (to prescribe a solution) was based on the concept of redeveloping the industrial area (Eldon Way/Foundry Estate), as set out in the Rochford District Core Strategy, and that the details of the redevelopment are being explored through the preparation of the Hockley Area Action Plan.

It is a core part of the council's position that the Core Strategy authorises them to define the outline requirements. Residents strongly argue that this is not correct. This was made clear in two specific amendments to the Core Strategy at the council's Full Council & ECM respectively on:
 9 September 2009 when it passed a revision, relaxing the existing proposals stating: ""Replace ..."Eldon Way/Foundry Industrial Estate will be redeveloped for housing" because "....There is concern that the initial wording could be interpreted as being overly definitive in terms of the redevelopment of employment sites"
 14 October 2010, changing policy H1, to state "In the case of Eldon Way/Foundry Industrial Estate, the nature of any redevelopment will be determined through the HAAP".


The council argues that their specific requirements were approved in its Core Strategy but this is not correct. This was made clear in two specific amendments to the Core Strategy Submission document, approved by votes at the full council's meetings on:
 9 September 2009 - when it passed a revision, relaxing the existing proposals at that time: "Replace ..."Eldon Way/Foundry Industrial Estate will be redeveloped for housing" ....There is concern that the initial wording could be interpreted as being overly definitive."
 14 October 2010 - changing policy EC3, to state "In the case of Eldon Way/Foundry Industrial Estate, the nature of any redevelopment will be determined through the HAAP".

The fact that the council has specially voted twice, a year apart, to make two specific changes to the Core Strategy, to make clear that the HAAP will determine the future for this area, totally undermines its current assertions that the exact opposite is true.
The fact that the full council has voted twice, a year apart, to make two specific changes to the Core Strategy, to make clear that the HAAP will determine the future for this area, totally undermines its current assertions that the exact opposite is true.

What the Core Strategy actually states:
(http://fs-drupal-rochford.s3.amazonaws.com/pdf/planning_cs_core_strategy_submission_document.pdf)

Page 135, 12.39 & 12.40
"Eldon Way/Foundry Industrial Estate in particular, has been identified as a potential opportunity site given its location in proximity to Hockley centre and the train station, and the potential for industrial uses to be accommodated in more appropriate locations within the District, as examined within the Economic Development section of the Core Strategy.

The Council will explore the above issues and potential in detail through the development of an Area Action Plan for Hockley centre".

and (Page 57, Appendix H1):
"Contribution towards Hockley centre regeneration to be determined through development of Area Action Plan, including:
− Public transport infrastructure improvements and service enhancements
− Healthcare facilities
− Public open space - landscaping and street furniture
− Pedestrian links between centre and train station, linking residential development to both
− Early years and childcare facility
− Youth and community facilities
− Local highway capacity and infrastructure improvements, including Spa Road/Main Road junction improvement"

The wording of the contract with the consultants for the 3rd review actually uses the same wording as the 090909 Core Strategy Submission document, ignoring the two specific amendments passed at two separate full council meetings. So it is very clear that HAAP should determine the way forward, not the CS as the council stated. This means the decision to prescribe redevelopment was based on an incorrect basis and is fatally flawed.

The Council's response: The council stated "Policy RTC6 of the Core Strategy provides the policy for redevelopment to be explored through the area action plan it does not specify the details, scale, uses or specific sites. It will be for the Hockley Area Action Plan to determine such issues, as well as the detailed policies relating to the rest of Hockley centre."

Comment: This endorses my view and is the one part of the council's response that is correct but it is not what the council has actually implemented. As the ECM specific amendments make clear, the HAAP should determine the actions not the other way round as specified in the contract with the consultants.