The HAAP proposals are 'a house of straw' with no foundations and no evidence to support the proposals. The council has also avoided answering direct Freedom of Information questions and 3 questions have been referred for Review and still outstanding.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! There is no evidence to support requirement for a supermarket and HAAP ignores the fact that 2 supermarkets have opened since R&LS published. RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary on 9 Sept and 14 Oct 2010.

1.2 imposing a two-tier consultation process with discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
restricting public consultation - only a hastily arranged exhibition using "not current thinking" 2010 material which had previously been consulted on
pre-defining the outcome;
limiting the time available
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. A FoI response showed that Traffic Assessments have been made for Rochford and Rayleigh but not for Hockley (later denied).

1.3 The council have maintained since the start of the HAAP (and also stated in the Core Strategy) that Highways would be included but went back on this commitment at the very last stage and excluded them. Indeed, RDC told ECC as recently as 2 July 2012 that "Transport assessments will be undertaken as an integral part of the development of the options for the three town centres.". Why has the council done a last minute U-turn? Residents have been mislead as to the council's intentions in this regard.

1.4 The HAAP is a proposal for strategic development which according to ECC must be accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. The main concern is the impact on traffic and parking. Highway issues are integral to the overall success of the project and must be addressed at this stage as guided by the advice obtained from ECC.

1.5 Freedom of Information requests have shown that the council have no evidence to support their views on Highways. Indeed the only document the council can produce on Highways is an email dated 4 September 2012 from Trenton Williams at Alan Baxter & Associates (the council's consultants) stationg "In Hockley, noted limited opportunities for significant capacity increases to Spa Road roundabout due to physical constraints".

1.6 manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.7 misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them .

2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which as not been provided. (211 v pro-rata 275). Supermarket developers will require adequate parking; without it proposal is not viable.
Station carpark reduced from 159 to 72 (55%). No evidence on the impact. Where will other commuters park - local estates?

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)

No Transport Assessment undertaken for Core Strategy. A Traffic Assessment is required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy. Essex County Council, advises that "On a local level every strategic development proposal is accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth."
No Transport Assessment undertaken for Hockley. FoI response showing Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - later denied!!
the existing need to deal with the bottleneck at the Spa mini-roundabout will no doubt be exaggerated in the future by extra traffic volume from the increased number of retail shoppers from the District as a whole as well as from the 1000 new houses to be built in the surrounding area which is the clearly identfiable central part of the District.
Plans for 3 slip-lanes at the Spa roundabout may not be viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Proposal to insert slip lane and widen pavement outside Spa but no evidence viable and RDC's own experts have expressed reservations
Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
Impact of moving station car park on highway under railway bridge not assessedProposal to raise access to Woodlands Road likely to cause delays on main road and endanger pedestrians.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, there is no evidence to support this; are contrary to the Retail & Leisure Study; and 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

2.4 Financial Assessment is unsound.
HAAP states financial analysis is marginal and that land assembly costs are included. The Viability Assessment states land assembly costs not included. No evidence plan is financially viable.

If the necessary entrepreneurial, risk taking developer(s) were reluctant to meet the indicated financial costs, the whole HAAP could fail to be taken forward and regeneration will be impacted. Or, possibly the options of moving the car park may need to be discarded, restricting the scope of any changes rendering the scheme non viable.

Deferring the transport assessments also effectively suggests that the whole redevelopment will need to be undertaken as a single project. Otherwise different developers addressing parts of the scheme could come up with different, contradictory or more likely, only partial highways proposals which together do not address the whole of the highway improvement needs.

Based on the financial information in the Council's viability assessment, a single project would be an extremely large undertaking which would increase the risks to the developer and if there were a failure then the whole regeneration could fail