Appendix H1

against the overbuilding of Rayleigh - another primary school but no senior school! You knocked down Park School to build more houses - no new senior school though.

I am interested to know where all these children will go to school? Surely town planners should always factor in new senior schools when building thousands of houses.

In all my time in Rayleigh (45 years) only two senior schools have been in existence namely Sweyne and Fitzimarc (although have to admit there was briefly a third one - Park School which you knocked down for more houses). There appears to be no forward planning in your ideas for Rayleigh as the more houses you build, the more primary schools you will need and the more senior schools are required - simply maths I would have thought.

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 district's highways suffer from years of under investment and over use. 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.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of addressing the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

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.

Details of infrastructure improvements are not quantified and do not appear to be adequate, particularly for the more unsustainable locations. No evidence base for infrastructure needs has been provided.

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 district's highways suffer from years of under investment and over use. 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.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of addressing the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

No evidence base has been provided to support the new infrastructure and services identified to accompany the proposed extensions to the residential envelope.

Not enough detail on proposed infrastructure inprovement or costs.

Inferstructure improvements required needs to be identified to highways imrovements by way of costs, and life safety.
Cycle paths perceived and projected for Watery Lane Hullbridge on a dangerous road, this has many very heavy lorries going to the sewerage works daily. These argments should not be used as a good reason for housing. A windy road which floods reguarly.

ROCHFORD DISTRICT COUNCIL - LOCAL DEVELOPMENT FRAMEWORK CORE STRATEGY SUBMISSION SEPTEMBER 2009

Iceni Projects Ltd (Iceni) has been instructed by Colonnade Land LLP (Colonnade) to submit representations to the Rochford Local Development Framework Core Strategy Submission (CSS).

a) Overview

It is our conclusion that the CSS is not justified, effective or consistent with national policy, as required by Planning Policy Statement 12: Creating Strong Safe and Prosperous Communities through Local Spatial Planning (PPS12) and is therefore vulnerable to being found unsound by an Inspector through the Examination in Public.

b) Background and Summary

These representations follow those made by Iceni on behalf of Colonnade to the Preferred Options Core Strategy, submitted via letter dated 17 December 2008. In this regard, we would request that the Council confirms that the representations made to the Preferred Options Core Strategy will be taken into account alongside the current representations, particularly as there are a number of cross references between the two sets of representations.

It is not considered necessary to reiterate the content of the previous representations, as they were made at the appropriate stage and will be considered by the Planning Inspectorate in due course, but it is inevitable that certain elements will require restating where it is not clear that they have been taken into account in the production of the CSS. For clarity, therefore, Colonnade feel that it is appropriate to clarify the 'in-principle' issues that were raised in the representations to the Preferred Options Core Strategy, recognising that these issues were raised in the context of a wider and more coherent justification made within the representations:

• Further cross-referencing of the recommendations made within the evidence base is required;
• Greater focus should be placed on promoting Rochford as the principal settlement within the District;
• Coombes Farm is the most logical location for residential development abutting the urban area of Rochford and as such warrants recognition as a general location for residential development;
• The allocation of Three Ashes Farm for employment generating uses will be pursued;
• Recognition that it is not realistic to expect residential allocations to be met mainly on Brownfield sites, nor should the intensification of smaller sites in residential areas be pursued;
• Many of the sites identified as suitable for residential development will not be viable and will not come forward for development within the timescales anticipated;
• The failure to provide the necessary justification for the proposed infrastructure improvements sought in Appendix H1;
• The inclusion of an affordable housing exception policy was sought; and
• The need to identify sites capable of delivering employment growth in the short term.

Following assessment of the CSS presented by the Council for consultation prior to submission to the Secretary of State, Colonnade considers the Plan to be 'unsound' as the document consistently fails to meet the tests of soundness set out in the table following Paragraph 4.52 of PPS12. For clarity, PPS12 confirms that to be 'sound' a Core Strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY and defines 'justified' as "founded on a robust and credible evidence base" and "the most appropriate strategy when considered against the reasonable alternatives" and 'effective' as "deliverable", "flexible" and "able to be monitored".

The rationale for the above is identified in the remainder of these representations, which are provided in the interests of ensuring the Council delivers a strong, robust and logical Core Strategy that guides the future development of the District in a justified and effective manner.

b) Colonnade

As the Council is aware from previous submissions to the Local Development Framework, Colonnade is a strategic land company with a particular interest in the future development of the District as a consequence of a number of sites that it controls, particularly around Rochford.

The Council will also be aware that Colonnade has recently submitted an outline planning application for the residential development of the land at Coombes Farm, Rochford to provide a sustainable urban extension comprising up to 326 residential dwellings, with associated accesses and community uses. Whilst the planning application process is clearly separate from the Local Development Framework production process, Colonnade wishes to continue the promotion of the site as a suitable location for residential development.

Accordingly, these representations focus on the legal requirements and tests of soundness associated principally with the Housing and Employment chapters of the CSS, with reference where appropriate to the sites that are controlled by Colonnade, the outline planning application at Coombes Farm and other issues where relevant.

c) Housing

i. Date of Adoption

The CSS assumes an adoption date of 2010 and plans for the provision of housing to 2025.

Taking account of the potential delays to the adoption of the Plan, including the Examination process, it would be more appropriate for the CSS to provide sufficient flexibility to allow for delays in its adoption. Colonnade considers an adoption date of 2011 for the CSS is a more realistic target.

Taking account of the advice in Paragraph 4.13 of PPS12, which states that the time horizon for the Core Strategy should be "at least 15 years from the date of adoption" it would be appropriate for the CSS to plan for the provision of housing to 2026 at the earliest. As such, Colonnade does not consider the CSS to be 'flexible' in the context of the tests of soundness in the table following Paragraph 4.52 of PPS12.

ii. Housing Delivery

However, setting the above aside, the Housing Chapter identifies the minimum housing delivery target for the period 2001 to 2021 of 4,600 dwellings as set out in the East of England Plan, with the annual average requirement of 250 dwellings per annum to extend provision from 2021 to 2025. It also confirms that the residual target for the period 2006 to 2021 is 3,790 dwellings, taking account of the delivery of 810 dwellings in the period 2001 to 2006, and a further 618 dwellings have been completed between 2006 and 2008.

This leaves a residual housing provision target of a minimum of 3,172 dwellings in the period 2008 to 2021. Taking into account the required provision beyond 2021, the residual housing provision target in the period 2008 to 2025 is a minimum of 4,172 dwellings. The disparity between these figures and those provided within the CSS are explained by the rounding down of the annual average delivery requirement in the period 2006 to 2021 to 250 dwellings per annum, compared with the actual figure of 252.67.

The table at Paragraph 4.6 of the CSS identifies the source of housing provision that will meet the identified minimum requirements and includes figures for 'Extant Planning Permissions' and 'Existing allocations/other appropriate sites identified in Strategic Housing Land Availability Assessment'. These figures, along with the actual completions within the period are combined to produce the figure for the 'Total without Green Belt release' figure.

Setting aside the concern regarding under-provision associated with the rounding down of the annual average delivery requirement in the period 2006 to 2021, the CSS fails to identify the sites that will contribute to the 'Extant Planning Permissions' provision. The identification of the sites that will contribute to the 'Extant Planning Permissions' should be provided in the context of the findings of the Inspector in the appeal by Asprey Homes [APP/G5180/A/07/2043219/NWF] who determined that the reliance on a delivery rate of 100% is unsafe [IR287].

Furthermore, at the time of writing these representations, the Strategic Housing Land Availability Assessment 2009 has not been published. It is impossible therefore for a full assessment of the proposed housing provision to be undertaken to confirm whether the CSS is 'founded on a robust and credible evidence base' [test of soundness in the table following Paragraph 4.52 of PPS12].

iii. Redevelopment of Employment Sites

Paragraph 4.14 of the CSS refers to the identification of the four employment sites that are considered by the Council to be suitable for redevelopment to residential use. However, the failure to publish the Strategic Housing Land Availability Assessment 2009 either before or alongside the publication of the CSS means that the assumptions made by the Council as to the suitability, availability, viability and deliverability of the sites cannot be assessed.

It has been necessary, therefore, to review the assumptions made in the Rochford Urban Capacity Study 2007 (UCS) regarding the sites. Within the section of the UCS entitled 'Redevelopment of Established Employment Land' [pages 22 & 23] includes a list of those sites assessed, their indicative capacities and the probability of residential development coming forward at the sites within the plan period (identified elsewhere as 2001 - 2021). The list includes the four sites identified in the CSS of Eldon Way/Foundry Estate, Hockley; Rawreth Lane Industrial Estate, Rayleigh; Stambridge Mills; and Star Lane Industrial Estate, Great Wakering.

In total, the UCS identifies an indicative residential redevelopment capacity of 486 units on the four sites (118, 220, 60 and 88 respectively). Of these, it identifies the Rawreth Lane Industrial Estate and Stambridge Mills as having a 'high' probability of coming forward for development in the Plan period (2001 - 2021), which would deliver 280 residential dwellings using the Council's own figures. The Star Lane Industrial Estate (referred to in the UCS as the Star Lane Brickworks) is identified as having a 'medium' probability of coming forward for development in the Plan period, with capacity to deliver 88 residential dwellings. It is unclear, therefore, where the figure for 'Existing allocations/other appropriate sites identified in Strategic Housing Land Availability Assessment'.

Set against this is the identification of these four sites in the CSS as being capable of delivery for residential development within the Plan period, with 671 units delivered between 2006 and 2015 and a further 506 units between 2015 and 2021.

The UCS also states in the same section that:

"There are considerable areas of land in the district that are currently allocated for, and in use as, employment land. The redevelopment of such sites for residential use would reduce demand for residential development on greenfield sites, but would at the same time create a need for alternative sites to be found for employment. Such an approach, which would be likely to require the decontamination of existing employment land to make it fit for residential use, together with development of a greenfield site and implementation of additional infrastructure to serve the new employment area, may well be unsustainable." [our emphasis]

The UCS appears to confirm therefore, that not only would the redevelopment of the four sites listed in the CSS be unlikely within the Plan period, but also potentially unsustainable. In this regard, it is notable that the promoters of Stambridge Mills sought the Screening Opinion of the Council as to whether Environmental Impact Assessment of the planning application for the redevelopment of the site for residential use was required in 2007, but to date are yet to submit a planning application for the redevelopment of the site.

In light of this, Colonnade does not consider the CSS is 'the most appropriate strategy when considered against the reasonable alternatives' [test of soundness in the table following Paragraph 4.52 of PPS12], which include the provision of residential development in East Rochford.

iv. Strategic Housing Growth to the East of Rochford

Furthermore, whilst paragraph 2.62 of the CSS identifies concern relating to the identification of locations to the east of Rochford for development on the basis that 'vehicular movements would inevitably be directed through Rochford's historic core', the CSS later identifies Stambridge Mills as a suitable site for residential redevelopment.

In light of the evident conflicts between the evidence base provided in support of the CSS and the absence of other evidence, the CSS is not considered 'sound' in the context of the tests of soundness in the table following Paragraph 4.52 of PPS12.

v. Housing Trajectory

Paragraph 4.28 of the CSS confirms that policies H1, H2 and H3 of the CSS will deliver housing supply as illustrated in the Housing Trajectory at Appendix H2. This Housing Trajectory is transposed from the 2008 Annual Monitoring Report (AMR).

Whilst on the face of it, the Housing Trajectory appears to confirm that the Council can meet its requirement to identify a five year housing supply, many of the sites identified within the AMR do not conform to the guidance issued by CLG in August 2008, on the assessment of a five year land supply. The guidance identifies sites that can be included within the five year assessment of housing supply as:

"those that are allocated for housing in the Development Plan, sites that have planning permission (outline or full planning permission that has not been implemented) and specific, unallocated brownfield sites that have the potential to make a significant contribution to housing delivery during the 5 year period".

Table 4.10: Projected Net Completions of the AMR confirms that the five year housing land supply figure includes sites from 'other land allocated for residential purposes', which are based on land allocations outside existing settlements. However, it should be clarified that these land allocations are not currently allocated for housing development in an adopted Development Plan. As such, these unallocated greenfield sites that are yet to make significant progress through the planning system should be discounted and the five year housing land supply recalculated.

The table below has been prepared to confirm the extent of the shortfall should the sites from 'other land allocated for residential purposes' be removed from the calculation of the Rochford five year housing land supply, in accordance with the guidance issued by CLG:

Recalculated Five Year Housing Land Supply (2009 - 2014):

Year
1st April 2009 to 31st March 2010
Predicted Delivery (A)
106 dwellings
Allocations on 'other land allocated for residential purposes' (B)
0
Residual delivery (A-B)
106 dwellings
Delivery Shortfall
0

Year
1st April 2010 to 31st March 2011
Predicted Delivery (A)
217 dwellings
Allocations on 'other land allocated for residential purposes' (B)
150
Residual delivery (A-B)
67 dwellings
Delivery Shortfall
150

Year
1st April 2011 to 31st March 2012
Predicted Delivery (A)
544 dwellings
Allocations on 'other land allocated for residential purposes' (B)
300
Residual delivery (A-B)
244 dwellings
Delivery Shortfall
300

Year
1st April 2012 to 31st March 2013
Predicted Delivery (A)
395 dwellings
Allocations on 'other land allocated for residential purposes' (B)
375
Residual delivery (A-B)
20 dwellings
Delivery Shortfall
375

Year
1st April 2013 to 31st March 2014
Predicted Delivery (A)
300 dwellings
Allocations on 'other land allocated for residential purposes' (B)
300
Residual delivery (A-B)
0 dwellings
Delivery Shortfall
300

TOTAL

Predicted Delivery (A)
1,562 dwellings

Allocations on 'other land allocated for residential purposes' (B)
1,125 dwellings

Residual delivery (A-B)
437 dwellings

Delivery Shortfall
1,125 dwellings

The above table confirms that the removal of the 'other land allocated for residential purposes' from the calculation of the Rochford five year housing land supply leaves the Council with a minimum net additional housing delivery of 437 dwellings, which equates to a supply of 1.7 years based on the adjusted annual delivery target of a minimum of 255 net additional dwellings per annum. As such, the Council is failing to meet its requirement to demonstrate a five year housing land supply in accordance with PPS3 and the supporting guidance provided by CLG. It is notable that the recent application by David Wilson Homes at Land between Main Road and Rectory Road and Clements Hall Way, Hawkwell identifies an even greater shortfall in the Council's five year housing land supply.

In addition to the above, the AMR does not include a commentary on how deliverability has been assessed against the requirements of paragraph 54 of PPS3.

Furthermore, the guidance from CLG confirms that the windfall sites cannot be relied upon in demonstrating a five year supply unless a Local Planning Authority can demonstrate genuine local circumstances exist to allow this exception. However, the second paragraph of the section entitled 'Housing Trajectory and Five Year Housing Supply' confirms that the estimated completions in the years 2008 to 2013 includes estimated yields through 'intensification' coming forward in future years. With reference to the definition of 'intensification' on page 13 of the AMR, it appears that the 'Housing Trajectory and Five Year Housing Supply' also includes provision for windfall sites. As such, the Council is required to demonstrate the 'genuine local circumstances exist to allow this exception'.

The pressures on delivery and need for additional sites are more acute when it is considered that an average delivery rate of 204 dwellings per annum was achieved during a strong period of housing market growth. In view of the current economic downturn, and significant problems faced within the housing market, the Council should seek to identify appropriate and deliverable sites to meet its regional housing target provision commitments. Suitable sites would include Coombes Farm, which has been positively promoted for development through the LDF process.

It may, therefore, be more appropriate for the Council not merely to allocate sufficient sites to meet the minimum targets set down by the East of England Plan, but to identify a reservoir of land capable of coming forward for development should the sites identified through the CSS and Allocations Development Plan Documents (DPD) fail to come forward for development within the anticipated timescales.

vi. Appendix H1

As set out in the representations to the Preferred Options Core Strategy, there is continuing concern that the list of improvements to infrastructure required in support of residential development as set out in Appendix H1 fails to provide the necessary justification for its inclusion. Whilst the preamble seeks to clarify why the infrastructure is sought, the inclusion of this list should be fully justified, otherwise it is of little value. Furthermore, it would be of benefit to provide further details of the existing community infrastructure provision and capacity within the evidence base.

The failure to provide the necessary justification for its inclusion means that the CSS will not be 'founded on a robust and credible evidence base' [test of soundness in the table following Paragraph 4.52 of PPS12].

d) Character of Place

As set out in the representations to the Preferred Options Core Strategy, Colonnade considers that, with respect to the requirement to produce and adhere to Development Briefs for large residential developments, as set out in Policy CP1, the Council should not seek to impose further demands on developers where existing regulations provide sufficient requirements regarding design. In this instance, Design and Access Statements provide sufficient design guidelines for developments and there is no additional information provided in the policy or supporting text that clearly sets out the justification for this requirement.

e) Green Belt

With reference to the comments regarding the redevelopment of employment sites under the 'Housing' section above and the requirement to allocate sufficient land to meet the minimum housing provision targets as required by the East of England Plan, Colonnade considers that the chapter on Green Belt, and policy GB1 in particular, fails to provide the necessary evidence base that will allow it to be monitored effectively.

It is inherent that the proposed redevelopment of previously developed employment sites for residential use in order to reduce the requirement to allocate previously undeveloped land for residential use will displace these employment uses. In turn, therefore, the separate allocation of previously undeveloped Green Belt to accommodate the compensatory employment provision is required. This is accepted in principle at paragraph 11.11 of the CSS.

Without providing clarification of the anticipated quantum of land required to accommodate the provision of housing and compensatory and new employment land, it is not possible to monitor the performance of policy GB1.

However, using the Council's figures in the table setting out the breakdown of the housing provision figures in Chapter 4 of the CSS (assuming that actual completions and extant permissions are all on previously developed land), setting aside the displacement of employment uses referred to above, approximately 42% of the required minimum housing provision target is capable of being accommodated on previously developed land (2,005 units from a total of 4,750). As such, the Council is required to provide at least 58% of the required minimum housing provision target on the Green Belt (2,745 units from a total of 4,750).

If these figures are adjusted to take account of the displacement of employment uses (assuming the provision of an equal quantity of land is required to compensate for the employment land that is redeveloped), this figure changes to 17.5% on previously developed land and 82.5% on Green Belt (828 and 3,922 units from a total of 4,750 respectively). Even allowing for the achievement of higher densities of employment on new developments, the figures above are unlikely to change significantly.

Furthermore, the table in Chapter 4 also confirms that no previously developed land will be available for development beyond 2021, or 2015 if account is taken of the displacement of the employment uses.

In light of this, not only does Chapter 6 fail to provide the necessary evidence base that will allow it to be monitored effectively, it is also necessary to consider whether it presents the most appropriate strategy for addressing the required release of Green Belt land to accommodate the defined housing and employment delivery targets to 2025 and beyond as necessary. Colonnade considers a more robust approach that is flexible and capable of being monitored, would be to clearly identify those sites capable of delivery in the short term, which for the avoidance of doubt includes those sites being promoted by Colonnade, with a reservoir of alternative sites set aside for future growth.

As set out in the representations to the Preferred Options Core Strategy, Colonnade considers that the inclusion of an affordable housing exception policy within the CSS will aid the delivery of community housing within rural areas. However, the CSS does not contain such a policy, or adequately address the issue of community housing within rural areas and the CSS is not considered to provide sufficient flexibility to allow for the delivery of essential rural housing.

f) Environmental Issues

Colonnade has concerns regarding the justification for and effectiveness of a number of the policies contained within the Environmental Issues chapter, as follows:

• Policy ENV1: The Council fails to identify how it will "maintain, restore and enhance" the sites of nature conservation importance that are identified, or how the performance of this policy will be monitored;
• Policy ENV3: In the context of the advice at paragraph 4.32 of PPS12 regarding the reformulation of national policies, Colonnade does not consider that this policy is required; and

• Policy ENV9: As set out in the representations to the Preferred Options Core Strategy, Colonnade does not consider that the necessary evidence base has been provided to justify a policy that seeks to go above and beyond the policy targets for the Code for Sustainable Homes as set out by Central Government.

g) Community Infrastructure, Leisure and Tourism

Policy CLT1 refers to the requirement for residential and employment development to contribute to the infrastructure identified in Appendix CLT1 through Standard Charges.

However, whilst the general principle of securing planning obligations through the application of standard charges is broadly accepted, the list of infrastructure requirements set out in Appendix CLT1 is not supported by sufficient evidence base to identify its robustness and credibility. As such, Colonnade does not consider either policy CLT1 or Appendix CLT1 is justified in the context of PPS12.

It is also noted that, despite the clarification sought by Colonnade at the Core Strategy Preferred Options stage, the CSS fails to confirm what information should be contained within Health Impact Assessments, which are required by policy CLT4. Once again, Colonnade requests further clarification of what is involved in the assessment and the expected outputs, which will provide greater clarity and will allow the policy to be monitored.

h) Transport

Policy T8 confirms that the Council will apply minimum parking standards. As set out in the representations to the Preferred Options Core Strategy, the guidance in Planning Policy Guidance Note 13: Transport (PPG13) is clear regarding the imposition of parking standards.

Paragraphs 52-56 of PPG13 confirm that the Local Planning Authorities should apply maximum not minimum parking standards. In order to satisfy the legal requirements set out in PPS12, the policy must reflect PPG13 to promote sustainable transport choices and further provide incentives for developers to locate further residential land closer to local service centres by requiring maximum parking standards for residential developments.

i) Economic Development

As set out in the representations to the Preferred Options Core Strategy, the land at Three Ashes Farm provides an excellent opportunity to deliver employment growth in the short term and may be a suitable site for the 'Eco-Innovation Centre' that is being promoted by the Council. Its identification as a suitable location for strategic employment growth, or the provision of an Eco-Innovation Centre, would accord with the general principles of the policies contained within Chapter 11.

The identification of Purdeys Industrial Estate as fit for purpose (in paragraph 11.32 and the Council's 2008 Employment Land Study 2008) and therefore it should be maintained and if possible expanded, is welcomed and Colonnade considers that Three Ashes Farm could deliver this expansion, providing a natural extension to Purdeys Industrial Estate and being strategically located close to the Airport.

Three Ashes would address the negative impacts that the nearby residential area experiences from the existing Industrial Estate by providing a buffer between established uses and the residential area with less intensive employment activities. The highways analysis that has been carried out has suggested that it would not have an adverse impact on roads and congestion. Furthermore, there are very few opportunities for businesses to expand and Three Ashes could provide this opportunity.

j) Conclusions

Following the submission of representations to the Preferred Options Core Strategy, Colonnade is disappointed to note that the CSS fails to take account of the majority of the issues raised in their representations.

In addition, Colonnade considers the plan to be 'unsound' as the document consistently fails to meet the tests of soundness set out in the table following Paragraph 4.52 of PPS12 and respectfully requests that the Council notifies Iceni, on behalf of Colonnade, of the future arrangements for the Examination of the Core Strategy. Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examination in Public, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request, and that the representations made to the Preferred Options Core Strategy will be taken into account alongside the current representations, by way of return to this letter.

Iceni Projects, on behalf of Colonnade Land LLP trusts that the Council will find these representations to be constructive and helpful in taking forward the Core Strategy. Should you wish to discuss any aspect of these representations further, please do not hesitate to contact us.

Highway & Traffic Implications

1. 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. 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 District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus services are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighbouring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states;

* (EC7.3C) "out-of-centre sites, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.

* EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPS1 (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

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

Summary:

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 unsound

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. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):

"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.

The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

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

Summary:

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 district's highways suffer from years of under investment and over use. 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.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of addressing the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

Summary:

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), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.

* The proposals also 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.

Summary:

Previous consultations ignored by RDC:
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 baseand are unsound

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

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

* the Foundry Industrial Estate has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy states this omission was due to a typing error!

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

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

Summary:

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates

The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW
businesses entirely
the Foundry Industrial Estate has never even been previously mentioned;
The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

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

8. Eldon Way and Foundry Industrial Estates form a significant part of the ongoing Hockley Area Action Plan (HAAP) consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy nor HAAP define its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, 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.

Summary:

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 Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:

1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.
2) (10.28) "There is no immediate capacity for additional floor space."

3) (10.29 "we recommend that focus be maintained on developing Hockley's

existing strengths, rather than retail expansion"

4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moveover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

The Core Strategy is inaccurate, misleading and unsound.

Summary:
The Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008. The Core Strategy states"The Retail & Leisure Study states Hockley has great potential and has a need for additional convenience floorspace". Whereas, the R&LS states: 1) "does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure. 2) "There is no immediate capacity for additional floor space." 3) "we recommend that focus be maintained on developing Hockley's existing strengths." 4) " the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

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".

South East Ashingdon

Agree with the new infrastructure and services to accompany residential development on this site.

Highway & 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. 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 District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus services are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighbouring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states;
• (EC7.3C) "out-of-centre sites, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.
• EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPS1 (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

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

Summary:
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.

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 unsound
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. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):
"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.
The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

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

Summary:
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.

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 district's highways suffer from years of under investment and over use. 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.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of addressing the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

Summary:
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.

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.

Previous consultations ignored by RDC:
• The Hockley Parish Plan (dated 2007), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.
• The proposals also 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.

Summary:
Previous consultations ignored by RDC:
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 baseand are unsound

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
• The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW businesses entirely
• the Foundry Industrial Estate has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy states this omission was due to a typing error!
• The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

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

Summary:
RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
• The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW
businesses entirely
• the Foundry Industrial Estate has never even been previously mentioned;
• The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

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

Eldon Way and Foundry Industrial Estates form a significant part of the ongoing Hockley Area Action Plan (HAAP) consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy nor HAAP define its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, 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.

Summary:
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.

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.

THE Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:
1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.
2) (10.28) "There is no immediate capacity for additional floor space."
3) (10.29 "we recommend that focus be maintained on developing Hockley's
existing strengths, rather than retail expansion"
4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moveover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".
The Core Strategy is inaccurate, misleading and unsound.

Summary:
The Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008. The Core Strategy states"The Retail & Leisure Study states Hockley has great potential and has a need for additional convenience floorspace". Whereas, the R&LS states: 1) "does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure. 2) "There is no immediate capacity for additional floor space." 3) "we recommend that focus be maintained on developing Hockley's existing strengths." 4) " the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

We consider the DPD is potentially unsound depending on the final selection of specific sites or site in South West Hullbridge.

Please see attached statements 1, 2, 3 and 4 evidential statement.

The precise wording should correlate to the proposal of the attached statements, although the issue may be resolved by publication of the allocations development plan document.

Oral participation will depend on whether the proposed site is included in the allocation development plan document for specific sites for future development, if the proposed site is included oral participation will not be required or necessary.

LDF - Preferred Options - Rayleigh conurbation.
On behalf of Rawreth Parish Council I confirm that this letter is a formal response of objection to the final draft of Rochford District Councils Core Strategy Preferred Options document.
Firstly, at no time has the Parish of Rawreth been included or mentioned in any "Tier" on page 33 of the document, the criteria for allocation of houses - within the Core Strategy. If it had been included it should have been in Tier 4 and this is, therefore, UNSOUND.
The Parish Council believes that to develop 550 houses in one place within area no: 144, land to the north of London Road and then to add a further 220 to the Rawreth Industrial Estate area will totally destroy the character and rural outlook of Rawreth and surrounding areas. It will destroy the residents' "strong sense of identity within their own settlement" and is, therefore, UNSOUND.
The huge development of 550 houses is totally unacceptable. The land north of London Road is good quality agricultural land which is protected by the Green Belt -GB1 - fulfils all purposes under PPG2 and should be retained as such. Once used for development this land can never be returned to agricultural use, and if you continue to erode into our Green Belt and farmland it will be lost forever.

The Parish Council believe a proportion of the houses required to be built in our area should compliment and enhance Rawreth, cause as little extra congestion to our already heavily overcrowded roads as possible and provide a pleasant environment for those people wishing to move to the area. This particular area is part of the "Gateway to Rochford" and is the "strategic buffer" between Rayleigh and Wickford. Reference is made in the Core Strategy document to "avoiding coalescence" of villages/towns, however a development of this size immediately erodes the buffer between Rayleigh, Rawreth and Wickford, starts coalescence, destroys the rural character of Rawreth and, therefore, is UNSOUND.

The Core Strategy Document details Rochford District Councils priorities and objectives and details how the role of the Core Strategy features in achieving these. In support of the Parish Councils observations and alternative proposals they comment as follows.
Page 5 "Fostering greater community cohesion"
Development of land between Rawreth Lane and north of London Road will not give any community cohesion at all, it will simply be an extension to the west of Rayleigh giving residents no real sense of belonging, they will live within the Parish of Rawreth, yet they will be considered as living in Rayleigh as has been proved with other developments along Rawreth Lane such as Laburnum Way.
Page 12 "Priority 5 Essex roads are safer less congested and everyone has access to essential services"

The roads and infrastructure in the Rawreth area are completely full to capacity. The A127, A1245, A129 London Road, Rawreth Lane and Watery Lane just cannot take any more traffic and the proposed development on land to the north of London Road will increase traffic to a completely unsustainable level. On numerous occasions this year incidents within and on the outskirts of the Parish have brought traffic to a standstill for hours along London Road, Rawreth Lane, Watery Lane/Beeches Road and the Hullbridge Road. It took some residents 1 ¼ hours to proceed along Rawreth Lane and into Hullbridge - a distance of 1 1/2 miles.

The proposed development at the western edge of Hullbridge, which is, in fact, largely in Rawreth would also greatly increase the traffic problems in the area. Rawreth Parish Council understand there would be a proposal to "widen/straighten" Watery Lane/Beeches Road, with a roundabout at the junction with the Hullbridge Road. This is an extremely dangerous junction even at the present time and would become increasingly so. There is also the question of where the traffic would go when it reaches Battlesbridge at the Western end, it cannot possibly cross the Bridge as this is "restricted" and in a Conservation Area, therefore, it would have to turn left and proceed to the A1245 - a very dangerous junction.

Beeches Road/Watery Lane is also shown in the document as a new cyclist route. Surely this is a conflict of interest, a road widening/straightening proposal coupled with a cycle route.
Page 33 "Tier Settlements"
Nowhere in the Core Strategy Document is Rawreth Parish actually mentioned, it features in the "all other settlements tier 4" and is referred to as "land north of London Road Rayleigh" or "West Rayleigh" yet, the housing allocation of 550 dwellings between 2015 and 2021 and the 220 planned for the Rawreth Industrial Estate is the largest that any area is taking. Rawreth Parish currently has 380 dwellings and an electorate of 812, yet the proposed housing figures are set to increase the overall number of dwellings in the Parish by 203%.
Pages 34 to 36 "The efficient use of land for housing" and "Extensions to residential envelopes and phasing"
The Core Strategy Document states that "the Council recognises the importance of making best use of brownfield land" and "whilst the Council acknowledge that the housing requirement stipulated in the East of England Plan is a minimum, it must also be mindful of the need to maintain Green Belt as far as possible" yet the proposed 550 houses on the land north of London Road will all be built on Green Belt land of high agricultural value. The document states that "the Council will direct development to the most sustainable locations on the edge of settlements having regard to:"
"The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance"
"The historical, agricultural and ecological value of land"
"The potential to create a defensible Green Belt Boundary and
"The avoidance of coalescence with neighbouring settlements"
Yet these key factors all seem to have been ignored when choosing the site to the north of London Road and, therefore, the proposal is UNSOUND. The Parish of Rawreth has a history of flooding, the land in Rawreth Lane will drain into the already overloaded brook system and the Services in the area would be unable to cope with this increase in housing - drains and sewers are already working to capacity. Heavy rain earlier in the year resulted in flooding in Watery Lane and the Rawreth Brook system has been very close to flooding twice already this year. During a meeting between the Parish Council and the Environment Agency we were advised that this situation will worsen with increased housing.

Page 42 "Gypsy and Traveller Accommodation"
This section details the need for an allocation of 15 pitches by 2011, it also states that they "will examine the potential of current unauthorised sites to meet this need" and that "sites will be allocated in the west of the District" The west of the District is in fact Rawreth, but yet again the Parish name has not been detailed. The Parish already has an unauthorised site which is the subject of an enforcement case and although well kept is on the brow of a hill on a main highway with restricted access which Essex County Council have already raised concerns about, this is not a site that should be considered as part of the requirement due to its location, but also, why is the allocation of all 15 pitches being detailed to one area?

Page 43 to 44 "Appendix 1"

Details of all the infrastructure to accompany residential development is listed, yet there are no detailed costs, have these been done? And are these achievable? Large numbers of housing in one area, as stated in the infrastructure requirements, will necessitate a new primary school. County figures suggest that there will be surplus places in Rayleigh schools even with new housing. Obviously these will be in the wrong parts of the town so increasing the risk that an existing school could close .It makes sense to spread the development in smaller sites around the town, avoiding closure and preventing unnecessary provision of a new school.

Page 57 "Strategies, Activities and Actions - The Green Belt"
The document states that "The Council will continue to support the principals of restricting development in the Green Belt, as set out in PPG2 and will preserve the character and openness of the Green Belt" it further states that "a small proportion of the District's Green Belt will have to have its designation reviewed to allow development" The entire development of 550 houses planned for land north of London Road is all on Green Belt land as is the land at Hullbridge, how does this equate to a "small proportion"?
The Councils own Policy GB1- Green Belt Protection states "The Council will allocate the minimum amount of Green Belt land necessary to meet the District's housing and employment needs" and that they will "direct development away from the Green Belt as far as is practicable and will prioritise the protection of the Green Belt land based on how well the land helps achieve the purposes of the Green Belt".
This area of land confirms all 5 purposes of the national PPG2 - Green Belt:-
It prevents the unrestricted sprawl of western Rayleigh
It provides a barrier to prevent the ultimate merging of Rayleigh, Rawreth and Wickford
It assists in safeguarding the countryside from encroachment
It preserves the setting and special character of historic towns
Assists in urban regeneration, by encouraging the recycling of derelict and other urban land
Rawreth Parish Council have observed that there are a number of sites that were put forward in the "Call for Sites" that are pre-used brownfield land in the Green Belt land, and as such would prove beneficial and in their opinion should have been considered for development. Their non-inclusion as "brownfield" sites makes the current proposals UNSOUND:
Site No; 73 Hambro Nursery a site of approximately 3.93 hectares, coupled with the adjacent site Clovelly, would provide between 200 and 250 houses in an area of approximately 4.85 hectares this area would have good access directly from the A1245 and if expanded north westward to include land up to and around the Village Hall, approximately another 2.08 hectares could produce between 50 and 80 further houses. This area could be accessed either from the slip road (Chelmsford Road) to the south of the Nevendon Garage or from Church Road.
Both of these sites would remove the need for extra traffic along the A129 and Rawreth Lane which are both already operating well over maximum capacity. This development would require a footbridge for pedestrians, cyclists and horses over the A1245.
Rawreth Parish Council believe these proposals would be sensible infill of these areas and would be on "Brownfield" sites where current businesses are not particularly progressive and would not result in the loss of many jobs. Our figures are quite conservative and we believe that if these sites were chosen a much reduced number of houses would need to be built "North of London Road" on Green Belt land.
Phase 2 - With regard to the houses that are proposed for the Northeast corner of Rawreth/Hullbridge, the Parish Council are concerned that any development would cause considerable extra congestion to the immediate roads. We understand that the thoughts are to "straighten" and improve parts of Watery Lane and Beeches Road to provide access to and through Battlesbridge - a conservation area. Recent experience of deep flooding in Watery Lane with the road closed for several days on 3 occasions in the early part of 2009 proves that this proposal is completely unsustainable. The local drainage systems simply cannot take the amount of run-off experienced now and with further development this would increase the problem.
If this development is to go ahead, the Parish Council believe that a relief road should be built, from the end of Watery Lane, skirting to the west of the Rayleigh Park Estate, crossing Rawreth Lane at a mini-roundabout and entering a vastly improved A129 at approximately Lower Barn Farm. This would take any necessary traffic in and out of the area efficiently.
The Parish Council further believe that the Michelins Farm site No: 49 would be an ideal site for the Rawreth Industrial Estate. This would adjoin proposed industrial sites within the Basildon District and would provide excellent road and transport links. Rawreth Parish Council also proposed that the land opposite Michelins Farm could be used to re-site the illegal Gypsy/Traveller site that is currently situated on the busy A1245. The land opposite Michelins Farm would not only be a much safer site for Gypsy/Traveller pitches, but the correct use of the land would also ensure the environmental improvement of the site as a whole.
All of the above proposals were submitted to Rochford District Council, but they were not taken into consideration in the final draft resulting in the predominant use of Green Belt land for development, bounded by already congested roads and, therefore, the proposals are UNSOUND.

The separate representations made by the Aston Unit Trust and Mr J Needs on Policies H1, H2 and H3 set out the case why the Core Strategy fails to provide a sound settlement strategy and distributes greenfield housing in a manner which will not deliver a more sustainable pattern of development and will not deliver the Core Strategy objectives. The remedy is to allocate less greenfield development to the villages such as Hullbridge, and more to Rayleigh which is the largest settlement in the District with the greatest range of facilities and services. The representations suggest combining Policies H2 and H3 and allocating further sites at Rayleigh including 200 dwellings to the east of the town. In order to be consistent, it is necessary to
add 'East of Rayleigh' to Appendix H1 setting out new infrastructure and services which would be required to accompany the site.

Add to Appendix H1

"East of Rayleigh and South of the B1013

- enhancements to the B1013 (Policy T2)
- local highway capacity and infrastructure improvements
- public transport infrastructure improvements and service enhancements
- improved pedestrian / cycle links to Rayleigh Town Centre
- improved pedestrian / cycle links to the Upper Roach Valley
- sustainable drainage systems
- public open space
- play space."

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.

Please find enclosed my objection to the Core Strategy Submission DPD. Please kindly acknowledge receipt of this objection and duly register it.

Objections to RDC's Core Strategy Submission DPD

Reason Unsound
1. Highway & 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. 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 District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus service are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighbouring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states:

(EC7.3C) "out-of-centre site, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.

EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPSI (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

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.

3. RCD 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. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):

"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.

The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

It is clear that (i) the combined impact of scattering houses across the District and (ii) relocating Eldon Way/Foundry Industrial Estates to the very edge of the District with no public transport services will exacerbate existing problems. It is also 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 not, especially, costs have been identified and the Core Strategy is therefore unsound.

The district's highways suffer from years of under investment and over use. 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. Thus it is unclear if use of Standard Charges is financially viable.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of address the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

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), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.

The proposals also 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?

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

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

The Foundry Industrial Estates has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy acknowledges this omission was due to a typing error!

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

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

8. Eldon Way and Foundry Industrial Estates form a significant part of the ongoing HAAP consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy or Hockley Area Action Plan (HAAP) defines its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, 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 show 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 doe 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 Core Strategy misrepresent the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:

1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.

2) (10.28) "There is no immediate capacity for additional floor space."

3) (10.29 "we recommend that focus be maintained on developing Hockley's existing strengths, rather than retail expansion".

4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moreover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

The Core Strategy is inaccurate, misleading and unsound.

1. Highway & 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. 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 District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus service are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighbouring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states:

(EC7.3C) "out-of-centre site, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.

EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPSI (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

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 unsound.

3. RCD 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. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):

"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.

The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

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

Summary:

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 not, especially, costs have been identified and the Core Strategy is therefore unsound.

The district's highways suffer from years of under investment and over use. 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. Thus it is unclear if use of Standard Charges is financially viable.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of address the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

Summary:

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), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.

The proposals also 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.

Summary:

Previous consultations ignored by RDC:

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 have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates.

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

The Foundry Industrial Estates has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy acknowledges this omission was due to a typing error!

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

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

Summary:

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates.

The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing FW businesses entirely.

The Foundry Industrial Estate has never even been previously mentioned.

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

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

8. Eldon Way and Foundry Industrial Estates form a significant part of the ongoing HAAP consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy or Hockley Area Action Plan (HAAP) defines its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, 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.

Summary

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% rejectionrate of respondents to the previous round of HAAP such an approach is entirely undemocratic and unsound.

9. PPS12, 4.6, states that Cores Strategies show 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 doe 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 Core Strategy misrepresent the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:

1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.

2) (10.28) "There is no immediate capacity for additional floor space."

3) (10.29 "we recommend that focus be maintained on developing Hockley's existing strengths, rather than retail expansion".

4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moreover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

The Core Strategy is inaccurate, misleading and unsound.

Summary:

The Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008. The Core Strategy states "The Retail & Leisure Study states Hockley has great potential and has a need for additional convenience floorspace". Whereas, the R&LS states: 1) "does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure. 2) "There is no immediate capacity for additional space." 3) "we recommend that focus be maintained on developing Hockley's existing strengths." 4) "the Council may wish to consider reclassifying Hockley from a town centre to a district centre.

1. Highway & 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. 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 District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus service are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighbouring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states:

(EC7.3C) "out-of-centre site, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.

EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPSI (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

Summary:

Proposals for moving employment to of town locations, at either end of the district, with no existing public transport inks, 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 unsound.

3. RCD 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. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):

"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.

The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

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

Summary:

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 not, especially, costs have been identified and the Core Strategy is therefore unsound.

The district's highways suffer from years of under investment and over use. 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. Thus it is unclear if use of Standard Charges is financially viable.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of address the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

Summary:

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), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.

The proposals also 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.

Summary:

Previous consultations ignored by RDC:

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 have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates.

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

The Foundry Industrial Estates has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy acknowledges this omission was due to a typing error!

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

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

Summary:

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates.

The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing FW businesses entirely.

The Foundry Industrial Estate has never even been previously mentioned.

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

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

8. Eldon Way and Foundry Industrial Estates form a significant part of the ongoing HAAP consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy or Hockley Area Action Plan (HAAP) defines its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, 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.

Summary

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% rejectionrate of respondents to the previous round of HAAP such an approach is entirely undemocratic and unsound.

9. PPS12, 4.6, states that Cores Strategies show 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 doe 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 Core Strategy misrepresent the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:

1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.

2) (10.28) "There is no immediate capacity for additional floor space."

3) (10.29 "we recommend that focus be maintained on developing Hockley's existing strengths, rather than retail expansion".

4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moreover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

The Core Strategy is inaccurate, misleading and unsound.

Summary:

The Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008. The Core Strategy states "The Retail & Leisure Study states Hockley has great potential and has a need for additional convenience floorspace". Whereas, the R&LS states: 1) "does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure. 2) "There is no immediate capacity for additional space." 3) "we recommend that focus be maintained on developing Hockley's existing strengths." 4) "the Council may wish to consider reclassifying Hockley from a town centre to a district centre.

Highway & 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. 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 District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus services are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighboring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states;
• (EC7.3C) "out-of-centre sites, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.
• EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPS1 (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

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

Summary:
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.
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 unsound
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. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):
"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.
The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

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

Summary:
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 modeling 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.

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 district's highways suffer from years of under investment and over use. 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.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of addressing the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

Summary:
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.
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.
Previous consultations ignored by RDC:
• The Hockley Parish Plan (dated 2007), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.
• The proposals also 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.

Summary:
Previous consultations ignored by RDC:
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

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
• The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW businesses entirely
• the Foundry Industrial Estate has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy states this omission was due to a typing error!
• The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

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

Summary:
RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
• The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW
businesses entirely
• the Foundry Industrial Estate has never even been previously mentioned;
• The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

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

Eldon Way and Foundry Industrial Estates form a significant part of the ongoing Hockley Area Action Plan (HAAP) consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy nor HAAP define its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, 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.

Summary:
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.
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.

THE Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:
1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.
2) (10.28) "There is no immediate capacity for additional floor space."
3) (10.29 "we recommend that focus be maintained on developing Hockley's
existing strengths, rather than retail expansion"
4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moveover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".
The Core Strategy is inaccurate, misleading and unsound.

Summary:
The Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008. The Core Strategy states "The Retail & Leisure Study states Hockley has great potential and has a need for additional convenience floorspace". Whereas, the R&LS states: 1) "does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure. 2) "There is no immediate capacity for additional floor space." 3) "we recommend that focus be maintained on developing Hockley's existing strengths." 4) " the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

Highway & 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. 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 District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus services are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighboring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states;
• (EC7.3C) "out-of-centre sites, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.
• EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPS1 (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

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

Summary:
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.
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 unsound
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. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):
"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.
The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

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

Summary:
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 modeling 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.

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 district's highways suffer from years of under investment and over use. 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.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of addressing the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

Summary:
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.
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.
Previous consultations ignored by RDC:
• The Hockley Parish Plan (dated 2007), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.
• The proposals also 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.

Summary:
Previous consultations ignored by RDC:
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

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
• The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW businesses entirely
• the Foundry Industrial Estate has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy states this omission was due to a typing error!
• The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

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

Summary:
RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
• The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW
businesses entirely
• the Foundry Industrial Estate has never even been previously mentioned;
• The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

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

Eldon Way and Foundry Industrial Estates form a significant part of the ongoing Hockley Area Action Plan (HAAP) consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy nor HAAP define its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, 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.

Summary:
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.
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.

THE Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:
1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.
2) (10.28) "There is no immediate capacity for additional floor space."
3) (10.29 "we recommend that focus be maintained on developing Hockley's
existing strengths, rather than retail expansion"
4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moveover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".
The Core Strategy is inaccurate, misleading and unsound.

Summary:
The Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008. The Core Strategy states "The Retail & Leisure Study states Hockley has great potential and has a need for additional convenience floorspace". Whereas, the R&LS states: 1) "does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure. 2) "There is no immediate capacity for additional floor space." 3) "we recommend that focus be maintained on developing Hockley's existing strengths." 4) " the Council may wish to consider reclassifying Hockley from a town centre to a district centre".

Appendix H1 - New infrastructure and services to accompany residential development
Summary: The Respondent finds the document to be unsound in its present form, however were the amendments set out in these representations to be incorporated then it is considered that the document will be sound. Whilst it is accepted that it is helpful to identify the new infrastructure and services required to accompany residential development, there is concern that some of the requirements may be excessive given the extent of development proposed.
Full text: With regard to land at East Ashingdon, this site is identified as having a number of new infrastructure and service requirements. Our clients control this land and it is envisaged that the majority of the items identified would form an integral part of any proposals for this area. However we have the following concerns:
1. It is not clear from the evidence base that there is a solid need to expand the school by the 3 hectares referred to in Policy CLT3. Discussions with Essex County Council Education have not been conclusive. The Respondent's master plan illustrates a 3 hectare area of land that could be provided, however the size of this land could vary and should not be fixed until further evidence is provided.
2. Public open space, play space and youth facilities and community facilities are listed as requirements. Whilst it is envisaged that public open space and play space would be provided as part of the development, it is considered that the on site provision of youth facilities and community facilities would be excessive given the scale of the proposals and the other contributions required. Further, Appendix H1 identifies that youth facilities and community facilities are also proposed at South-East Ashingdon, just a short distance from East Ashingdon and therefore it would seem excessive to have youth and community provision on both sites. It should be noted that the site lies in close proximity to a secondary school, which already has sport and recreation facilities i.e. all weather pitch.

Whilst the principle of contributing to the infrastructure and services listed is supported, it is suggested that this should either be in the form of on site contributions or financial contributions towards off site facilities and services in accordance with Policy CLT1.
Proposed Amendment to Appendix H1: For this Appendix to be sound, the heading of the second column should be amended to read "Contributions required for new infrastructure and services to accompany residential development".

Masterplan/Facilities plan Council ref AE22

ROCHFORD CORE STRATEGY SUBMISSION DOCUMENT, SEPTEMBER 2009
RESPONSE OF ESSEX COUNTY COUNCIL


1. General Comment

Essex County Council welcomes and broadly supports the Core Strategy prepared by Rochford District Council. The Strategy contains policies and proposals that address the spatial characteristics, issues and opportunities facing the District whilst respecting the distinctive qualities of the different settlements and parts of the District.

The County Council fully supports the maintenance of a strong policy approach to protection of the Green Belt and of the quality of environmental assets in the District whilst making adequate housing and employment provision within the District. The Core Strategy presents an approach that emphasises a balance of opportunity through the District and recognition of emerging economic prospects in the District and neighbouring areas. The intended preparation of more detailed Action Area Plans for London Southend Airport and its environs and for each of the three town centres of Rayleigh, Rochford and Hockley will further enhance the approach of the Core Strategy. The emphasis on the three town centres is particularly welcomed as offering a stimulus to improvement in the services and facilities available locally within the District whilst also affording possibilities of increased community focus.

2. Housing Distribution and Locations

The East of England Plan requires Rochford to provide a minimum of 3,790 additional dwellings between 2006 and 2021. In addition, provision for a further 1,000 dwellings should be made between 2021 and 2025 to ensure delivery of housing for at least 15 years from adoption of the Core Strategy (expected in 2010). Of this total requirement the District Council has identified a capacity of 2,000 dwellings through a Strategic Housing Land Availability Assessment. This means that the Core Strategy has to identify locations for about 1,750 dwellings to be delivered before 2021 and a further 1,000 dwellings between 2021 and 2025.

Policy H1 (The efficient use of land for housing) is supported. However, prioritisation of the reuse of previously developed land within settlements for additional housing is unlikely to provide a sufficient source of provision due to the generally residential nature of existing settlements in the district and the absence of potentially large sites of previously developed land. The assessment of potential for additional housing provision within settlements already includes the proposed re-allocation to substantially residential use of 4 existing employment areas.

Within Policy H2 (Extensions to residential envelopes and phasing) and Policy H3 (Extension to residential envelopes post-2021) the District Council has adopted a balanced approach to the distribution of additional housing locations, which is based on identification of tiers of settlements defined by reference to their accessibility to jobs, services and facilities (some of which lie outside the District) and the need to protect the valued environments within the District. This approach is generally supported, although implementation and delivery of individual schemes should give further thought to securing sustainable functional relationships between proposed development locations and availability of jobs, services and facilities.

The proposed scale and phasing of development at each of the identified locations in Policy H2 and Policy H3 should be capable of being supported by County Council service groups, provided that adequate and timely funding is available. The County Council would wish to work with the District Council to ensure that future infrastructure and facilities would serve and give benefit to the existing adjoining community as well as to the new development. In this respect it is noted that the Core Strategy proposes preparation by the District Council of a Planning Obligations and Standard Charges document (Policy CLT1). The District Council's document should fully reflect the County Council's own approach to this matter as set out in the County Council's 'Developer's Guide to Infrastructure Contributions'.

3. Economic Development

The approach to Employment Growth (Policy ED1) is supported. Given the economic structure of Rochford District the support to be given to protection and enhancement of the role of small and medium sized businesses; enhancement of the District's commercial centres; and development of a skills training academy is particularly welcome. These measures will assist in building on the existing economic resource of the District.

Proposals for the comprehensive development of London Southend Airport and its environs (Policy ED2) are supported. The further elaboration of proposals through an Area Action Plan will provide a firm foundation to realise the economic regeneration and growth opportunities presented by effective use of the Airport. The recognition of the potential environmental impact of the Airport and the commitment to work to mitigate any adverse impacts on the environment and local amenities is fully supported.

The location of the proposed Eco-Enterprise Centre to the North of London Southend Airport (Policy ED4) is supported. Creation of the Centre would assist reduction of the rate of business start-up failure in the district. Further the proposed location for the Centre would afford a clear offer to businesses within an area of varied business activity.

The continued protection and enhancement of existing employment land (Policy ED3) is supported, as is the identification of 4 existing employment sites for appropriate alternative, substantially residential, uses. Each of the 4 sites affords particular issues and opportunities whereby their redevelopment for other uses and relocation of existing occupiers would confer advantage for the immediately neighbouring areas and for the District as a whole.

4. Town Centres

The town centres of Rayleigh, Rochford and Hockley, and future plans for them, are closely linked to the economic development of the District but also present the opportunity to offer greater community focus within the District. The varied approach being taken to each of these town centres is supported (Policy RTC4, RTC5 and RTC6), notably the recognition of the role and purpose of the town centres beyond retail uses.

The contribution that the County Library service could make to plans for the town centres should not be overlooked. The 5 libraries in the District are substantial footfall draws in their localities and act as a 'community anchor store'. This has knock-on effects in encouraging use of neighbouring retail and service facilities. Further the Library service is currently looking at co-location opportunities for other services within the libraries which would enable them to act as a community focus.

5. Transport

The transport aspects of the Core Strategy are well balanced in identifying potential measures that would meet the needs of existing residents and businesses in the District as well as needs arising from future development. The approach reflects and makes good reference to the transportation aspirations of the County Council. The policy emphasis on close working between the District Council and the County Council to advance the transport aspirations is welcomed and fully supported.

In relation to parking standards (Policy T8 and Paragraph 10.30) the review undertaken by Essex County Council in conjunction with the Essex Planning Officers Association has now been completed. Revised parking standards have been agreed and signed off as County Supplementary Guidance, in accordance with PPS12, and is being applied by the County Council as Local Highways Authority.

6. Coastal Protection Belt

Policy ENV2 (Coastal Protection Belt) is not supported because in its current form it is not a suitable or effective replacement policy for Policy CC1 of the Replacement Structure Plan. Structure Plan Policy CC1 (The Undeveloped Coast - Coastal Protection Belt) currently remains a 'saved' policy of the Essex and Southend-on-Sea Replacement Structure Plan, April 2001 (following a direction of the Secretary of State, dated 27th September 2007, under paragraph 1(3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004). The existing Policy CC1 reads,
'Within the Coastal Protection Belt defined in adopted local plans there shall be the most stringent restrictions on development within the rural and undeveloped coastline situated outside existing built-up areas, and any development which is exceptionally permitted within this Belt shall not adversely affect the open and rural character, historic features or wildlife.'

Core Strategy Policy ENV2 should be revised to include specific reference to,
* Definition of the boundary of the Coastal Protection Belt in another Development Plan Document;
* the application of the most stringent restrictions on development within the rural and undeveloped coastline;
* any development exceptionally permitted not adversely affecting the open and rural character, historic features or wildlife.

7. Historic Environment

The importance of the historic environment in Rochford District is clearly identified within the Core Strategy document. Nevertheless, the policy guidance could be usefully enhanced to promote consideration and enhancement of the historic environment and use of the historic environment to shape place. This would be achieved by the following amendments to the Core Strategy,

* Policy ENV1 (Protection and Enhancement of the Natural Landscape and Habitats and the Protection of Historical and Archaeological Sites) should be amended by deletion of the final sentence and its replacement with,
The Council is committed to the protection, promotion and enhancement of the diverse historic landscape and extensive surviving archaeological deposits of the District.

* Paragraph 8.15 of the supporting text should be amended to better support the suggested amendment to Policy ENV1. The existing text of Paragraph 8.15 should be deleted in its entirety and replaced by,
The historic environment of Rochford District has developed through a history of human activity that spans over 450,000 years. Much of the resource lies hidden beneath the ground in the form of archaeological deposits. Other elements such as the historic landscape, the pattern of field, farms, woods and grazing marsh which characterise the District, are a highly visible record of millennia of agriculture, industry and commerce. Of particular significance are the coastal, island and estuarine areas where multi-period landscapes reflecting the exploitation of coastal and marshland resource survive. The District also includes the important historic medieval market towns of Rochford and Rayleigh.

* Page 16 (Sustainable Community Strategy Priority: Promoting a Greener District) should be amended to further support the approach to the Historic Environment. The fourth bullet of the Key Section/Policies of the Core Strategy should be amended to include the word 'historic', so that the first sentence of the bullet would read,
The Environment chapter seeks to protect and enhance the biodiversity, historic and natural environment of the District by protecting sites of local, national and international importance.

8. Community Infrastructure

The approach to Community Infrastructure is supported. The County Council would wish to work with the District Council to ensure that future community infrastructure and facilities would serve and give benefit to the existing adjoining community as well as to the new development. In this respect it is noted that the Core Strategy proposes preparation by the District Council of a Planning Obligations and Standard Charges document (Policy CLT1). The District Council's document should fully reflect the County Council's own approach to this matter as set out in the County Council's 'Developer's Guide to Infrastructure Contributions'.

In addition, it should be noted that,
* Some County Council services are not highly visible despite being regarded as highly desirable community services by local residents. The need to ensure adequate funding and contributions to enable these services to meet community expectations should be recognised and acknowledged in consideration of planning obligations and standard charges.
* The Adult Community Learning Centre at Rocheway, Rochford could be better located with regard to the wider Rochford/Castle Point area of service. Relocation of the Centre could provide opportunities both at the new location and for the current site.
* The Core Strategy should make specific reference to,
o Appendix H1, Location at South Canewdon: new Early Years and Childcare facilities;
o Policy CLT2, final sentence: insert after the words 'primary schools' the words 'and Early Years and Childcare facilities;
o Appendix CLT1, Other issues/comment: for Early years and childcare facilities add 'Land to be allocated within new residential areas, as appropriate'.

9. Implementation, Delivery and Monitoring

The inclusion in the Core Strategy of a section considering Implementation, Delivery and Monitoring is welcomed and supported. Nevertheless, the District Council, in moving towards implementation and delivery of the individual elements of the Core Strategy, should highlight those schemes and projects that are critical to achievement of other aspects of the Strategy.

Further, the monitoring proposal for Policy H6 (Lifetime Homes) and for Policy CP1 (Design) should be amended,
* Policy H6 (Lifetime Homes) - the identified monitoring tool is Core Indicator H6 Housing Quality Building for Life Assessments. The Building for Life Assessment methodology was devised to measure the overall design/layout quality of housing developments. It was not devised to measure compliance with Lifetime Homes, which is largely, but not exclusively, concerned with internal space standards and the provision of internal arrangements within dwellings to meet needs of all residents.
* Policy CP1 (Design) - the monitoring indicator proposed by the Core Strategy is not supported because it is unclear what the indicator would actually be measuring. The proposed indicator should be replaced by the Core Indicator, Housing Quality - Building for Life Assessments, as suggested by the County Council in its response to the Core Strategy Preferred Options, October 2008. A better approach would be to base evaluation and monitoring of Policy CP1 on the Commission for Architecture and the Built Environment's (CABE) 20 Building for Life principles, particularly as Government has endorsed these principles and is urging local authorities to use them to assess design quality. It is suggested that the monitoring arrangements for Preferred Option CP1 be deleted and replaced by the following text,
'The success of the implementation of this policy will be monitored by assessing schemes, or an appropriate sample of schemes, against the Commission for Architecture and the Built Environment's (CABE) Building for Life principles.'

10. Access to Housing

The Core Strategy notes the higher prevalence of older people in Rochford District and the need to support them. However, a more broadly based approach to access to housing should be adopted by Policies H4, H5 and H6. It should recognise the presence of other vulnerable adults in the community, for example, those with learning or mental health disability, and the range of possible forms of accommodation, including supported, sheltered and extra care accommodation. The high level of owner occupation in the District further emphasises the need for a broader approach. The emphasis on Lifetime Homes would not address the variety of future needs, whilst the potential exemptions to the Lifetime Homes policy standard in Policy H6 are likely to act against demographic trends.

See statement

Council ref AE18 and AE18a

Policy Appendix H1 of the Core Strategy is not "sound". The appendix H1 is unjustified and this not sound.

Para 4.9 of PPS12 requires infrastructure needs and costs to be identified. This has not been completed or published. There is no evidence to support the infrastructure requirements, or who will provide it, or when.

The list of infrastructure projects is not justified in accordance with the PPS. The list of infrastructure required, whilst potentially accepted appears to be based on a development brief that we are not aware of and has not been published. The site allocation should be general at this stage in order to allow proper consultation of the alternatives. This has not previously be consulted on in the previous options documents.

Proposed Change

We request that the wording be changed from "North of London Road, Rayleigh" to refer to "West of Rayleigh", to allow further consideration of alternative sites.

We reserve the right to expand on these grounds in more detailed evidence to follow should the Inspector request.

Site location plan received, see Council ref AE30

Local Development Framework

Representations on the Core Strategy
Submission Document, November 2009
On behalf of Barratts Eastern Counties

Introduction

The requirements of Core Strategies are enshrined in the 2004 Planning and
Compensation Act, the Town & Country Planning (Local Development) England (Regulations) 2004 and the 2008 policy guidance in PPS12. The requirements of Coe Strategies are clear. And they are legal requirements. The Core Strategy must comply with the Local Development Scheme, Statement of Community Involvement and the Regulations. The Core Strategy must be subject to a sustainability appraisal, have regard to national guidance, conform generally with the Regional Spatial Strategy and have regard to any Sustainable Community Strategy. A Core strategy must be sound - justified, effective and consistent with national policy. The following
representations therefore focus on these legal requirements.

HOUSING
Paragraph 4.6 - Evidence Base

To meet the soundness test Submission Core Strategies (SCS) must be justified, that is to say it must be founded on robust and credible evidence base and comprise the most appropriate strategy when considered against reasonable alternatives. The housing strategy in as far as it identifies a need for Green belt sites is sound, however, there are other elements which are unsound.

Paragraph 4.6 notes that the Strategic Housing Land Availability Assessment (SHLAA) has examined the supply of housing. It is presumed that the Table at paragraph 4.6 is the outcome of this examination. Whilst the SHLAA has some leigitimacy in that it identifies various sites that are apparently available, we are concerned that because the SHLAA was only published in November 2009 it post dates the SCS. This implies that the SCS is driving the SHLAA exercise rather than the other way round. Whilst this may have no real practical effect on the outcome of the SCS and the identified need for Green Belt sites, the Inspector will be mindful of the advice in paragraphs 33 and 54 of PPS3 that SCS draw on the evidence in SHLAA. It may be that the SCS should explain how the evidence base has been used to justify the strategy.

PPS12 explains at paragraph 4.37 that Core Strategies are based on thorough evidence. Since the SHLAA has only recently been published it is considered that the SCS is unsound as it is not justifiable. This, together with other comments on the SCS, indicates that the process should be delayed to ensure that a more robust document is placed in front of the EiP Inspector.

Table at Paragraph 4.6 - Evidence base

From our review of the available evidence it would appear that the housing land supply is insufficient and that Green Belt release are required. From the wider strategy being promoted we note that some of the sites that the District Council consider to be 'appropriate' are likely to relate to existing employment areas. As set out elsewhere in our representations, we maintain sever reservations that the redevelopment of existing employment sites for alternative uses and particularly the Eldon Way Industrial Estate is unsustainable. We will make reference to the effectiveness of this strategy in relation to sustainability, whether it is justified in the context of National Policy and the deliverability of such a strategy elsewhere.

In particular, paragraph 11.32 of the SCS refers to existing employment land and sites within the UCS. It does not refer the SHLAA and as such it appears that an evidence base to support the re-use of employment land for residential is not reported in the SCS.

Having reviewed the 2008 Annual Monitoring Report, as we did when commenting on the 2008 Preferred Options Core Strategy, we maintain severe doubts as to the appropriateness of some of the previously developed sites identified as potential housing sites and their expected housing yield. Whilst we cannot at this stage ascertain whether the SHLAA sites referred to in this table correlate with the Annual Monitoring Report and indeed the 2007 Urban Capacity Study, it is our view that there will be some commonality and so the reliance on these sites is likely to be at odds with Government Policy. We shall elaborate on this objection in relation to the specific housing policy below.

We note that the last two rows in the Table at paragraph 4.6 set out figures with and without Green Belt releases. The text to this section of the Core Strategy should, for reasons of clarity, explain that Green belt review will be necessary in order to deliver the required housing.

Paragraph 4.9

The table on page 40, which sets out the settlement tiers, is supported. Rayleigh, Rochford/Ashingdon, Hockley/Hawkwell are clearly the largest settlements in the District and they benefit from good employment, housing, leisure, community and public transport provision. These settlements are the most sustainable ones with the greatest mix of uses. Consequently, it is sensible that the Core Strategy identifies these as top tier settlements and is able to target them with growth accordingly. This component of the strategy is justified by reference to sustainability data and is effective, since targeting development at these locations will ensure a more sustainable pattern of development.


Paragraph 4.14

We maintain that the strategy for redeveloping the Eldon Way Industrial Estate for housing and other alternative uses to employment is unsound. It is neither justified nor effective. The Industrial Land Availability Study 2006 sets out on page 7 strategic objectives. The 3rd objective seeks to Support town centre and industrial estate enhancement initiatives aimed at improving the environment ensuring the area is economically prosperous and competitive. Clearly the strategy as currently drafted envisages major changes to existing industrial estates, including alternative uses. This strategy is not consistent with other strategies and evidence based studies and so cannot be justified in the context of the tests set out in PPS12. It is also an ineffective strategy since the new employment locations that would free up the Eldon Way site for redevelopment relies on transport infrastructure that has no certainty of being delivered. Principally, the erosion of employment uses at Eldon Way could
make the settlement of Hockley/Hawkwell less sustainable and thus conflict with the tiered approach on page 40, paragraph 4.9.

Policy H1

Prioritising the use of previously developed land ("pdl") is supported in principle. It is a justified strategy in the context of PPS3 and effective as sequential choices can be made by implementing the policy. However, the District Council is also promoting a strategy which seeks the redevelopment of existing employment locations to alternative uses and by consequence is identifying green field sites for new employment development elsewhere (Policy ED4 refers). This 'land swapping' is not considered consistent with PPS3, nor is it considered to be justified or effective in delivering the desired strategy. This is particularly the case as most of the existing employment sites are occupied and therefore unavailable for redevelopment. In addition, the new Greenfield sites are in an arguably less sustainable locations away from the top tier settlements identified on page 40 of the Submission Core Strategy. Clearly this element of the strategy is inconsistent with the wider strategy.

The Industrial Land Availability Study 2006 is included as an evidence base by the District Council. It includes an introductory section, which explains that the authority wishes to make Rochford the place of choice for new business. It includes several strategic objectives on page 7 including "Support town centre and industrial estate enhancement initiatives aimed at improving the environment ensuring the area is economically prosperous and competitive." It reviews existing employment areas and identifies vacant land, including land available from allocations. It does not include any assessment of new sites or potential opportunities for new sites that might have been expected to feed into the Core Strategy. The strategy for identifying Green Belt site employment allocation does not appear to be based on any evidence in this document and in that context cannot be justified. The strategy being promoted potentially conflicts with Government policy in PPG13, PPG2 and emerging PPS4.

The Employment Land Study 2008 is a much later document. It has a key recommendation on page ii "we recommend that Rochford District Council adopts strong policies to protect existing employment land." Furthermore under recommendations for existing sites on page iii-iv of that document it states "In our view, Hockley Trading Centre is a strategically well placed employment location. However, we recognise the ambitions of the Hockley Town Centre masterplan and that within this the Council should consider it to be allocated for other uses. However, we recommend that this reallocation happen only if provision is made within the masterplan for office use within Hockley Town Centre as part of a mixed use scheme." The view of the writers of this document is clear - the Eldon Way Industrial estate (Hockley Trading Centre) is a good employment site and that it is for other reasons that alternative uses are being considered and only then if office development is supported. This supports our representations that new future uses at
the Eldon Way site should be employment dominated and that alternative uses should relate to the objectives of the Town Centre which is to enhance the shopping and leisure facilities. Residential is not an appropriate alternative.

This document recommends the use of land to the west of Rayleigh for employment and envisages Green belt release. However, the SCS does not explain through the evidence base why existing employment sites should be 'deallocated' and Green belt land unnecessarily used.

In addition to these key issues we have some specific concerns. As a consequence we maintain an objection to the second paragraph of Policy H1. This policy states that the Council will seek the redevelopment of various industrial estates including Eldon Way. The Policy says that alternative uses will be sought (presumably alternative to the existing employment offer) and that new land will be allocated elsewhere. This policy statement, in relation to Eldon Way in particular, is unsound for a number of reasons:

The emerging Hockley Area Action Plan consulted upon in 2008 states that the Eldon Way Industrial Estate is strategically well placed. In a sense this statement underplays the true importance of this highly sustainable employment location and only major employment area in Hockley/Hawkwell. The employment area is adjacent to the railway station and located a short distance from the main bus routes that run along Spa Road. Some of the residential areas of the town are also within walking distance of this commercial area, thus providing a potential for sustainable travel by employees. The Eldon Way Industrial Estate is therefore right at the heart of the settlement of Hockley/Hawkwell and provides an opportunity to meet sustainable transport objectives by reducing the need to travel by car. Consequently, this employment area should be highlighted as a premier employment site in sustainability terms, both in the context of PPG13, PPG4 and PPS6. To encourage alternative uses as set out in Policy H1 implies the removal of the majority of employment based activity at Hockley/Hawkwell and this would be contrary to National policy, would not be the most appropriate strategy when considered against alternatives and is therefore unsound.

Whilst it is acknowledged that improvement to the Eldon Way Industrial Estate can and should take place, the extent to which the mix of employment uses should be altered in favour of alternative land uses requires careful consideration. It is our view that a mix of existing or indeed new employment land uses with some Town Centre type uses should dominate the Eldon Way site. A mix of employment types between offices, light industry and other high technology industries should be encouraged as this will provide many locational advantages to the firms that agglomerate together. The Council says that the existing uses on this site are harmful to amenity. However, the site has operated for many years without any significant issues and if renewal for B1 type uses are encouraged then the employment area can be maintained without harm to amenity. Renewal of the employment stock can help develop and improve trade, improve the sustainability of businesses as a whole and make for a more flexible labour market as skill levels are varied. A singularly different use altogether or a variety of uses which excludes employment could undermine the long term sustainability of the area and Town Centre. As such Policy H1 is not an effective strategy and should be amended to acknowledge the importance of Eldon Way and the need to renew the employment stock to ensure that the site maintains its important role as a employment site, albeit with some ancillary alternative use development where appropriate.

The 2008 Retail Study notes that Hockley Town Centre is not strong and there is trade leakage. Eldon Way Industrial Estate provides a customer base for existing town centre uses. Weekday spending within town centres is an important contributor to the viability of many retail and leisure businesses either through expenditure by employees during the lunchtime trade or expenditure by employers, on necessary goods and services. This relationship helps sustain the critical mass of a centre and provides a platform for new retail and leisure growth. It is important to have a balanced centre with a variety of uses. Policy H1, as currently drafted, implies the removal of employment related development and this is likely to harm the vitality and
viability of Hockley Town Centre. The Council has presented no evidence to suggest that this is not the case. Importantly, the 2008 Retail Study explains that there is a need for additional retail and office space. In principle we would support additional office and other B1 type uses plus retail but employment uses should always dominate for the sustainability reasons given above. Retail and office development are likely to present a viable alternative to some of the more industrial type uses.

Consequently, we do not support the phrasing of the third paragraph of Policy H1 and maintain that the most appropriate strategy is to seek renewal of the employment stock with employment based uses and with some new retail development. Removal of employment land uses completely as currently implied-which was the approach adopted in the emerging Hockley Area Action Plan - is not a justifiable strategy.

One of the key tests of a Core Strategy is consistency between policies in the
emerging Plan and this strikes at the heart of demonstrating an effective strategy. Policy H1 implies alternative uses to employment and the relocation of Eldon Way to a site identified under Policy ED4. However, Policy RTC6 sets out a suite of policy criteria for Hockley Town Centre which includes employment and commercial activities. In addition Policy ED3 seeks the protection of sustainable employment sites (Eldon Way) and notes that some reallocation of existing employment sites will include a proportion of employment. It notes that in the case of Eldon Way employment development will form a component. The policies appear at odds with one another. The third paragraph of Policy H1 should be deleted as the second paragraph is sufficient to set a strategic context for delivering new housing development. The employment policies and Hockley specific policies should be left to consider the type and quantum of land uses appropriate in the area. If the third paragraph of H1 is to be retained then it should tie in more with Policy RTC6 and in our view explain that employment uses should dominate any redevelopment proposals for the Eldon Way site and that retail and leisure uses should be a supporting proportion.

Implementation, Monitoring and Delivery - page 132 onwards

One of the key tests of soundness is that the Core Strategy should be effective - it should be able to deliver its strategy. The Implementation strategy set out at page 132 onwards of the Core Strategy does not explain how Policy H1, RTC6 and the strategy for redeveloping Eldon Way (Policy ED2 and ED3) will be delivered. The comment at Policy ED3 on page 161 identifies it as a potential risk and alludes to land assembly difficulties and the choices to be made by owner/occupiers. In order to deliver the strategy there should be a clear understanding as to whether the new land use values being promoted are sufficient to encourage relocation voluntarily. Secondly there is a need for more information to be gathered and presented to show
that current occupiers and landowners are wiling to relocate and the timescales likely for this. For example, do the building lease contracts enable early review or are there any break out clauses. There should be some commentary on whether the Council will engage in compulsory purchase orders to pursue their strategy should the 'encouragement' route fail. As currently drafted there is no clear path to deliver the strategy and the danger is that despite reallocation, the sites identified for redevelopment will not come forward in the plan period. In this regard, evidence to satisfy the test of soundness is not provided.

Policy H2 - General Locations

We support the strategy that new housing growth should be targeted at land South of Hawkwell. This area is suitably located to the urban area of Hockley/Hawkwell and to tie in with the settlement tiers on page 40 of the Submission Core Strategy the same terminology for settlement should be used. This ensures a consistency within the SCS. The choice of this location as a housing growth area is appropriate as it would not contribute to the coalescence of the urban area with Ashingdon (there is existing
development between this identified housing area at Rectory Road and Ashingdon and moreover, Rectory Road can form a natural physical boundary for the new Green belt boundary. This area is also well located to the existing road network. Cherry Orchard Way has recently been improved and provides much better accessibility to the proposed housing growth area than any other location around Hockley/Hawkwell. The existing bus routes along Rectory Road also make this location sustainable and the additional housing proposed will help underpin the financial viability of bus routes in this area. Locally there are employment opportunities, including the small commercial estate off Main Road. The Eldon Way Industrial Estate adjacent to the Town Centre also provides the opportunity for employment locally. Extensive public open space, play pitches and built leisure facilities are located just to the north of this area and a community hall is located off Briar Close, nearby. The area to the south of Hockley/Hawkwell is close to local shops on the corner of Heycroft Road and Main Road and there are numerous footpath links between this area and the local community including links via Thorpe Road, Thorpe Close, Briar Close, Hawkwell Park and Park Gardens. The area therefore provides the opportunity to enhance existing links, including cycle links, and
contribute towards community integration - more so than other sites on the south side of this settlement. The site is also in the control of one house builder and deliverable.

However, we find that the Policy is not fully consistent with national policy and
furthermore needs to be reviewed in order to be justified and effective. We have concerns as to how the Green Belt review strategy set out at Policy H3 and in the Local Development Scheme integrates with this policy and feel that Green Belt review should be more explicit throughout the SCS. We note that it is only Policy H3 which indicates the need for Green Belt land review. In fact Policy H3 only pays lip service to the need for a Green Belt review and provides, at best, loose advice in this regard. It says that prior to 2021 Green Belt will be safeguarded save for the releases noted under Policy H2. Policy H3 then goes onto talk about land release for development after 2021 but no time period is set out to provide a framework for any Green Belt review in this latter period. In our view Policy H2 and certainly Policy H3 and Policy GB1 should explain fully the need for a Green Belt review and that such a
review should take place for a defined period. That such a review has not taken place in advance of the SCS is a serious matter for the Inspector to consider in the context of soundness. That said, it is considered that any review of Green Belt should have regard to a period beyond 2021 as indicated by draft Policy H3. Paragraph 1.9 of the East of England Plan explains "this RSS covers the period to 2021 but sets a vision, objectives and core strategy for the longer term". 2026 is therefore considered a minimum suitable period that any Green Belt review must have regard to in order to meet the 5 year land supply requirements in PPS3 for the period after 2021. However, Policy SS7 of the East of England Plan talks about Green Belt reviews up to 2031. In view of this and the need to explore the circumstances of Rochford - that existing settlements cannot contain future housing growth; that Green Belt is necessary to provide housing; and that these provide exceptional reasons to vary the Green Belt locally (paragraph 2.6 to 2.7 of PPG2) the policies and strategy for the SCS should identify a Green Belt review covering the
period to 2031 and set out why a review is necessary.

Policy H2 - Phasing and Quantum

The 2008 Preferred Core Strategy document indicated that the area south of Hawkwell should deliver 330 dwellings over a phasing period to post 2021 (see Policy H2 and H3 of that document). The SCS reduces the quantum of housing in this area to 175 but expects delivery by 2015. At a broader level the Preferred Options Core Strategy of 2008, (Policy H2) required 1,450 dwellings to 2015 and a further 1,050 by 2021. In the SCS the figures are now 775 and 1,010 respectively.

Since the SHLAA post dates the publication of the SCS, we are uncertain as to the reason why such a significant reduction in quantum of housing and extensions to the residential envelope is considered necessary. Presumably it is the 'new' strategy to redevelop existing employment areas within the settlements that has led to this change. Our representations on this strategy and specifically the Eldon Way Industrial Estate are included elsewhere within our representations. Previously we have commented on the Table at paragraph 4.6 of the Submission Core Strategy and the lack of evidence to underpin that table. It seems odd that in the space of a year the expected requirement for Greenfield sites has effectively halved on the basis of a SHLAA exercise. The community is therefore not able to effectively comment on the housing land supply and at this stage the Submission Core Strategy
is legally unsound.

That said, we are of the view that the quantum of housing envisaged south of Hockley/Hawkwell should be more than the 175 currently envisage. In coming to this view we have reviewed the Urban Capacity Study and the latest housing figures in the Annual Monitoring Report 2008. We conclude that the shortfall in housing land supply is such that 330 dwellings in this location is appropriate.

The recently published SHLAA is based upon the data obtained from the Urban Capacity Study 2007, a call for sites exercise and data from the Annual Monitoring Report 2008.

The 2007 Urban Capacity Study (UCS)

1. 2007 is widely recognised as being the peak level of house prices in the UK and it was acknowledged by Government and practitioners alike that 2007 house prices were at an unsustainable level. It is our view that utilising the 2007 UCS as an evidence base without reference to the market does not pick up the depressed demand that is likely to now exist. Recent corrections to the housing market now mean that housing land prices are at a much lower and arguably more affordable level than before. The implications are that some pdl may not be viable for housing development. Often brownfield sites have much higher development costs than Greenfield sites and so the yield from urban capacity will be much lower than anticipated in the 2007 study. One example is the employment allocation of the Adopted Local Plan located at 76-92 Main Road, Hawkwell. This site has been allocated for several years and has been available during the most recent rises in residential property prices during
2006-07. As a consequence the lack of progress on the site can only be described by its current occupancy and perhaps it comprises high value
uses that do not encourage redevelopment. Despite this the site is identified as having high potential for alternative use and high potential demand. The SHLAA form notes that there is no information on legal constraints (e.g., tenancy agreements) As a consequence it is difficult to see how this could continue to be a potential site and as a consequence the allowance for green field releases should be increased.

2. There are considered to be other instances in the UCS and the recently published SHLAA where the assumptions and calculations would indicate that the 1301 urban capacity figure is over optimistic and the SHLAA assessment is limited. In the assessment of 'non-residential sites in appropriate locations' within the UCS assumptions are made as to the probability of sites coming forward for new housing. 68-72 West Street, Rochford is identified as a high probability site but we note that it has been subject to 7 refusals of planning permission/conservation consent. There is a significant gap between the urban capacity identified as being suitable by the Council and the capacity applied for by the owners. Given its alternate use value, it is debateable whether the two capacity figures can be reconciled. No 247 London Road is another example of a site allocated in the Local Plan but which hasn't come forward. This is now the subject of a proposal for a care home and if approved would further limit the scope for market/affordable housing capacity on the site. A striking example of how the urban capacity study has underestimated is also evidence by 2-4 Alderman's Hill, Hockley - described as a disused service station. There has been no residential development application on
this site since 2004 and most recent applications have sought commercial use of the site. Rather than being evidence of housing land deliverability, this particular site evidences the need for commercial uses in the area.
There are therefore deliverability doubts over these 'high probability' categories which amount to some 40 units.

3. In relation to the assessment in the UCS entitled 'intensification of existing
residential uses' we note that the assessment is premised on an assessment of recent trends taking into account net completions between 2001-2006 and 2005-06. This is effectively an assessment of windfall trends and not an approach that PPS3 encourages. Importantly Table 3-12 in the urban capacity study seeks to project forward urban capacity from residential redevelopment - a period that benefited from high house prices and PPG3 guidance encouraging redevelopment. These two circumstances have markedly changed and so the assumptions and conclusions drawn would also have changed. Even taking into account the UCS discounting, the reliability of the 404 units from this source must be questioned and in our view the 1301 figure cannot be a sound basis for urban capacity and further Greenfield releases are necessary.

4. In the section of the UCS entitled 'subdivision of dwellings' and 'living above the shop' it is estimated that recent trends would result in 7 and 15 units. Our concerns with using trends as a basis for urban capacity are detailed above - PPS3 does not encourage this. Rather, local authorities are charged with surveying their areas, identifying which areas may yield urban capacity and how much and developing policies to achieve that. Government guidance does not encourage the estimation of windfalls in the way the UCS does.

5. Redevelopment of established employment land is a separate section
within the UCS. At 1 above we identify the low probability of the Main Road residential allocation coming forward. This remaining section of the UCS considers 11 further employment sites which were first identified in the 2000 UCS. Three of these are considered to have a high probability of coming forward. We have looked at these three sites and can find no evidence that they are likely to come forward. In the 8 years between 2000 and 2008 the three identified high probability employment sites have not been developed and there is no reason to assume that the next 5-10 years will be any different. For example the Rawreth Industrial Estate is identified as being well used in the UCS and although it has some unneighbourly uses there is no indication that the site is available, suitable or deliverable for residential. Land between 39-69 Lower Lambricks, Rayleigh is identified as having a high probability of residential uses. Yet there is no evidence of any pre-application advice or planning applications for this area. Stambridge Mills, Mill Lane, Stambridge is a further example. This site is separated from the urban area, in a flood risk zone and protected in the 2006 Replacement Local Plan by Policy EB9 which promotes B1 uses. Against this background there is only two relevant planning applications affecting this area both date from the early 1990's and relate to a plant room and loading bay. There is no evidence that this is likely to come forward for residential purposes in the next 5-10 years.

6. In the UCS extant permissions are identified as 856 dwellings. It is
important to note that this figure needs to be continually reassessed so
that from the point of adoption of the Core Strategy a 5 and 10 year
housing land supply is available. The SHLAA notes extant permissions for
2009-14 being 106. As noted below extant permissions do not necessarily
translate into deliverable sites. There is therefore a contingency that
needs to be built in. Further allocations on greenfield land need to be
increased and as such the quantum of housing in the area south of
Hockley/Hawkwell should be increased to 330 dwellings in order to begin
to meet the shortfall identified.

The District Council's 5 year housing supply assessment

7. The District Council's Annual Monitoring Report ("AMR") 2008 purports to
demonstrate a 5 year housing land supply. The preamble to Table 4.10 in
the AMR 2008 explains that Rochford District Council ("RDC") has
included units under construction, units with full permission, units with
outline permission, units with a resolution to grant, units subject to preapplication discussion/Urban Capacity Assessment and land allocations in
its trajectory. The reader is referred to Appendix B which breaks down the
sites in more detail. The recently published SHLAA also includes a table
showing a potential 1273 dwellings deliverable. However, it refers to
"appropriate brownfield sites." Since these 'appropriate sites' are do not
benefit from an application or a planning permission it is difficult to
programme them into the housing delivery trajectory.

8. In the full planning permission category of the AMR 2008 where work has
not yet started there can be no guarantee that all these sites will be delivered in the 5 years. This comment relates to the one above in relation to the recently published SHLAA. It is not uncommon for permissions to be obtained to provide a means for valuing a site where the owner has no immediate plans to sell the site or develop housing. Delivery may also be hampered by funding constraints, or site assembly problems (where sites are in an alternative use or relocation constraints). Appendix B of the AMR 2008 does not set out the intentions of the landowner or whether the sites are truly achievable in the 5 year period as per PPS3 requirements. The SHLAA purports to show developer intentions at Appendix C but the assessment by the local authority into the legitimacy of some of the claims is not presented. The evidence base is not as full as it should be to demonstrate the robustness of Table 4.6 of the SCS. It is also unclear the extent to which this table is based on either the UCS 2007, AMR 2008, SHLAA 2009 or a combination of all three. This should be set out clearly.

9. In addition, to the 'non delivery' of a proportion of new homes in the AMR
2008, there is concern at the timings of delivery in that data set, for
example, 10 units in 2008-2009 relates to outline planning permissions
and it is doubtful whether reserved matters can be turned round quick
enough to begin delivering housing in this year period. There could well
be examples in that set of data where the delivery of units in the first year
of the 5 is unlikely, thus delivery is reduced for that period and pushed
back and this process is then compounded throughout the data set up to
and beyond year 5. Statistical evidence from the Department of
Communities and Local Government ("CLG") reveals that building starts
are 43% down on the quarter to March 2009 compared with March 2008.
It is not clear whether the recently published SHLAA has taken this into
account and unless it does the data in the Table at 4.6 of the SCS cannot
be relied upon, particularly given the current recessionary circumstances.
In relation to the Table at Paragraph 4.6 a refinement is therefore needed
to take into account this effect on phasing.

10. This problem is compounded for other units relied upon where permission
has been granted but no start on site has been made; this accounts for a
considerable number of sites in 2009-10 period (100 dwellings) which is
(year 2 of the 5 year period). A delay in these will require more Greenfield
sites to be identified in order to meet the shortfall.

11. Finally we note that the East of England Plan expresses its land supply
requirement as a minimum. This strategy is not reflected in the
Submission version of the Core Strategy policy H2.

12. In summary since neither the UCS nor the Annual Monitoring Report form
a SHLAA, reservations are maintained about the degree to which
sufficient housing land has been identified.

Policy H3

In the Preferred Options Core Strategy 2008 more locations were identified for
housing growth in the post 2021 phase. Whilst it is our view that land south of
Hockley/Hawkwell should benefit from a greater number of dwellings than the 175 currently identified (330) in order to make the strategy effective. We are concerned at the significant change in strategy between the Preferred Option Core Strategy and the Submission version, which has significantly less housing growth on green field sites. This change in strategy is so significant that we would question whether it is appropriate in the context of soundness and the consultation processes that have taken place so far.

We also have concerns as to how the Green Belt review strategy set out at Policy H3 and in the Local Development Scheme integrates with other policies in the SCS and feel that Green Belt review should be more explicit throughout the SCS. As it currently stands there is a potential conflict with national policies and limited justification for the Green belt strategy. We note that in Policy H3, which indicates the need for Green Belt land review, the advice is limited and unclear. In fact Policy H3 only pays lip service to the need for a Green Belt review and provides, at best, loose advice in this regard. It says that prior to 2021 Green Belt will be safeguarded save for the releases noted under Policy H2. Policy H3 then goes onto talk about land release for development after 2021 but no time period is set out to provide a
framework for any Green Belt review in this latter period. In our view Policy H3 and Policy GB1/H2 should explain fully the need for a Green Belt review and that such a review should take place for a defined period. That such a review has not taken place in advance of the SCS is a serious matter for the Inspector to consider in the context of soundness. That said, it is considered that any review of Green Belt should have regard to a period beyond 2021 as indicated by draft Policy H3. Paragraph 1.9 of the East of England Plan explains "this RSS covers the period to 2021 but sets a vision, objectives and core strategy for the longer term". 2026 is therefore considered a minimum suitable period that any Green Belt review must have regard to in order to meet the 5 year land supply requirements in PPS3 for the period after 2021. However, Policy SS7 of the East of England Plan talks about Green Belt reviews up to 2031. In view of this and the need to explore the
circumstances of Rochford - that existing settlements cannot contain future housing growth; that Green Belt is necessary to provide housing; and that these provide exceptional reasons to vary the Green Belt locally (paragraph 2.6 to 2.7 of PPG2) the policies and strategy for the SCS should identify a Green Belt review covering the period to 2031 and set out why a review is necessary. Not to do so is unsound for justification and effectiveness reasons.

Policy H4 - Affordable Housing

As currently drafted we feel that the policy is not concise enough and that the policy does not reflect current guidance. The phrase 'at least' would indicate that in most cases affordable housing above 35% will be sought. Our understanding is that the 35% figure is recommended in the SHMA and that to provide a policy framework which seeks to go beyond that figure would potentially be unworkable as many sites could not financially bare the burden of over a third of the net developable area not yielding a value. The policy should be redrafted so that "a target of 35% affordable housing shall be provided on all developments of 15 or more units..."

The last policy paragraph provides some scope to relax this policy, if there are clear site constraints that make on site provision impossible. The policy, though, is not particularly clear on what would constitute exceptional circumstances. For example, physical site constraints, which unusually raise development costs, would be one such reason and this should be specified. There may be other reasons including the nature of housing needs in the part of the District the site is located which justify affordable housing below the 35% target. Design reasons may also have a bearing on how provision is made and in what form, particularly if the site is in an historic area where design might override housing need argument. It is therefore recommended that the policy expand on the type of circumstances where affordable
housing may be relaxed and the type of information that will be sought of applicant's who have a need to invoke this part of the policy.

Policy H5

In support of the policy, it is advantageous that no percentages requiring a specific mix are included. This flexibility will enable developers and the Council to respond directly to changing circumstances in the local housing market. In the past some authorities have set out a percentage for the type of housing they require only to find that after a few years of strict implementation there is an oversupply of property of that type and no flexibility in the policy to address the problem.

Policy ED2 - London Southend Airport

It is considered that to grow non aviation related employment at a location north of Southend Airport where sustainable access from the rest of Rochford District requires careful consideration. Most Airports are serviced by aviation related employment development and as such a location close to the airport is sensible and sustainable. However, for surface access reasons it would be inappropriate to encourage travel from Rochford's main settlements to what essentially would be a rural location for general employment uses. Whilst sustainable access would be improved by a railway station and better bus links, there is no evidence to suggest that a sustainable surface access strategy for non related employment development at the Airport can be achieved. Paragraph 11.22 explains the critical importance of a
railway station to the delivery of the strategy yet the Transport Chapter and
Implementation Chapter provide neither a policy nor an assessment of deliverability. It is also notable that the South Essex Rapid Transit Policy T4, as set out at paragraph 10.16, notes that Rochford is not proposed to be served but may be served in future phases. This uncertainty is no way to plan for a major employment land supply strategy in the District. In relation to PPS12, the ability to deliver sustainable green field employment sites away from the top tier settlements of Hockley/Hawkwell, Rochford and Rayleigh is unsound.

Policy ED3

We fully support the first sentence of the Policy and note the apparent contradiction with the statements in Policy H1 and elsewhere which seeks to develop on alternative uses at industrial estates such as Eldon Way.

This contradiction is evidence in the second paragraph of Policy ED3. In our
representations on Policy H1 we have explained why it is not sound to diminish the employment stock at Eldon Way and the importance of maintaining a dominance of employment type uses at this estate. These arguments are not repeated here.

We note the sentiments of the third paragraph and in accordance with our
representations elsewhere are of the view that this sentence should be revised to explain that Eldon Way will accommodate principally employment type uses. As noted elsewhere uses which are an alternative to employment would diminish this highly sustainable employment site and this is unsound when assessed against National Policy.

Policy ED4 - Future Employment Allocations

In part, the de-allocation strategy is not supported as it is considered unsound when set against sustainability criteria. In relation to the Eldon Way Industrial Estate it is considered critical to the ongoing sustainability of this settlement that employment uses are maintained at this location. It is close to the railway station, bus routes and local residential areas from which the opportunity exists for employees to walk or cycle to work. Its location adjacent to the Town Centre offers opportunity for some retail and leisure development to complement the centre and to maintain a supporting function. These sustainable benefits would not occur with the deallocation of Eldon Way or the significant erosion of its employment floorspace. Whilst redevelopment of the employment site to achieve new employment is supported, the dominant land use should continue to be employment use. As a consequence, the 18ha of land required for employment in this policy is considered to be excessive and the policy should be reviewed to explain that redevelopment of existing employment sites for primarily new employment development will be
encouraged.

Policy T4

It is noted that the South Essex Rapid Transit policy, as elaborated upon at
paragraph 10.16 notes that Rochford is not served but may be served in future phases. This uncertainty is contrary to the delivery principles of soundness and directly puts at issue the employment land supply strategy in the District which is founded on sustainable access to new sites. In relation to PPS12, the ability to deliver sustainable green field employment sites away from the top tier settlements of Hockley, Rochford and Rayleigh is unsound.

Appendix H1, CTL1 - Infrastructure

It is recognised that necessary infrastructure provision is an important part of creating a sustainable development and in that context appendix H1 is supported. The supporting text notes that the table at Appendix H1 is not exhaustive and in that context it is very important that the framework properly distinguishes between what should be provided as part of new development schemes and what shouldn't. It is therefore essential that the framework acknowledges the importance of Circular 05/05 and the tests which say that provision of infrastructure and/or contributions should be:

* Relevant to planning
* Necessary to make the proposed development acceptable in planning
terms
* Directly related to the proposed development
* Fairly and reasonably related in scale and kind to the proposed
development
* Reasonable in all other respects

As is made clear (Paragraph B9 of Circular 5/05) contributions should not be used to make good existing deficiencies in infrastructure provision. Nor are they to be used to secure contributions to the achievement of wider planning objectives that are not necessary for consent to be granted. In that context the Core Strategy should set this out as its policy framework.

Policy GB1 - Green Belt

The objectives of this policy are supported, although as noted in other
representations the SCS is unsound as it does not meet the tests in relation to
justification, compliance with national policy or effectiveness of strategy.

Policy GB1 mentions the objective to allocate the minimum amount of Green Belt land necessary. The policy should link to the requirements of PPG2 and RSS which are discussed in relation to the representations on Policy H2 and H3. The policy should set out a timeframe for the review and why Rochford requires a Green Belt review (what the exceptional circumstances are in this District that justify a review of local boundaries. The policy should be amended to set out a 2031 time frame and this may require the SCS to have an extended life span beyond 2021.

We would recommend the deletion of the word character since Green Belt
designation is not related to landscape character as currently drafted. For clarity we would also recommend that the Policy or its supporting text explain that a Green Belt review will takes place in support of an allocations document (paragraph 6.6) in order to identify an appropriate new boundary. This is particularly necessary given the commitment to a Green belt review in the adopted Local Development Scheme.

Policy CLT1 - Planning Obligations and Standard Charges

In view of the need to test fully the basis on which standard charges are based it is important that any document produced is in a development plan document that enables an examination in public. The policy should explain this in order that when the document is produced it accords with Policy and is based on sound evidence.

ENV9 - Code for Sustainable Homes

Object. The advice from the Department of Communities and Local Government is that the new requirement to have a rating against the Code does not make it mandatory to build a Code home or to have each new home assessed against the Code. It does however mean that all buyers of new homes be given clear information about the sustainability of the new home. A house builder can do this in one of two ways:

- they can chose to build a Code home, have that home assessed against the
Code and provide the home buyer with a Code certificate stating the star rating the home has achieved
- or, they can chose to build to current building regulations standards, not to pay for an assessment and instead download a nil-rated certificate of non-assessment (also referred to as a nil-rating) to provide to the home buyer.

As such the Rochford policy requirement that coding 3 be achieved by 2010 and Code 6 by 2013 is out of step with Government advice. The policy wording should explain that it is just the coding that is a requirement of new homes and not necessarily that new homes should be constructed to achieve a standard.

The current Government objectives are for the code to be introduced over a
reasonable period with development to be code 3 by 2010, code level 4 by 2013 and code level by 2016. In this regard the policy, as drafted, seeks to achieve code 6 by 2013 and consequently compresses the code requirements into a shorter time scale with the costs associated expected to be subsumed within the housing market though higher prices. This is not a realistic strategy for the delivery of sustainable homes and we consider that the policy should be revised to extend the period of compliance but to also make it more flexible based on local circumstances.

Research undertaken on behalf of the Housing Corporation and English
Partnerships, published in February 2007 'A cost review of the code for sustainable homes' reveals that code 6 is unlikely to be unattainable given existing technologies and that achieving code 5 could result in a 12% to 20% increase in costs that would have to be passed onto the consumer. Given the variability of the housing market with peaks and troughs, it is unlikely that the housing market would be able to subsume this level of price increase.

The code system policy as currently drafted does not have regard to site
circumstances and so many of the requirements could be difficult to meet. For
example, micro electricity generation on site may be difficult to achieve where local circumstances deter the capture of wind or solar power. If more expensive technologies are required to generate power than is the norm then costs will rise. There may be other competing reasons why designs cannot include certain sustainability measures if housing sites are in sensitive landscape and historic locations. Alternatively there may be significant development costs associated with site specific circumstances and so viability of the site's development becomes a valid consideration. By insisting on the code for sustainable homes other policy objectives such as affordable housing at particular rates and other contributions may need to be reconsidered. Consequently, we are of the view that this policy should be drafted in a
manner which enables site specific circumstances to be taken into account. As noted above the Government explains that the code is a certification requirement and does not necessarily mean that buildings are constructed in accordance with a code level.

It is also important to note that it is not the purpose of planning legislation to duplicate other legislation. In this regard, the policy should accept that the Building Regulations will be the main vehicle for implementing this policy and that unless the coding requires external development then there will be no need to specify what is to be carried out in a planning application.