Appendix CLT1

Not sound in terms of national policy consistency as standard charges for open space and leisure facilities only sought from residential developments. However, employment, tourism etc development also generates open space/leisure needs and PPG17 requires the needs of those working in and visiting areas to be included in assessments and planning permissions do not only apply to housing. This could result in new non-residential developments not making any provision for additional needs that they generate. Also standard charges towards open space should be expected from residential developments as not appropriate to always provide on-site e.g. playing pitches.

The Core Strategy identifies infrastructure that may form the basis of applying standard charges or negotiating planning obligations with developers.

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.

Para 4.8 States sustainability underlines any decisions on housing location, primarily: current and future deliverability of infrastructure, eg roads, services, public transport, health.

Policy H1
Para.4.14 Some employment sites are considered more suitable for other uses (eg housing) including Eldon Way/Foundry, Hockley. This is all open to question.

Hockley-re Eldon Way/Foundry
In CS Preferred Options 2008 policy H2 you discarded N.E.Hockley as a housing option - whilst close to centre, station, "impact on highway network from traffic heading through Hockley..along Ashingdon Road..renders location unviable". Clearly the same principle applied to Eldon Way/Foundry for the same reasons.

Response to C.S Preferred Options 2008 and HAAP 2009

June 2009 issue C S Submission issue says Eldon Way will be used for housing, whereas Sept.2009 issue says "alternative uses, including residential.." to be decided by HAAP (Issues consultation done, Pref.Options issue awaited, but judging from JAAP Pref.Options decision - namely biggest option chosen against overriding opposition, it will be housing).

Need to be logical and even-handed in proposals

Health services GP surgeries are full and a PCT health centre will not occur in the foreseeable economic climate.

Ch.10: Highways and Transport
Policy T1, T2 RDC proposes working with ECC Highways, developers, but admits it has no authority, responsibility here. RDC will seek developer contributions, but this is neither detailed nor costed in CS Submission nor HAAP, and contravenes PPS 12.3 para.4.93 which states "The infrastructure planning process should identify as far as possible infrastructure needs and costs". Idea of paying for road & transport improvements through Standard Charges is unproven and unsound.

Establish likely level of Standard Charges. Accept you cannot turn district into motorways with wholesale demolition.

In neither CS Submission nor HAAP is there any highways improvement, except idea to replace Spa roundabout with traffic lights and 1 way system up Southend Road and Hockley Rise.

Para.10.5 "..highway improvements serving new developments..in a timely manner..ensuring developments delivered alongside necessary infrastructure".
These improvements cannot possibly be delivered. It should be realised: B1013 (Southend Rd), Rectory Road Hawkwell, Ashingdon, West Rochford - all in area proposed for large new developments are former winding, narrow country roads, tarmacked over for motorised traffic. Large housing increments are unsustainable off these roads, which cannot be altered without much destruction.

Reply to CS Pref. Options 2008 & HAAP Issues/Options 2009

Policy T3, CLT1 Appendix CLT1 Public transport RDC admits this is in the private sector. In Hockley, operator has cut No7 service to 1 per hour from Ashingdon Schools, claiming it is unviable beyond. This is unlikely to change as Hockley is car dependant. No8 bus through Hawkwell is cut to 1 per hour to Rayleigh, for same reason as No7. Proposed planning agreements with developers can't run: eg, a community centre or classroom given by a developer remains once he has moved on - how can that apply for an on-going bus service?

Reply to Infrastructure Transport in CS Pref. Opts. 2008 and to HAAP Issues Opts. 2009.

Ch.11 Economic development

Policy ED3 Core Strategy preferred Options 2008 hinted at possible housing in Eldon Way site. June 2009 Submission version, without consultation, said Eldon Way would be housing (map included Foundry, not the text). September 2009 Submission said redevelopment would be in HAAP (which apart from the Issues/Options version, is unfinished. Judging from results of JAAP Preferred Options where biggest option is chosen, though most respondents were against it, site will be housing, without consultation.

Para.1.25, Para.11.32 Note CH.1 Introduction to CS Submission 2009 para.1.25 East England Plan requires 3000 additional jobs, presumably to 2021. Revised Southend Airport is expected to drive Economic development. But at para. 11.32 Eldon Way-Foundry estate is planned to be more suitably utilized. "..alternative land will be required to accommodated employment uses so displaced" - ie jobs sent to eg new site near Southend Airport - not new jobs.

Reply to HAAP Issues Options 2009

Remove compulsory relocation

Policy ED4 Policy states Council will allocate 18ha of land to make up for de-allocations in ED3 - that proves point above.

Proposals for moving employment to out of town locations with no existing transport links are contrary to government policies PPG4, PPS1 and PPS4 and Core Strategy Policy T1.

Evidence Base is ignored by contravening Hockley Parish Plan 2007 and ignoring resents' views on HAAP Issues/Options. Next stage of HAAP Preferred Options is pre-empted and rendered irrelevant. Core Strategy plans to relocate Eldon Way Foundry estate to Greenfield site with no nearby bus or railway. RDC plans to upgrade the nearest road to dual carriageway, though the connecting B1013 (through Hockley) will stay single, said by ECC Highways statistics to be 72% capacity. Airport bosses and council cannot suggest there will be no traffic growth from JAAP and new industrial site.

Reply to Hockley Parish Plan 2007. HAAP Issues 2009

Move to new industrial site near airport contravenes PPPS4:

- EC7.3C "out of centre sites, with preference given to sites..well served by choice of..transport and..close to centre and..high likelihood of forming links with centre". There is no current public transport and links with centres is unlikely".

- EC 7.5.1 "whether the site is or will be accessible and well served by choice of transport, public transport, walking and cycling, as well as by car..". Remote location, narrow busy B1013 makes the site unsuitable for access by cycle or on foot.

It also contravenes PPS1 (27vii).."reduce need to travel, encourage accessible public transport provision to secure more sustainable patterns of transport..Planning should actively manage patterns of urban growth to make fullest use of public transport and focus development in existing centres, near to major public transport interchanges". Core Strategy undermines its own policy Transport and Highways policy T1 and is unsound.

Although shown on accompanying drawing in earlier versions, there was no prior textual mention of Foundry industrial estate (next to Eldon Way) for redevelopment until current CS 2009 Submission. This was stated to be a typing error, but does not inspire confidence in reliability of drafting.

Revise both 2009 Core Strategy and 2009 HAAP Issues/options

Chapter 12: Retail/Town centres
The Core Strategy misrepresents findings of the Retail and Leisure Study 2008.

Para.12.38 The Core Strategy states (para.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 floorspace".

3) (10.29) "we recommend 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 has a very small catchment population. Accordingly, the council may wish to consider reclassifying Hockley from a town centre to a district centre".

Defer whole of proposals for Hockley town centre to Hockley Area Action Plan.

The Council will work with landowners and its partners to deliver the HAAP.

Remove threat of compulsory purchase orders.

One doesn't perceive impartiality when the Planning Director replies to local' HAAP survey with "The affluent people of Hockley are entitled to famous name shops".

Chapter 5: Character of Place and Local Lists
Para.5.4 "Rochford district has unique character..stems from traditional buildings..still dominate towns and villages".

Para.5.17 "Council believes many buildings..are of local distinctiveness..part of..cherished local scene".

This only applies to favoured places: Rochford, Rayleigh, greenbelt villages. Many Hockley conservable items have been systemically removed for supposedly lucractive development in face of widespread protect. This is for supposed need for housing. In fact heritage items have been replaced by dwellings most cannot afford, and/or are hard to sell due to unsuitability of massing and siting. Many other homes are jeopardised by this practice.

HAAP issues 2009. Core Strategy 2006, 2007,2008, SCI.2006

Fewer 'vested interests', more even handedness. No more pressing people out of businesses, homes for expediency.

A CPRE Fieldwork issue extolled Local Lists, citing refusal of 16 flats to replace character house, not on local list. Inspector said house, façade made a contribution to area character, even if English heritage decided it didn't warrant listing. Council worked to get the house grade listed and even made adjacent area conservation one.

Hockley had one such on a "significant site" faced with 13 flats. Ward Member omitted house from refusal proposal, so house could be demolished. RDC dropped Local List ahead of appeal: "Government frowned on such Lists" (Other LAs, unaware of supposed directive retained theirs. After demolition RDC restored Local Lists, saying Government now support them. When Inspector queried the complaint, the then policy officer said "just politics, lot of local interest, nothing of character in the area[!]. (A dozen such items had been removed). Some "distinctive" Hockley buildings are still condemned (in Greensward Lane:, others threatened (Spa Road). Whereas a modest hue and cry in Rayleigh will usually result in a building being saved.

Conclusion

Core Strategy Submission DPD is basically unsound in many respects

Incomplete information. Amongst others, it refers to Hockley AAP, the first stage of which is complete, but not other three. Rochford AAP first stage has been published in arrears of Core Strategy Submission. Rayleigh AAP is still awaited. Precise housing sites are absent, as Urban Capacity Study 2007 has been superseded by Strategic Housing Land Availability Assessment, not yet published. Traders, residents, are thus responding to Core Strategy Submission with incomplete information.

Lack of community involvement. Chapter 1, Introduction, para. 1.11 "Community involvement is an essential part of the plan making process".

In Statement of Community Involvement 2006 Rochford RDC "recognises need to enable people.to have their voices heard".

Re Public Meetings: "Consideration will be had to timing and venue to ensure meeting is as accessible as possible".

Take Hockley Area Action Plan as an example of the opposite of all this:- Presentation of document was at Hullbridge, 7.30pm. It was also discussed with JAAP at Rochord Freight House (for traders only) at 7am, without publicity. Excuse made: HAAP on RDC website, which none will seek unless knowing it is there. Rochford District Matters newssheet had minute articles on p.3, half way through consultation period. Another excuse: a 2nd presentation by Hockley Residents Association with planning officer present: only because of complaints, and it is not the HRA's responsibility to RDC's job. Due to unavoidable haste of calling meeting, few knew and only 50 were present.

In Core Strategy Submission Hockley Parish Plan has been ignored. Proposals also ignore 95% rejection rate response to HAAP 2009, which included proposals for Eldon Way employment site.

Unfettered right of developers to carry on as if Core Strategy didn't exist. In PPS 12, Ch.4.6 states: "Core Strategies should be flexible and able to show how they handle contingencies". Several large planning applications have been submitted proposing developments outside the Core Strategy which does not indicate how such applications will be handled and does not comply with PPS 12.

Where are we? Finally, at Chapter 1, Introduction, para. 1.24: "the Core Strategy will have to be reviewed in the event of a new Local Area Agreement, post-2011, setting different priorities". So what purpose does all this work serve? So we have hardly finished this exercise, before it all starts again?

Ch. 4 Housing: Ch.10 Transport, Highways; Ch.11 Economic Development; Ch.12 Retail/town centres; Ch.5 Character of place & Local Lists

Chapter 4: Housing

Para 4.8 States sustainability underlines any decisions on housing location, primarily: current and future deliverability of infrastructure, eg roads, services, public transport, health.

Policy H1, Para.4.14 Some employment sites are considered more suitable for other uses (eg housing) including Eldon Way/Foundry, Hockley. This is all open to question.

Hockley-re Eldon Way/Foundry
In CS Preferred Options 2008 policy H2
N.E.Hockley was discarded as a housing option - whilst close to centre, station, "impact on highway network from traffic heading through Hockley...along Ashingdon Road..renders location unviable". Clearly the same principle applied to Eldon Way/Foundry for the same reasons.

Need to be logical and even-handed in proposals

June 2009 issue C S Submission issue says Eldon Way will be used for housing, whereas Sept.2009 issue says "alternative uses, including residential.." to be decided by HAAP (Issues consultation done, Pref.Options issue awaited, but judging from JAAP Pref.Options decision - namely biggest option chosen against overriding opposition, it will be housing).

Policy H1, T1 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 PPG14 & 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.

Health services GP surgeries are full and a PCT health centre will not occur in the foreseeable economic climate.

Ch.10: Highways and Transport

Policy T1, T2 RDC proposes working with ECC Highways, developers, but admits it has no authority, responsibility here. RDC will seek developer contributions, but this is neither detailed nor costed in CS Submission nor HAAP, and contravenes PPS 12.3 para.4.93 which states "The infrastructure planning process should identify as far as possible infrastructure needs and costs". Idea of paying for road & transport improvements through Standard Charges is unproven and unsound.

Establish like motorways with wholesale demolition.

In neither CS Submission nor HAAP is there any highways improvement, except idea to replace Spa roundabout with traffic lights and 1 way system up Southend Road and Hockley Rise.

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.

Para.10.5


Policy T3, CLT1 Appendix CLT1
T1 & T2 "..highway improvements serving new developments..in a timely manner..ensuring developments delivered alongside necessary infrastructure".
These improvements cannot possibly be delivered. It should be realised: B1013 (Southend Rd), Rectory Road Hawkwell, Ashingdon, West Rochford - all in area proposed for large new developments are former winding, narrow country roads, tarmacked over for motorised traffic. Large housing increments are unsustainable off these roads, which cannot be altered without much destruction.

Public transport RDC admits this is in the private sector. In Hockley, operator has cut No 7 service to one per hour from Ashingdon Schools, claiming it is unviable beyond. This is unlikely to change as Hockley is car dependant. No 8 bus through Hawkwell is cut to one per hour to Rayleigh, for same reason as No 7. Proposed planning agreements with developers can't run: e.g., a community centre or classroom given by a developer remains once he has moved on - how can that apply for an on-going bus service?

Ch.11 Economic development

Policy ED3 Core Strategy preferred Options 2008 hinted at possible housing in Eldon Way site. June 2009 Submission version, without consultation, said Eldon Way would be housing (map included Foundry, not the text). September 2009 Submission said redevelopment would be in HAAP (which apart from the Issues/Options version, is unfinished. Judging from results of JAAP Preferred Options where biggest option is chosen, though most respondents were against it, site will be housing, without consultation.

Para.1.25 Para.11.32
Policy ED4 T1 & T2 Note CH.1 Introduction to CS Submission 2009 para.1.25 East England Plan requires 3000 additional jobs, presumably to 2021. Revised Southend Airport is expected to drive Economic development. But at para. 11.32 Eldon Way-Foundry estate is planned to be more suitably utilized. "..alternative land will be required to accommodated employment uses so displaced" - ie jobs sent to eg new site near Southend Airport - not new jobs.

Remove compulsory relocation

Policy states Council will allocate 18ha of land to make up for de-allocations in ED3 - that proves point above.

Proposals for moving employment to out of town locations with no existing transport links are contrary to government policies PPG4, PPS1 and PPS4 and Core Strategy Policy T1.

Evidence Base is ignored by contravening Hockley Parish Plan 2007 and ignoring resents' views on HAAP Issues/Options. Next stage of HAAP Preferred Options is pre-empted and rendered irrelevant.

Core Strategy plans to relocate Eldon Way Foundry estate to Greenfield site with no nearby bus or railway. RDC plans to upgrade the nearest road to dual carriageway, though the connecting B1013 (through Hockley) will stay single, said by ECC Highways statistics to be 72% capacity. Airport bosses and council cannot suggest there will be no traffic growth from JAAP and new industrial site.

Revise both 2009 Core Strategy and 2009 HAAP Issues/options

Move to new industrial site near airport contravenes PPPS4:

EC7.3C "out of centre sites, with preference given to sites..well served by choice of..transport and..close to centre and..high likelihood of forming links with centre". There is no current public transport and links with centres is unlikely".

EC 7.5.1 "whether the site is or will be accessible and well served by choice of transport, public transport, walking and cycling, as well as by car..". Remote location, narrow busy B1013 makes the site unsuitable for access by cycle or on foot.

It also contravenes PPS1 (27vii).."reduce need to travel, encourage accessible public transport provision to secure more sustainable patterns of transport..Planning should actively manage patterns of urban growth to make fullest use of public transport and focus development in existing centres, near to major public transport interchanges". Core Strategy undermines its own policy Transport and Highways policy T1 and is unsound.

H1 & RTC6 Although shown on accompanying drawing in earlier versions, there was no prior textual mention of Foundry industrial estate (next to Eldon Way) for redevelopment until current CS 2009 Submission. In recent amendment to the CS this was stated to be due to a typing error!

Chapter 12: Retail/Town centres

The Core Strategy misrepresents findings of the Retail and Leisure Study 2008.

Defer whole of proposals for Hockley town centre to Hockley Area Action Plan.

Para.12.38 H1 & RTC6 The Core Strategy states (para.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 floorspace".

3) (10.29) "we recommend 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 has a very small catchment population. Accordingly, the council may wish to consider reclassifying Hockley from a town centre to a district centre".

Remove threat of compulsory purchase orders.

The Council will work with landowners and its partners to deliver the HAAP.

Chapter 5: Character of Place and Local Lists
Para.5.4 "Rochford district has unique character..stems from traditional buildings..still dominate towns and villages".
Para.5.17 "Council believes many buildings..are of local distinctiveness..part of..cherished local scene".

This only appears to apply to certain places: Rochford, Rayleigh, greenbelt villages. Many Hockley conservable items have been systemically removed for supposedly lucractive development in face of widespread protect. This is for supposed need for housing. In fact heritage items have been replaced by dwellings most cannot afford, and/or are hard to sell due to unsuitability of massing and siting. Many other homes are jeopardised by this practice.

Conclusion

Core Strategy Submission DPD is basically unsound in many respects:

Incomplete information. Amongst others, it refers to Hockley AAP, the first stage of which is complete, but not other three. Rochford AAP first stage has been published in arrears of Core Strategy Submission. Rayleigh AAP is still awaited. Precise housing sites are absent, as Urban Capacity Study 2007 has been superseded by Strategic Housing Land Availability Assessment, not yet published. Traders, residents, are thus responding to Core Strategy Submission with incomplete information.

Lack of community involvement. Chapter 1, Introduction, para. 1.11 "Community involvement is an essential part of the plan making process". In Statement of Community Involvement 2006 Rochford RDC "recognises need to enable people..to have their voices heard".

Re Public Meetings: "Consideration will be had to timing and venue to ensure meeting is as accessible as possible".

Hockley Area Action Plan as an example of the opposite of all this:- Presentation of document was at Hullbridge, 7.30 p.m. It was also discussed with JAAP at Rochord Freight House (for traders only) at 7 a.m., without publicity. Excuse made: HAAP on RDC website, which none will seek unless knowing it is there. Rochford District Matters newssheet had minute articles on p.3, half way through consultation period. Another excuse: a second presentation by Hockley Residents Association with planning officer present: only because of complaints, and it is not the HRA's responsibility to RDC's job. Due to unavoidable haste of calling meeting, few knew and only 50 were present.

In Core Strategy Submission Hockley Parish Plan has been ignored. Proposals also ignore 95% rejection rate response to HAAP 2009, which included proposals for Eldon Way employment site.

Unfettered right of developers to carry on as if Core Strategy didn't exist. In PPS 12, Ch.4.6 states: "Core Strategies should be flexible and able to show how they handle contingencies". Several large planning applications have been submitted proposing developments outside the Core Strategy which does not indicate how such applications will be handled and does not comply with PPS 12.

Where are we? Finally, at Chapter 1, Introduction, para. 1.24: "the Core Strategy will have to be reviewed in the event of a new Local Area Agreement, post-2011, setting different priorities". So what purpose does all this work serve? So we have hardly finished this exercise, before it all starts again?