Policy H1 - The efficient use of land for housing

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

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.

I feel that the plan is unsound and that the farmland should be saved to prevent urban sprawl to the west of Rayleigh. By not building on farmland it will safeguard the countryside from encroachment. Other brown field sites should be used that are available before any greenbelt is considered. The plan is supposed to protect community character and and identity yet will double the population of Raweth. Building here will put unsustainable pressure on Rayleigh's roads and amenities. There is not enough places now for local children in the schools in the west Rayleigh area, Raweth Lane is a solid traffic jam during morning and evening rush hours. The local infrastructure simply can't cope with a further 770 houses.

This policy appears to have decided that, in particular, Eldon Way/Foundry sites will be redeveloped. However, the Hockley Area Action Plan - issues and options consultation gives the impression that this has not been decided. There may be alternatives that emerge and the policy would be inflexible.

We are supportive of the majority of the Policy H1 and believe it to be sound as it has acknowledged the need to develop in the Green Belt adjacent to urban boundaries. However it is questionable on the evidence whether the site at Stambridge Mills is sustainable or deliverable. The inclusion of this site as an identified area for development is unsound as there is no evidence to assert it will be deliverable because of flood risk. The non delivery of this site will place an increased demand for housing allocation which should be recognised in H2

We would welcome prioritising brown land for development, but note later comments on limiting density. The costs of developing Brown land ( dealing with previous buildings, contamination, etc) are often high, and unless a reasonable density of development is allowed on brown land, the costs per property can be uneconomic.

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.

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.

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

The CS totally 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".
5) "we do not consider it to meet the definition of a 'town centre' as set out by PPS6"

There is more capacity for intensification in existing settlements before releasing this amount of Green Belt. RDC has provided no evidence of harm to the character of existing settlements which have low densities. DPD is unsound, RDC has not provided justification for the release of Green Belt and is not consistent with national policy which aims to reduce the need to travel by private car by locating development in sustainable locations which offer good access to jobs, key services and infrastructure. It is not legally compliant as it does not conform to the RSS or national policies.

Stambridge Mills Industrial site will be unsustainable for housing due to flood risk and the potential mitigation costs and therefore should be retained for light industrial use. Alternative site for housing needs to be allocated.

A comprehensive policy, although it could be criteria-based.

Whilst the priority for brownfield land is supported, the inclusion of Stambridge Mills is unsound. There is scant evidence on the absolute need to re-use land in the flood zone to deliver the housing numbers for Rochford when alternative and deliverable options exist in areas of lower or no flood risk (i.e. land to west of Hockley). This approach is inconsistent with the sequential approach contained in policy in PPS25.

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.

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.

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.

The general approach to the identification and efficient use of land for housing is supported, however, the redevelopment of the four existing employment sites is unrealistic in the timescale proposed. It is also counter-productive to the strategy, as it does not represent sustainable practice or meet the test of soundness. It will require the allocation of alternative employment land in the Green Belt to accommodate the displaced businesses. It would be more appropriate to upgrade existing employment sites where possible, and identify additional land on the edge of the most sustainable settlements to accommodate future housing growth.

Agree, however, if and when developments take place at Stambridge Mills a 106 Agreement should be sought to be able to build a bridge over the Roach for an alternative entrance/exit to the site with potential to link up to Fossetts Farm. This could also be applied to the current proposed development for Coombes Farm. From a trading point of view, the Chamber welcomes additional housing to the east of Rochford, but seeks additional infrastructure for existing and potential new housing to the east of Rochford to relieve the necessity to access them through the centre of Rochford.

HPPG objects to the redevelopment of Eldon Way Industrial Estate for residential purposes. The proposal was not included in the October 2008 version, hence did not go through public consultation. It is unacceptable to Hockley residents because: Hockley Parish Plan published October 2007 recommends no housing development in Hockley, and, if enforced, must not include large housing estates or the loss of greenbelt (both criteria have been ignored). A Resident Survey completed October 2009 concluded that only 13% of residents supported redevelopment of Eldon Way and, if redeveloped, housing development received only just over 1% of response support..

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.

Previous consultations and public opinion ignored by RDC and HAAP pre-empted:
As well as ignoring the Parish Plan and the 95% rejection rate of the HAAP proposals, the Core Strategy proposals pre-empt the next round of the HAAP.

Public opinion in Hockley is strongly against both the HAAP and Core Strategy proposals for Hockley Village Centre. A survey undertaken in October 2009 had 972 responses (over 20% of households) and the key results were:
- shops: only 5% in favour of major redevelopment (43% supported moderate redevelopment and 52% only wanted minor improvements)
- Eldon Way & Foundry Industrial Estates: just 13% wanted major change with a youth centre suggested as the most popular improvement.
- Roads: nearly 2/3rds wanted to retain a roundabout at the Spa Junction instead of traffic lights proposed by RDC.

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

objectives are flawed as several sites were put forward on previously used sites and have been rejected in favour of easily achievable green belt sites.Wish list for infrastructure is unsound as numbers of houses could not supply sufficient funds .It has been continously emphasised that this document is non site specific but specific sites are identified whilst others are sufficiently vague to create confusion.

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.

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This submission is made on behalf of the West Rochford Action Group and its members. Further details sent under separate cover: email and by hand.
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H1 Efficient use of land for housing.

Only 4 brownfield sites have been identified in this policy for redevelopment Star Lane Industrial estate, Stambridge Mills, Eldon Way Industrial Estates and Rawreth Lane Industrial estate, Rayleigh. However there are others which have not been included despite the statement that the Council will prioritise the use of previously developed land. The Brickfields site off Cherry Orchard Way is not mentioned and would provide an additional site and be more appropriate in land use terms. On the Rochford Town Centre Plan further sites are being considered namely the Rose and Crown Car Park and adjoining shops, Whittinghams garage. There are further sites which were previously being considered by the Council in 2007 which are not mentioned - these should all be assessed and utilised in preference to green belt sites.

PPG3 on housing requires Local authorities to promote more sustainable patterns of development and make better use of previously developed land the focus for additional housing should be existing towns and cities. PPG3 requires LAs to build in ways which exploit and deliver accessibility by public transport to jobs education and health facilities shopping and local services.

The Core Strategy does not provide for a proper annual monitoring and review of brownfield sites or a policy which states that as brownfield sites come forward the proposed green belt sites will be abandoned. There is no reason why such a policy should not be adopted.

See supporting document, Council ref AE28

The way in which sites may be allocated within the Allocations development plan document should be guided by an additional level within the sequential approach. The Core Strategy objectives in relation to Green Belt seek to continue to protect the openness and character of the Green Belt and to balance that with the minimum amount of release of such land to meet the District's housing and employment needs.

The sequential approach of Policy H1 should indicate that land to be allocated for development, as extensions to residential envelopes should prioritise previously developed land and other built sites that are now redundant.

The approach of prioritising the re-use of previously developed land is sound and supported. The redevelopment of vacant industrial land at Stambridge Mills and at the former Star Lane Brickworks site (part of Star Lane Industrial Estate) will reduce the need to release Green Belt land, and will allow for the removal of contamination, the re-use of existing on-site materials, and the environmental and ecological enhancement of the sites and their surroundings. In respect of Stambridge Mills, the need to satisfy the PPS25 exceptions test follows the successful completion of the sequential test.