Policy T1 - Highways

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".

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.

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.

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".

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".

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".

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?

Thank you for inviting the Highways Agency (HA) to comment on the Rochford Core Strategy (CS) Submission Document and Rochford Area Action plan (AAP) prepared by Rochford District Council

As you are aware the HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England's motorway and all-purpose trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport.

In spatial planning and development control terms, we have a duty to safeguard the operation of the motorway and trunk road network as set out in the Department for Transport Circular: 02/2007: Planning and the Strategic Road Network. http://www.dft.gov.uk/pgr/regional/strategy/policy/circular207planningandstrategic. The circular encourages the HA to work co-operatively with Local Planning Authorities within the framework of the Government's policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council's Local Development Framework to promote strategies, policies and land allocations which would support alternatives to the private car.

In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the HA that the impact of major development proposals in the Rochford area is considered within the context of future impact on the M25 and the A13 Trunk Road.

Please see below some general comments regarding the soundness of the CS and SSA from a transport perspective, referring to specific proposed submission policies as necessary. This response has been completed with reference to paragraph 4.52 of PPS12 (2008) PPS12, paragraph 4.52 - To be 'sound' a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY.

CORE STRATEGY

Policy GB1 - Green Belt Protection

The HA acknowledges that only the minimum amount of Green Belt land will be allocated to meet the District's housing and employment needs as necessary. However, the HA is concerned that any proposed redevelopment of greenbelt sites could result in development in areas with limited access to sustainable transport modes therefore resulting in higher levels of car usage and subsequent impact on the SRN. Although the HA recognizes that new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment.

It is therefore important that an appropriate assessment of infrastructure requirements is performed for development sites on Green Belt land. Funding towards the necessary public transport infrastructure improvements must be sought and secured prior to occupation of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure. This will help the CS meet the PPS12 requirement that a sound DPD should be 'justified' and 'effective' and hence deliverable.

Policy T1 - Highways

Policy T1 highlights the need to reduce reliance on the private car but also observes that 'some impact on the highway network is inevitable'. In a District with such high levels of private car ownership and a limited public transport network, as stated in paragraph 10.2, it will be important to assess the potential impacts to the highway network and ensure that mitigation measures are proposed and implemented where necessary.

An emphasis should be placed on the provision and improvement of sustainable transport infrastructure, particularly where high trip-generating developments such as offices are proposed. In line with the DfT's Guidance on Transport Assessment (2007) - DfT GTA, paragraph 4.51 - 'The key issue is the need to ensure that development proposals strive to achieve nil detriment ('no worse off') to the strategic network, for the opening year and appropriate horizon year'. This emphasis will assist in mitigating potential increases in private vehicle trips and hence help ensure that there is a nil-detriment effect on the SRN.

Policy T3 - Public Transport

The recent Planning Inspectorate 'LDF - Learning from Experience' document (September 2009) suggests that a Core Strategy should identify a clear source of funding for infrastructure for at least the first 5 years of the plan - The Planning Inspectorate, LDF: Examining DPDs: Learning from experience, September 2009, Paragraph 22 - 'For at least the first 5 years of the plan it should be clear what infrastructure is required, who is going to fund and provide it and how it is to relate to the rate of development'.. Paragraph 10.15 of the CS highlights the importance of public transport links for new developments and implies that developers may be required to contribute towards public transport provision. However, it is noted that developer contributions cannot be expected to pay for all transport improvements and as such, in line with the recent Planning Inspectorate document outlined above additional sources of funding should be identified. It is recommended that alternative sources of funding for public transport improvements are clearly outlined within the CS to ensure that adequate infrastructure provision is made.

Policy T4 - South Essex Rapid Transit

As mentioned in our response to the Core Strategy Issues and options consultation the HA is supportive of this policy and the need to progress the route through South Essex. This has the potential to reduce the impact on the SRN (A13).

Policy T5 - Travel Plans

The HA welcomes the requirement for a travel plan for developments involving both destination and origin trips. However it is noted that no threshold for employment sites have been specified. Essex County Council requires the production of a workplace travel plan for developments with over 50 employees or where there will be a significant impact on the local road network. To avoid ambiguity for developers, the HA recommends that the Rochford District Core Strategy specifies a similar threshold within Policy T5. This will ensure the Core Strategy is in line with PPG13 paragraph 87 - PPG13 - 'Local authorities are expected to consider setting local targets for the adoption of travel plans by local businesses and other organizations..'

Policy ED2 - London Southend Airport

The HA previously responded to the London Southend and Environs Joint Area Action Plan Preferred Options Document (March 2009). As such, we have not repeated our comments here but instead refer you to our consultation response dated 31 March 2009.

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?

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?

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?

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?

1.0 Instruction and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Submission (September 2009) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations in the Submission document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the LDF preparation process and we look forward to the opportunity to comment further at the Examination to the Core Strategy.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

2.0 Housing:
Policy H1 - The Efficient Use of Land for Housing

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements on greenfield sites, particularly in the most sustainable locations. As such, Swan Hill supports that where feasible, the redevelopment of existing employment sites for residential/employment purposes can make a contribution towards the strategic housing requirement, provided that sufficient additional employment land is brought forward to ensure the stability of employment levels in the District, and to ensure employment growth meets the East of England Plan requirements.

2.3 Swan Hill considers that Policy H1 should include consideration that new extensions to existing settlements have regard to their potential impact on the wider characteristics and openness objectives of the Green Belt.

Policy H2 - Extensions to Residential Envelopes and Phasing

2.4 Swan Hill generally supports the approach taken by the Council in this policy. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advice in PPS3.

2.5 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that the potential supply of alternative previously developed sites is limited, without detrimentally affecting the character of the District, and therefore the best way forward is the use of sustainable greenfield urban extensions to the existing settlements of the District.

2.6 However, Swan Hill consider that a fundamental consideration that the District Council should consider relates to the potential impact of the urban extensions on the Green Belt policy has been somewhat overlooked. The wider sustainability credentials of the settlements of the District should only be one of many key considerations for determining the level of expansion. In view of the proximity of Southend-on-Sea to all the main settlements of the District, and the influence this has on the likely location many people would travel for employment and leisure, sustainability of many of the settlements is not a key overarching factor, and greater weight should be placed on the potential impact on the openness of the Green Belt, as this cannot be remedied if development occurs in the wrong location.

2.7 As such, Swan Hill considers that determining the location of growth for the main settlements should be to identify those locations where the impact on the wider setting of the Green Belt can be minimised. Further justification for those general locations chosen should be identified in Policy H2. In this regard, Swan Hill has serious concerns regarding the removal of Land South West of Great Wakering as a viable option for the growth of the settlement. The development of this area of Great Wakering, in addition to the potential redevelopment of the Star Lane Industrial Estate could provide a more comprehensive development, whilst ensuring that the wider openness of the Green Belt is maintained. Land South West of Great Wakering is significantly better placed to limit the impact on the wider Green Belt than Land West of Great Wakering, and could contribute to the provision of an important amenity and wildlife site for the local community.

2.8 In addition, Swan Hill consider that the Council now has no reserve provision in the event that any of the existing employment sites set out in Policy H1 fail to come forward for development within the envisaged timescale. Further, Land West of Great Wakering has not been identified in the SHLAA as a deliverable site to help meet the strategic housing requirement, contrary to the requirement set out in PPS3.

2.9 As such, Swan Hill would support the provision of suitable sites which could be safeguarded for future development in the likelihood of a shortfall in supply.

Policy H3 - Extensions to Residential Envelopes Post 2021

2.10 As set out above, Swan Hill supports the overall approach the Council has taken towards the provision of sustainable urban extensions as a suitable means of meeting their strategic housing requirement. However, as set out for Policy H2 above, Swan Hill has serious concerns regarding the removal of several proposed sites set out in the October 2008 Preferred Options Core Strategy, without any guarantee of the ability to deliver those sites set out in Policy H1.

2.11 As also considered above, the inclusion of West of Great Wakering for 250 dwellings should not be included ahead of South West of Great Wakering, in view of the fact that the site is not identified in the SHLAA as available, suitable and achievable as required by PPS3, and thus is not supported by a robust and creditable evidence base for its inclusion as a strategic site for development.

2.12 Whilst Swan Hill acknowledge that alterations to Policy H1 has resulted in the removal of some locations for growth in Policy H3 (as set out in the Sustainability Appraisal), Swan Hill does not consider that the most appropriate locations have been chosen.

2.13 In addition to the matters raised above, the use of West of Great Wakering would also result in the loss of valuable agricultural land, which clearly in a Green Belt location, should be less suitable for development than other sites, such as South West of Great Wakering, which would have limited impact on the wider Green Belt policy, and not result in the loss of valuable agricultural land.

2.14 Finally, in respect of Policies H1, H2 and H3, all of the above comments are based on our interpretation of the Submission Version Core Strategy when compared to the October 2008 Version of the Core Strategy. Without the ability to undertake a detailed assessment of the Council's SHLAA, it is not possible to clarify the proposed Core Strategy position regarding the proposed direction of growth proposed for the settlements in the District. As such, Swan Hill reserves the right to make additional representations regarding the proposed Policies H1, H2 and H3 following the publication of the SHLAA in due course.

Policy H4 - Affordable Housing

2.15 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy H5 - Dwelling Types

2.16 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's policy where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers that seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a percentage of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 Character of Place:
Policy CP1 - Design

3.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

3.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

4.0 The Green Belt:
Policy GB1 - Green Belt Protection

4.1 Following the amendments to the wording of the Policy since the October 2008 Preferred Options Core Strategy, Swan Hill is now generally supportive of Policy GB1 and its supporting text. However, as expressed above, it is important that where alterations to the Green Belt boundary occur as a result of the extension of the settlements to meet the strategic housing requirement, both the minimal amount of land is taken and where that land is taken for development, it represents the best available land which has a minimal impact of the wider openness characteristic of the Green Belt.

5.0 Environmental Issues:
Policy ENV3 - Flood Risk

5.1 Swan Hill generally supports the approach set out in Policy ENV3 regarding ensuring development accords with the sequential test of PPS25. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy ENV4 - Sustainable Drainage Systems (SUDS)

5.2 Following the revisions from the October 2008 Preferred Options Core Strategy, Swan Hill now generally supports the approach set out in Policy ENV4. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy ENV8 - On-site Renewable and Low Carbon Energy Generation

5.3 Whilst Swan Hill recognises the importance of reducing carbon emissions, particularly in new housing developments, and the role this can play in reducing the nations overall Greenhouse emissions. As such Swan Hill is generally supportive of Policy ENV8. It is noted that Policy ENG1 of the East of England Plan sets out sets out a threshold of developments comprising 10 or more dwellings. Swan Hill consider it important for the District Council to justify the reduction in the threshold level.

5.4 Further, no assessment of Policy ENV8 has been set out in the Sustainability Appraisal which justifies the change in threshold from that of Policy ENG1 of the RSS.

Policy ENV9 - Code for Sustainable Homes

5.5 Following the revisions from the October 2008 Preferred Options Core Strategy, Swan Hill now generally supports the approach set out in Policy ENV9. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

6.0 Community Infrastructure, Leisure and Tourism:
Policy CLT1 - Planning Obligations and Standard Charges

6.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

6.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

6.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

7.0 Transport:
Policy T1 - Highways

7.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

7.2 Swan Hill recognises the importance of providing sufficient infrastructure provision to meet the requirements of development, and that where developments have insufficient consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T3 - Public Transport

7.3 Swan Hill is generally supportive of the policy approach set out in T3, however, as set out in paragraph 7.2 above, it is important that the District Council do not consider that it is the developer's responsibility to resolve existing shortfalls in provision of public transport, and any contribution towards additional public transportation provision should only be to mitigate against the additional level of demand likely from the development proposed.

Policy T5 - Cycling and Walking

7.4 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. The policy provision acknowledges the need to ensure relevant contributions in the event of additional travel demands generated by individual developments, whilst also setting out additional aspirations for the cycle network in the District.


7.5 As such, Swan Hill considers this policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy T8 - Parking Standards

7.6 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill generally supports the policy approach chosen by the Council. As set out in the SPD, whilst Swan Hill generally supports the approach taken by the District Council towards setting residential parking standards, in that the Council has recognised that in the suburban areas, even with some access to public transport, the majority of residents will rely on the use of private cars. However, Swan Hill has concerns over the failure of the District Council to comply with the provisions of PPG13: Transport (2001) which sets out that Local Planning Authorities should not set minimum standards for car parking. Whilst it is acknowledged that PPS3 sets out provision for the consideration of local circumstances, it is considered that the Council has not justified this deviation from PPG13's maximum standard.

7.7 Whilst it is acknowledged that such justification may become apparent through the work currently being undertaken by Essex County Council, until such time, the District Council should only seek to apply the maximum standards indicated in PPG13. However, Swan Hill recommends that the District Council make provisions in the wording of the Policy to allow for changes in the event that future policy on car parking standards need to reflect the County standard, following the completion of the County Council review.

8.0 Economic Development:
Policies ED3 - Existing Employment Land
ED4 - Future Employment Allocations

8.1 In respect of Policies ED3 and ED4, Swan Hill notes that they have changed considerably since the October 2008 Preferred Options document, in that they are site specific regarding the location of the proposed redevelopment of existing employment sites. These four sites are also identified in Policy H1 - Efficient Use of Land, and in general, Swan Hill supports the approach to the redevelopment of these sites (where feasible) based on the assessments of the sites set out in this version of the Core Strategy.

8.2 However, Swan Hill has concerns that these policies might not be considered suitably sound given that insufficient opportunity has been allocated for consultation on their redevelopment. Without the SHLAA being publically available prior to the consultation on this Core Strategy, an insufficient evidence base has been provided to corroborate that these sites are neither suitable or deliverable to meet the test of soundness requirements.