11.32

Showing comments and forms 1 to 14 of 14

Object

Core Strategy Submission Document

Representation ID: 15841

Representation ID: 16259

Received: 14/10/2009

Respondent: Colonnade Land LLP

Agent: Iceni Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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

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

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

Full text:

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

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

a) Overview

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

b) Background and Summary

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

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

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

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

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

b) Colonnade

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

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

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

c) Housing

i. Date of Adoption

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

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

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

ii. Housing Delivery

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

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

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

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

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

iii. Redevelopment of Employment Sites

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

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

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

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

The UCS also states in the same section that:

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

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

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

iv. Strategic Housing Growth to the East of Rochford

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

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

v. Housing Trajectory

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

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

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

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

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

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

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

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

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

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

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

TOTAL

Predicted Delivery (A)
1,562 dwellings

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

Residual delivery (A-B)
437 dwellings

Delivery Shortfall
1,125 dwellings

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

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

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

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

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

vi. Appendix H1

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

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

d) Character of Place

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

e) Green Belt

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

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

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

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

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

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

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

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

f) Environmental Issues

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

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

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

g) Community Infrastructure, Leisure and Tourism

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

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

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

h) Transport

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

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

i) Economic Development

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

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

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

j) Conclusions

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

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

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

Object

Core Strategy Submission Document

Representation ID: 16754

Received: 02/11/2009

Respondent: Hockley Under Threat

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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.

Full text:

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?