Policy 3 - Promoting better movement

Insufficient "Consolidated parking" is proposed to cater for existing users; a supermarket 6 times current size; consolidated rail station parking.

The proposals are not viable and extending size would render rest of proposals unworkable. Providing a multi-story car would change village character.

No supermarket will invest without adequate car parking.

No detailed Highways proposals have been made despite repeated promises, the most recent of which was on 17 July 2012 at Full (RDC) Council. This is discriminatory.

Traffic Assessments (TAs) have been undertaken for the parallel Rochford & Rayleigh AAPs but not Hockley - why not? What is the council hiding?

Cllr Hudson said this was to save money but disproved by the RoAAP and RaAAP TAs.

Addtiional cycle parking proposed but nothing on cycle access. The narrow railway bridge is a serious obstacle to cycling in Hockley

Report proposes reduced parking levels (below standard). Developers are unlikely to invest in a supermarket with inadequate parking.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 Misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary.

1.2 Imposing a two-tier consultation process which discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
* restricting public consultation;
* pre-defining the outcome;
* limiting the time available
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. Traffic assessments have been made for Rochford and Rayleigh but not for Hockley.

1.3 Manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.4 Misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them (although they have undertaken Traffic Assessments for Rochford and Rayleigh).

1.5 Misleading residents by holding an exhibition in Jul/Aug 2012 which used 2010 proposals which had previously been consulted on and were "not current thinking".


2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
* A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which has not been provided.
* Proposed parking space insufficient even without proposal to move station carpark
* Supermarket developers will require adequate parking; without it proposal is not viable.

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)
* Plans for 3 slip-lanes at the Spa roundabout are not viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - why?
* Proposal to insert slip lane and widen pavement outside Spa not viable and RDC's own experts have expressed reservations
* Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
* Impact of moving station car park on highway under railway bridge not assessed
* Proposal to raise access to Woodpond Road likely to cause delays on main road and endanger pedestrians.
* A Traffic Assessment is also required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, despite the fact that 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 Misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary.

1.2 Imposing a two-tier consultation process which discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
* restricting public consultation;
* pre-defining the outcome;
* limiting the time available
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. Traffic assessments have been made for Rochford and Rayleigh but not for Hockley.

1.3 Manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.4 Misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them (although they have undertaken Traffic Assessments for Rochford and Rayleigh).

1.5 Misleading residents by holding an exhibition in Jul/Aug 2012 which used 2010 proposals which had previously been consulted on and were "not current thinking".


2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
* A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which has not been provided.
* Proposed parking space insufficient even without proposal to move station carpark
* Supermarket developers will require adequate parking; without it proposal is not viable.

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)
* Plans for 3 slip-lanes at the Spa roundabout are not viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - why?
* Proposal to insert slip lane and widen pavement outside Spa not viable and RDC's own experts have expressed reservations
* Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
* Impact of moving station car park on highway under railway bridge not assessed
* Proposal to raise access to Woodpond Road likely to cause delays on main road and endanger pedestrians.
* A Traffic Assessment is also required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, despite the fact that 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

DPD is not legal because - The HAAP consultations have misled residents by misrepresenting evidence regarding RLS and its potential and as to whether HAAP should conform with Core Strategy, and regarding Traffic Assessments not undertaken although the HAAP does not incorporate highway issues. Moreover the consultation process has discriminated against Hockley compared to Rochford and Rayleigh Area Action Plans by pre-defining the outcome and limiting time available. RDC failed to analyse outcomes of consultations before determining next steps in the process.

DPD is not Sound because adequate parking (Chapter 3, Policy 3) is not provided. Also regarding highway issues 3 sliplanes at the Spa roundabout are not viable, nor is it viable to insert a sliplane and widen the pavement outside the Spa. A Traffic Assessment is required in view of the 3500 Core Strategy new houses planned in the district. Furthermore a new huge supermarket is out of proportion to Hockley and could ruin small businesses.

Improvements to Spa Road mini-roundabout junction
A more detailed investigation needs to be carried out on the flow of traffic along Main Road and Southend Road to and from Rayleigh/Rochford before propsals for widening the Spa junction and the wider development of the area are considered. The possibility of an alternative or relief route needs to be explored to ease the volume of traffic at peak times and ease congestion. The fact that this route is the only alternative for traffic to and from either town is problematic, especially as any minor traffic incident renders the whole route impassable.

The sooner we have a thorough Traffic Assesesment the better. The development of Hockley might need more parking and traffic lanes than currently suggested; so the proposals may not be sound.

There is insufficient parking for both shops and, particularly, the station where existing parking is more than halved!

The Viability Assessment shows a plan of 211 supermarket parking places and 72 for station users. A manual count of the existing car parking has shown that there are approximately:
- Existing Coop car-park: 31 standard spaces+1 permit holder+1 disabled+1 child+1 delivery van = total 35 (+ existing back-street ad hoc parking, say 15), = total 50
- Railway main car-park NE of railway line : 144 slots + 3 disabled = 147 plus small car-park SW of railway line: (4 short term+2 taxis+3 disabled+3 staff = total 12) = overall 159

A new 3,000 sq m supermarket will be about 5.5 times as large as existing, which suggests a pro-rata need for around 275 car parking spaces for shopping, meaning the new proposals are very tight. Railway parking, however, shows a huge reduction of 87 spaces - over half! - and at a time when hundreds of new houses are being built in the area, creating more demand in a commuter town. This will have a 'knock-on' effect in Rochford and Rayleigh as well as pushing parking in to surrounding housing estates.

This is a poor plan, with very limited vision, which does very little to take Hockley forward. The key issue of Highways has not been addressed and the proposed changes will make it harder to improve traffic issues in the future.

Despite numerous repeated commitments (the latest being at Full Council on the 17 July 2012) to include highways issues in the HAAP, the council now states that it has not undertaken a transport assessment, in order to save money, and that it will be undertaken by any developer at a later stage, This has a number of implications.

Highways issues have been been considered critical and highlighted at every stage of the HAAP. There are two key considerations, one at each end of the high street::
1) the existing need to deal with the bottleneck at the Spa mini-roundabout, which will no doubt be exaggerated in the future by extra traffic volume from the increased number of shoppers, as well as from the hundreds of new houses to be built in the surrounding area.
2) the potential new problem created by the council's recent decision to move the station carpark to the Eldon Way site, thus reversing existing flows through the narrow railway bridge, which often requires one-way traffic flows when a bus, or large vehicle, is trying to pass through the bridge.

Plans to more than halve the size of the station car park may well also exacerbate both problems.

Thus failure to determine the way forward may well have a significant impact on the viability of the whole AAP. If potential developer(s) are unwilling to meet the resultant financial costs, the whole HAAP will 'stall' and regeneration will be impacted. Or, possibly, options such as moving the station car park may need to be discarded, restricting the scope of any changes.

Even if the HAAP goes forward as currently proposed, the most that is achievable within the current layout/space is a 'fudge' on highways - minor improvements at best, which do not really resolve the underlying issues, which will become even more intractable. The current proposals simply will not move Hockley forward and a more holistic approach is required.

Deferring the transport assessments also effectively suggests that the whole redevelopment will need to be undertaken as a single project. Otherwise different companies could come up with different, contradictory or partial highways proposals. Based on the financials in the Council's viability assessment, a single project would be an extremely large undertaking which would increase the risks to the council's ability to manage the developer effectively.

We also note that RDC do not seem to have addressed the outstanding highways issues from the Core Strategy and there is no district Transport Assessment, in to which the Hockley context can be fitted.

Highway issues are integral to the overall success of the project and as such need to be addressed at this stage

The council have performed a last minute U-turn and excluded highways' considerations from the HAAP. No assessment of road improvements required has been made for either (i) the Core Strategy or (ii) the HAAP.

(i) There is no mention of any highway improvements as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. An Integrated Transport Assessment should be made for the Core Strategy as a whole and incorporated into this document detailing the improvements to all roads in the District
required by the development of these sites. On 21 December 2012, Alastair Southgate Transportation Strategy Manager wrote in an email to Cllr John Mason "On a local level every strategic development proposal is accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth." Any improvements required should be completed before the development or at least as the first units are occupied. Where Essex County Council would be responsible for any upgrades improvements should take place prior to the commencement of any development.

(ii) Improvements to the Spa road/main Road roundabout have always been an integal part of the HAAP. The Core Strategy Policy T2 - Highways Improvements - states
"The Council will work with Essex County Council Highways Authority to ensure that highway improvements are implemented to address issues of congestion, road flooding and poor signage. In particular, highway improvements to the following will be prioritised:
* ....................
* Spa Road/Main Road Roundabout Hockley"

That commitment has been repeated at regular intervals. The latest was at Full Council on 17 July 2012, when Cllr Hudson stated "that part of the remit of the Area Action Plan was to consider roads and junctions throughout Hockley ".

Despite these numerous repeated commitments to include highways issues in the HAAP, at the last minute the council now states that it has not undertaken a transport assessment, in order to save money, and that it will be undertaken by any developer at a later stage, The only Transport Impact Assessment required will therefore be developer funded and relate only to te HAAP, without taking into account either highway issues or other developments in the district. .

Especially given the long delay in undertaking the Core Strategy Transport Assessment, appropriate, integrated Transport Assessments at district and local levels should be an integral part of the HAAP, or the opportunity will be permanently lost.

The council has ignored concerns raised during the consultation concerning increased traffic and congestions. It has failed to undertake any traffic analysis of current volumes and therefore has no baseline against which to measure any transport assessments. Although the document talks about 'working with our partners' which presumably includes Essex County Council, there is no evidence that ECC is aware of or has any plans to address traffic congestion in Hockley or in the surrounding area. If the council's assertions about the new supermarket attracting customers back from current out of town centres then clearly there will be increased congestion both in Hockley and along the various routes into the village. These can only be resolved if ECC is committed to undertaking changes.

THERE IS A NEED TO ASSESS TRAFIIC LEVELS SO THAT THE INFRASTRUCTRE WILLBEABLE TO COPE. AT PRESENT THE ROADS STRUGGLE TO COPE WITH CURRENT LEVELS OF TRAFFIC ANY INCREASE WILL ONLY MAKE THE SITUATION WORSE.

Improvements to Spa Junction are welcome but does any planning officer really believe extra lanes at the Spa junction will cope. If they do then they should find another job. Housing developments already commenced between Hockley and Rochford now total over 800 dwellings. During contsruction and when completed these homes will massively increase traffic flow through Spa Junction. This excludes any increased housing development in Hockley which is included in this plan.

Consolidation of car parking will add to the congestion for traffic and reduce the ease of movement for pedestrians.

DETAILS: HIGHWAYS ISSUES

CHAPTER 1: Working with our partners
In 2011 Core Strategy document at T2 - Highways Improvements - re Retail & Town Centres - RTC 4, 5, 6 - it is noted for Rochford and Rayleigh Traffic Accessibility Reports will be made (which has been done), but such matters for Hockley would be in HAAP.

However, at para. 1.3 above, Rochford council claims to have liased with ECC Highways officers to identify proposed developments with significant highways impact, but there is no reference to a Traffic Assessment being done by Essex County Council under the HAAP procedure. This is both unsound and not legally compliant with documents.

CHAPTER 4, POLICY 3: Promoting better movement

This says planning applications for new development should be supported by a Transport Assessment, inferring developers, not ECC or RDC in conjunction with ECC, should deal with serious highways problems occasioned by a very impacting HAAP.

This policy is unsound, not positively prepared, justified or effective. It doesn't take into account inadequacy of the road system to cope with 100 new houses proposed, a c.3000 sq.m. supermarket and 3500 proposed dwellings across the district. Hockley has B1013, busiest B road in UK. This item should not be left to a developer, but to responsibility of ECC Highways on Rochford council's behalf to provide a Transport Assessment to accompany a HAAP.

CHAPTER 5: Working in partnership; Working with ECC

Council says it will continue to engage with the community in respect of future planning applications and they will be able to have further input in developments. As it has been demonstrated that they have not had much to date, this is doubtful and therefore unsound as indicated above.

DPD says ECC will review/approve Transport Assessments in any planning proposals and must be satisfied impacts are mitigated. Rochford council will cooperate with ECC through Local Highways Panel, which decides where monies for highways should be spent. However, this leaves such assessments to developers and a question mark over any public finance contribution. This is unsound and also not legally compliant, as Core Strategy 2011 infers HAAP would deal properly with Transport Assessments, which it does not do.

DETAILS PARKING

It has not been demonstrated at eg Figure 13 how parking to serve: supermarket c.3000 sq.m., 100 houses, leisure, offices, parking at railway, public using Spa Road shopping centre can be effectively
provided, as set out in Chapter 4, Policy 3 (f). This is not sound, as above.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! It recommends a small, "boutique" approach. There is no evidence to support requirement for a supermarket and HAAP ignores the fact that 2 supermarkets have opened since R&LS published.

RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary (9 Sept 2009 and 14 Oct 2010).

1.2 imposing a two-tier consultation process with discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
* restricting public consultation - only a hastily arranged exhibition using 2010 material, acknowledged by the council as "not current thinking", which had previously been consulted on. Exhibition not advertised ungtil halfway through/
* pre-defining the outcome: as noted above, the council incorrectly set requirements based on the Core Strategy
* limiting the time available: the two other AAPs have more time and more consultation.
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. FoI response showing Traffic Assessments have been made for Rochford and Rayleigh but not for Hockley (later denied by the council).

1.3 manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.4 misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them .

2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
* A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which as not been provided. (211 v pro-rata requirement for 275). Supermarket developers will require adequate parking; without it proposal is not viable.
* Station carpark reduced from 159 to 72 (a 55% reduction). No reason or evidence to support this

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)
* No Transport Assessment undertaken for Core Strategy. A Traffic Assessment is required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.
* No Transport Assessment undertaken for Hockley. FoI response showing Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - later denied by RDC.
* Plans for 3 slip-lanes at the Spa roundabout may not be viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Proposal to insert slip lane and widen pavement outside Spa but no evidence viable and RDC's own experts have expressed reservations. In responses to Freedom of Information requests, the council says it has "no transport paper" to support their proposals.
* Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
* Impact of moving station car park on highway under railway bridge not assessed. Traffic flows at peak commuter hours will be reversed. Impact unknown.
* Proposal to raise access to Woodlands Road likely to cause delays on main road and endanger pedestrians.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, there is no evidence to support this; are contrary to the Retail & Leisure Study; and 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

2.4 Financial Viability (Chapter 5.2)
HAAP states financial analysis is marginal but that land assembly costs are included. The Viability Assessment states land assembly costs not included. No evidence plan is financially viable.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! It recommends a small, "boutique" approach. There is no evidence to support requirement for a supermarket and HAAP ignores the fact that 2 supermarkets have opened since R&LS published.

RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary (9 Sept 2009 and 14 Oct 2010).

1.2 imposing a two-tier consultation process with discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
* restricting public consultation - only a hastily arranged exhibition using 2010 material, acknowledged by the council as "not current thinking", which had previously been consulted on. Exhibition not advertised ungtil halfway through/
* pre-defining the outcome: as noted above, the council incorrectly set requirements based on the Core Strategy
* limiting the time available: the two other AAPs have more time and more consultation.
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. FoI response showing Traffic Assessments have been made for Rochford and Rayleigh but not for Hockley (later denied by the council).

1.3 manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.4 misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them .

2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
* A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which as not been provided. (211 v pro-rata requirement for 275). Supermarket developers will require adequate parking; without it proposal is not viable.
* Station carpark reduced from 159 to 72 (a 55% reduction). No reason or evidence to support this

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)
* No Transport Assessment undertaken for Core Strategy. A Traffic Assessment is required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.
* No Transport Assessment undertaken for Hockley. FoI response showing Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - later denied by RDC.
* Plans for 3 slip-lanes at the Spa roundabout may not be viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Proposal to insert slip lane and widen pavement outside Spa but no evidence viable and RDC's own experts have expressed reservations. In responses to Freedom of Information requests, the council says it has "no transport paper" to support their proposals.
* Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
* Impact of moving station car park on highway under railway bridge not assessed. Traffic flows at peak commuter hours will be reversed. Impact unknown.
* Proposal to raise access to Woodlands Road likely to cause delays on main road and endanger pedestrians.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, there is no evidence to support this; are contrary to the Retail & Leisure Study; and 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

2.4 Financial Viability (Chapter 5.2)
HAAP states financial analysis is marginal but that land assembly costs are included. The Viability Assessment states land assembly costs not included. No evidence plan is financially viable.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! It recommends a small, "boutique" approach. There is no evidence to support requirement for a supermarket and HAAP ignores the fact that 2 supermarkets have opened since R&LS published.

RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary (9 Sept 2009 and 14 Oct 2010).

1.2 imposing a two-tier consultation process with discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
* restricting public consultation - only a hastily arranged exhibition using 2010 material, acknowledged by the council as "not current thinking", which had previously been consulted on. Exhibition not advertised ungtil halfway through/
* pre-defining the outcome: as noted above, the council incorrectly set requirements based on the Core Strategy
* limiting the time available: the two other AAPs have more time and more consultation.
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. FoI response showing Traffic Assessments have been made for Rochford and Rayleigh but not for Hockley (later denied by the council).

1.3 manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.4 misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them .

2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
* A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which as not been provided. (211 v pro-rata requirement for 275). Supermarket developers will require adequate parking; without it proposal is not viable.
* Station carpark reduced from 159 to 72 (a 55% reduction). No reason or evidence to support this

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)
* No Transport Assessment undertaken for Core Strategy. A Traffic Assessment is required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.
* No Transport Assessment undertaken for Hockley. FoI response showing Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - later denied by RDC.
* Plans for 3 slip-lanes at the Spa roundabout may not be viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Proposal to insert slip lane and widen pavement outside Spa but no evidence viable and RDC's own experts have expressed reservations. In responses to Freedom of Information requests, the council says it has "no transport paper" to support their proposals.
* Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
* Impact of moving station car park on highway under railway bridge not assessed. Traffic flows at peak commuter hours will be reversed. Impact unknown.
* Proposal to raise access to Woodlands Road likely to cause delays on main road and endanger pedestrians.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, there is no evidence to support this; are contrary to the Retail & Leisure Study; and 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

2.4 Financial Viability (Chapter 5.2)
HAAP states financial analysis is marginal but that land assembly costs are included. The Viability Assessment states land assembly costs not included. No evidence plan is financially viable.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! It recommends a small, "boutique" approach. There is no evidence to support requirement for a supermarket and HAAP ignores the fact that 2 supermarkets have opened since R&LS published.

RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary (9 Sept 2009 and 14 Oct 2010).

1.2 imposing a two-tier consultation process with discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
* restricting public consultation - only a hastily arranged exhibition using 2010 material, acknowledged by the council as "not current thinking", which had previously been consulted on. Exhibition not advertised ungtil halfway through/
* pre-defining the outcome: as noted above, the council incorrectly set requirements based on the Core Strategy
* limiting the time available: the two other AAPs have more time and more consultation.
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. FoI response showing Traffic Assessments have been made for Rochford and Rayleigh but not for Hockley (later denied by the council).

1.3 manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.4 misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them .

2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
* A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which as not been provided. (211 v pro-rata requirement for 275). Supermarket developers will require adequate parking; without it proposal is not viable.
* Station carpark reduced from 159 to 72 (a 55% reduction). No reason or evidence to support this

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)
* No Transport Assessment undertaken for Core Strategy. A Traffic Assessment is required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.
* No Transport Assessment undertaken for Hockley. FoI response showing Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - later denied by RDC.
* Plans for 3 slip-lanes at the Spa roundabout may not be viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Proposal to insert slip lane and widen pavement outside Spa but no evidence viable and RDC's own experts have expressed reservations. In responses to Freedom of Information requests, the council says it has "no transport paper" to support their proposals.
* Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
* Impact of moving station car park on highway under railway bridge not assessed. Traffic flows at peak commuter hours will be reversed. Impact unknown.
* Proposal to raise access to Woodlands Road likely to cause delays on main road and endanger pedestrians.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, there is no evidence to support this; are contrary to the Retail & Leisure Study; and 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

2.4 Financial Viability (Chapter 5.2)
HAAP states financial analysis is marginal but that land assembly costs are included. The Viability Assessment states land assembly costs not included. No evidence plan is financially viable.

1) Process Failures by RDC resulting in a failure to consult properly i.e. NOT "legal"

RDC has consistently manipulated the HAAP consultations, misleading residents and denying their democratic rights, with the sole aim of implementing the council's own predetermined policies. Failings include:

1.1 misrepresenting evidence (including that of its own experts, thus distorting and undermining the whole economic rational for redevelopment) and contradicted itself. RDC have stated that "The Retail and Leisure Study (RLS) indicates that Hockley has great potential." The RLS actually says that Hockley has limited potential! It recommends a small, "boutique" approach. There is no evidence to support requirement for a supermarket and HAAP ignores the fact that 2 supermarkets have opened since R&LS published.

RDC has also stated that the HAAP must conform with the Core Strategy despite passing two specific motions in Full Council to the contrary (9 Sept 2009 and 14 Oct 2010).

1.2 imposing a two-tier consultation process with discriminates against Hockley. The council "accelerated" the HAAP and imposed a two-tier consultation system which discriminates against Hockley by:
* restricting public consultation - only a hastily arranged exhibition using 2010 material, acknowledged by the council as "not current thinking", which had previously been consulted on. Exhibition not advertised ungtil halfway through/
* pre-defining the outcome: as noted above, the council incorrectly set requirements based on the Core Strategy
* limiting the time available: the two other AAPs have more time and more consultation.
compared with similar, Area Action Plan studies for Rochford and Rayleigh, which were included in the same contract. The parallel action plans for Rayleigh and Rochford have been allowed more time and more consultation opportunity, despite the potential impact on those areas being much smaller. FoI response showing Traffic Assessments have been made for Rochford and Rayleigh but not for Hockley (later denied by the council).

1.3 manipulating and ignoring public consultations (contravening RDC's own Statement of Community Involvement). RDC have demonstrably determined the next step of the way forward before analysing the outcomes of earlier consultations, thereby rendering those consultations meaningless.

1.4 misleading residents by repeatedly stating highways issues would be included in the HAAP but, in fact, not including them .

2, Failures in the HAAP proposals resulting in it not being "sound"

The plans as presented in the HAAP are simply not viable

2.1. Parking (Chapter 3; Policy 3 )
* A new supermarket nearly 6 times the size of the current Co-Op will require adequate and appropriate additional parking, which as not been provided. (211 v pro-rata requirement for 275). Supermarket developers will require adequate parking; without it proposal is not viable.
* Station carpark reduced from 159 to 72 (a 55% reduction). No reason or evidence to support this

2.2 No effective proposals to deal with highways issues. (Chapter 3, Policy 3)
* No Transport Assessment undertaken for Core Strategy. A Traffic Assessment is required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.
* No Transport Assessment undertaken for Hockley. FoI response showing Transport Assessments undertaken in Rochford & Rayleigh but not Hockley - later denied by RDC.
* Plans for 3 slip-lanes at the Spa roundabout may not be viable (due to the narrow pavement outside the Spa) and have not been researched, despite previous promises. Proposal to insert slip lane and widen pavement outside Spa but no evidence viable and RDC's own experts have expressed reservations. In responses to Freedom of Information requests, the council says it has "no transport paper" to support their proposals.
* Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
* Impact of moving station car park on highway under railway bridge not assessed. Traffic flows at peak commuter hours will be reversed. Impact unknown.
* Proposal to raise access to Woodlands Road likely to cause delays on main road and endanger pedestrians.

2.3 Retail (Chapter 3, Policy 6)
The proposals are largely focussed on developing a new supermarket, there is no evidence to support this; are contrary to the Retail & Leisure Study; and 2 new supermarkets have opened since the HAAP process started. No mention is made of these. The size of the new supermarket is out of proportion; may overwhelm existing retailers, reduce competition, and is unlikely to take Hockley forward.

2.4 Financial Viability (Chapter 5.2)
HAAP states financial analysis is marginal but that land assembly costs are included. The Viability Assessment states land assembly costs not included. No evidence plan is financially viable.

I do not believe that a developer would do any of this work unless it could make a massive redevelopment of the area including a major supermarket and mass house building, which Hockley does not want or need. This would mean redevelopment of Eldon Way, which contradicts the previous statements of retaining Eldon Way as a trading centre. There are no estimated costings, which I believe would cost many millions of pounds. Some of these proposals would be on railway property, which are notoriously difficult to deal with. I therefore believe this proposal to be unsound.

Parking :- Given the predicted increase in rail passengers numbers over the next 10 years then reducing the Station car parking places does not makes much sense. This would imply that reasonable consideration has not been being given to the requirement to satisfy objectively assessed development and infrastructure requirements but has been clouded by the financial offerings of a large supermarket wanting parking spaces near to it proposed supermarket and then because of the need to build houses somewhere commuters will lose out.

Improvements to Spa Road mini-roundabout junction :- A thorough detailed investigation needs to be carried out on the flow of traffic along Main Road and Southend Road to and from Rayleigh/Rochford before proposals for widening the Spa junction and the wider development of the area are considered. Given that a bypass was consider 30 years ago and traffic volumes have multiplied considerably since, then just messing about with Spa junction is not really going to solve the problem. Any minor traffic incident or even the councils' own refuge vehicles currently cause havoc on a regular basis. Therefore this aspect of the proposal does not constitute an appropriate strategy so therefore cannot be justified; it cannot possibly meet any Infrastructure requirements and certainly will not be effective

No consideration given to enhancement of pedestrian links leading to problems - note anecdotal evidence of burglars commuting to Hockley.
The simplist approach suggested would have no bearing on train usage.
Cyclists are actually one of the major causes of congestion along the B1013 and, ironically where the road is actually wide enough for them, a nuisance in the town centre riding on the pavement
Bus improvements suggested are inadequate unless a return is made to a service every 15 minutes and the price comes down (it's cheaper for a family to get a taxi to Rayleigh) it won't be used
Spa Road mini roundabout

We have asked 3 Freedom of Information requests asking for:
1) copies of any correspondence re HAAP highways issues. The council says there are none!
2) evidence that Spa Roundabout can be enhanced with 3 slip lanes, contrary to their experts view that space is limited
3) confirmation that no Traffic/Transport Assessments have been ordered, contrary to evidence provided earlier.
The Council has not answered these specific questions and the 3 requests are been submitted for formal review, taking responses outside this consultation period.
The Council's whole approach to Highways is inconsistent, obscure and incomplete.

Despite all that has been said Hockley is a nice small town / village with very small roads leading in and through the area. The area has regular traffic queues during rushhour times in particular but they can happen anytime something unexpected occurs, ( like the Sainburys lorry unloading produce ).
I have great concerns that Hockley will become one huge traffic jam almost constantly, I also have clear concerns that the same people who gave the go ahead for Sainsburys to open a store where there is NO PARKING AT ALL should be involved in this huge proposal for the area. Clearly they are out of touch with local people's thoughts and concerns.

The Council is concerned that a traffic impact study has not been undertaken prior to publication of the submission document. This would have provided evidence that the proposed juction improvement at the Spa roundabout would be viable and take into consideration proposed redevelopment of the industrial estate, including construction of a large supermarket, shops, offices and housing; also, other developments in the area ie. Hawkwell, West Rochford, Ashingdon and the Airport expansion.

Insufficent detailed consultation/investigation as to the restricted traffic flow into the area caused by the Rail Bridge and Traffic Lights at the junction of Greensward Lane and Plumberow Avenue. Additional traffic numbers caused by a larger retail outlet and yet more housing in a confined area.
This cannot be mitigated by any possible increase in alternative forms of public transport as a rural district we have none and can expect no improvement. for an example, use the new proposed development I would either have to walk, 20 mins to village or as now take my car.