Hockley Area Action Plan - Issues and Options

Paragraph 2.4.3


We strongly support the view that the Eldon Way Industrial Estate provides a customer base for existing town centre uses. Weekday spending within town centres is an important contributor to the viability of many retail and leisure businesses either through expenditure by employees during the lunchtime trade or expenditure by employers, on necessary goods and services. This relationship helps sustain the critical mass of a centre and provides a platform for new retail and leisure growth. We are of the view that it is not just desirable to retain these uses but essential in order to underpin the long term vitality and viability of the Town Centre. Alternative uses such as residential would not provide the most beneficial use and it is doubtful whether residential use value would be sufficient to make the redevelopment viable given the brownfield character of the area and potential need for mitigation. Any option should therefore focus on maintaining much of the employment floor space character of the area and regeneration should focus on the area closest to the Town Centre for retail, leisure and some office use only.

We strongly agree with the statement that the Eldon Way Industrial Estate is strategically well placed. In a sense this statement underplays the true importance of this highly sustainable employment location. The employment area is adjacent to the railway and located a short distance from the main bus routes which run along Spa Road. The residential areas of the town are also within walking distance, providing a potential for sustainable travel by employees. The Eldon Way Industrial Estate is therefore right at the heart of the Town and provides an opportunity to meet sustainable transport objectives by reducing the need to travel by car. Consequently, this employment area should be highlighted as a premier employment site in sustainability terms, both in the context of PPG13, PPG4 and PPS6. To encourage alternative uses may put at issue the soundness of the planning principles on which the Area Action Plan is based.

Whilst it is acknowledged that some improvement to the Eldon Way Industrial Estate can and should take place, the extent to which the mix of employment uses should be altered in favour of alternative land uses requires careful consideration as the soundness of the Area Action Plan may be investigated at a later date. It is our view that a mix of employment land uses should continue to dominate for the reasons noted above. In addition, the switching of employment uses to favour offices only, as noted in this paragraph of the AAP, is not considered to be appropriate or sustainable. A mix of employment types between offices, light industry and other high technology industries should be encouraged as this will provide many locational advantages to the firms that agglomerate together. It can help develop and improve trade, improve the sustainability of businesses as a whole and make for a more flexible labour market as skill levels are varied. A single employment use such as offices or a different use altogether would undermine the long term sustainability of the area and Town Centre.

Paragraph 2.4.1-2.4.2 and Section 2.9

It is agreed that the town centre has a poor retail offer and a need for larger and more variety in the retail stock. If some of the units along Spa Road and a small part of the Eldon Way Industrial Estate were to be redeveloped a mixed use approach including retail, leisure and some limited office development would need to be considered. The scale and quantum would need to relate to the town centre and settlement.

It is not considered that the whole of the Eldon Way Industrial Estate should be developed for alternative uses as summarised in Table 3 in the AAP for the reasons noted in our representations on paragraph 2.4.3 above and as set out below. In summary the harm to the area would outweigh any benefit.

The objectives are incomplete and as such there is a danger that the strategy that will be developed becomes flawed. The objectives provide no commentary on the important role of the employment uses of the Eldon Way Industrial Estate to the town centre and wider area. The vision statement includes a comment about the town centre being a place to 'live and work' yet the objectives do not. This needs to be reconsidered for reasons of soundness.

We agree that there needs to be improved retail facilities and a new focal point in the town centre.

Paragraph 3.2.3

This paragraph as currently drafted highlights a limited understanding of the role of the Eldon Way Industrial Estate plays in underpinning the town centre and providing work for nearby residents in a sustainable location. The reference to 'more valuable and appropriate uses' is not well defined and open to wide interpretation. If implemented it could undermine the vitality and viability of the town centre. Whilst noisy and potentially polluting industrial uses may not be appropriate in this location, a mix of offices, light industrial, high technology, and studio based employment would be an appropriate alternative. These uses would be valuable and appropriate and help maintain the role of the industrial estate as significant employment area within the Town Centre. It would maintain the settlements sustainability credentials and reduce the need to travel for work. The potential would remain for some land to be devoted to new retail development, a civic square and leisure uses to meet the objectives noted in 3.2.1 providing that a higher density of employment is achieved elsewhere on the site.

Reference is made under paragraph 3.3.4 to compulsory purchase powers and again at paragraph 3.10. The Issues and Options for the Area Action Plan do not currently provide any insight into how delivery will occur and over what time period. Most of the options that are proposed would indicate that some degree of compulsory purchase is envisaged. This being the case there has to be a section within the document that explains the process, how funding will be achieved and a delivery programme. Often it is necessary to achieve a planning permission prior to pursuing compulsory purchase powers and depending on the circumstances a regeneration scheme of this scale could require Environmental Impact Assessment. It may then be necessary to participate in an inquiry to review the compulsory purchase order and then find funding to purchase the site and begin. Much of the site is industrial and may require costly mitigation. This process and the nature of the problems could take several years and be very costly - possibly to the extent that it is not viable. The Area Action Plan therefore needs to fully review the processes and set out how delivery will be achieved. It may be necessary for the Council to explain how it will fund the regeneration, particularly any pump priming initiatives. It is our view that the complexity of this process will require that the proposals are phased toward the end of the Plan period and this needs to be reflected in the emerging Core Strategy.

Paragraph 3.3.2 to 3.3.6

For the purposes of this Issues and Options review, identifying the sites as A to H is a suitable way of identifying key land areas that could feature in one or more of the options under consideration. Sites A1, A2 and A3 would logically be suitable for primarily Town Centre uses including retail, leisure and the civic square. These sites are closest to the central town centre along a road identified as needing regeneration. Some office could be included at upper floor levels.

Sites B to G relates to the Eldon Way Industrial Estate and it is suggested in the Options and Issues document that more appropriate and valuable uses could replace the existing industrial uses. This section is drafted in such a way that the indication is that employment uses should be removed in favour of other uses such as residential. This is not considered to be an appropriate strategy for various sustainability and town centre viability reasons. The sites are in a highly sustainable location where the proximity of existing residential areas, bus routes and railway station contribute to sustainability objectives and the need to reduce the use of the private car, particularly for short trips such as commuting. The industrial area also helps sustain the town centre through the provision of a customer base and through business links. Irrespective of the employment land availability assessment of the wider district, the locational merits of the Eldon Way employment site would indicate to us that the majority of the site should continue to be maintained for employment type uses rather than wholesale redevelopment for residential and leisure purposes. Rather than removing employment uses altogether the objective should be to maintain an employment presence by encouraging a mix of appropriate employment uses such as offices, light industrial, high technology and studio based workshops.

3.4 Development Options


Whilst the 6 development options provide an insight into the various approaches that could be adopted, it is considered that the regeneration objectives for this area can be best achieved by varying option 1.2 . We set out below a twin strategy for this area (option 1.3).

Alternative to Option 1.2 (Option 1.3)

It is important that the redevelopment and regeneration of this area is based on sound planning principles that are deliverable and offer value for money. It should be noted that Hockley is not a large settlement and as such any strategy for regenerating the centre should be commensurate with the town as a whole including any likely growth anticipated in the Regional Spatial Strategy. In that context it is not considered necessary to promote an unduly large area for renewal, particularly where the net result is a potential loss of an important and strategically significant/sustainable employment site. We would suggest a twin approach - firstly focusing on a much smaller area for regeneration and secondly, introducing a positive policy framework for encouraging more appropriate employment development.

Option 1.2 is considered, subject to refinement, to be a strategy that could be made to deliver a sustainable approach to town centre regeneration.

Policy Strategy
The retention of the majority of the site for employment purposes is considered to be critical to the delivery of a sustainable town centre/settlement. This should be one of the principles of the Area Action Plan. A strong employment site would continue to underpin the vitality and viability of the town centre and help provide the opportunity for people to continue to live close to their workplace. The site is already a large employment area and the approach should be to encourage redevelopment of it for appropriate employment purposes so that it delivers a more acceptable employment mix. This can be achieved through a proactive planning policy framework that supports new office, workshop, and light industrial development. The AAP should explain this as its main approach.

Regeneration Strategy
The second underlining principle should be to secure regeneration through the development of sites A1, A2 and A3 together with some development of B and C. These sites are located in an area that would meet the town centre regeneration objectives of the authority. These land areas are closest to the core of the town centre and the Spa Road which is identified as needing improvement. However, it is not considered that these areas are suitable for significant residential development and at most 30 flats may be appropriate. This will enable the area to deliver retail, leisure, open civic space and some limited upper floor residential and office uses. It is considered that the civic square should be slightly larger to enhance the opportunity for outdoor use, particularly opportunities for specialist markets, community gatherings, small scale exhibitions and events, seating and the on street café culture.

This approach would enable the important benefits of the Eldon Way Industrial Estate to be retained and enhanced within the context of a new policy framework for the estate. By focusing on land areas A to C for the land assembly and compulsory purchase, the delivery of regeneration will be made simpler and at a scale commensurate with the settlement. It is considered that this approach will require some of the suggested land uses to be reviewed and the residential component to be reduced in order to ensure an appropriate quantum. This approach may be more viable and require less public authority funding.

The community development options and hub concept is supported.

Option 1.1

The additional residential units proposed under this option would inevitably lead to the loss of employment land. However, for the reasons noted elsewhere in these representations that would not be a sustainable approach. Residents would need to commute out of Hockley to access any replacement employment sites thus contributing to car journeys. The customer base, which the town centre relies on, would also be undermined.

Option 2.1 and 2.2

The redevelopment of most of Eldon Way Industrial Estate for alternative uses is considered to be at odds with the underlying principles of sustainable development. There are no other significant employment areas in Hockley. Both PPG4 and PPG13 note the importance of employment areas close to residential areas and the need to reduce travel by car, particularly over short journeys. The site is therefore highly sustainable. The employment area helps underpin the vitality and viability of the Town Centre and should be retained for that reason. The regeneration area the subject to compulsory purchase should be based on a scale and quantum that is necessary and that can be delivered. It is doubted that the residential uses proposed have a significantly greater use value than the employment site, particularly when the costs of redevelopment (and potential mitigation) is factored in.