Core Strategy Submission Document

Proposals for moving employment to out of town locations, at either end of the district, with no existing public transport links, are contrary to government policy PPG4. It also contravenes the Core Strategy's stated aims of reducing carbon emissions; reliance on car transport and providing "an integrated network of cycle paths".

The District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus services are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighbouring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states;
ï‚· (EC7.3C) "out-of-centre sites, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.
ï‚· EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPS1 (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

The Core Strategy also contravenes its own policy T1 and is unsound.

The Transport Evidence Base has not been re-evaluated following the decision to impose extra housing on the Eldon Way & Foundry Industrial Estates. ECC Highways have confirmed that the B1013 is running at 72% of its maximum theoretical capacity) and the effect of extra housing in Hockley (as well as Hawkwell) has not been re-evaluated and it is unclear what improvements will be required and whether they can be physically achieved.

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

The Transport Evidence Base has not been re-evaluated following the decision to impose extra housing on the Eldon Way & Foundry Industrial Estates. ECC Highways have confirmed that the B1013 is running at 72% of its maximum theoretical capacity) and the effect of extra housing in Hockley (as well as Hawkwell) has not been re-evaluated and it is unclear what improvements will be required and whether they can be physically achieved.

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

RDC are proposing to scatter housing across the district in around 12 or sites but no detailed consideration has been given to the implications for highways across the District. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):
"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.
The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

It is clear that (i) the combined impact of scattering houses across the District and (ii) relocating Eldon Way/Foundry Industrial Estates to the very edge of the District with no public transport services will exacerbate existing problems. It is also clear that the extent of improvements required is both unknown and not funded and the proposal is unsound.

RDC are proposing to scatter housing across the district in around 12 or sites but no detailed consideration has been given to the implications for highways across the District. The "Core Strategy" is not a strategy but simply a collection of disparate sites. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts or the funding required to upgrade them. At the Central Area Committee on 25 June 2009, RDC stated (in response to a question):
"Rochford Council is not the highway authority, but is working closely with Essex County Council to identify highway infrastructure requirements. Highway infrastructure improvements will be set out in the Core Strategy and other subsequent Development Plan Documents as required. These will be fed into the next version of the Essex Local Transport Plan, which is effectively a bidding document for funds to implement highway infrastructure improvements, schemes to tackle congestion, etc.
The District Council is working closely with the Essex County Council to ensure that highway infrastructure identified in the Core Strategy can be delivered."

It is clear that (i) the combined impact of scattering houses across the District and (ii) relocating Eldon Way/Foundry Industrial Estates to the very edge of the District with no public transport services will exacerbate existing problems. It is also clear that the extent of improvements required is both unknown and not funded and the proposal is unsound.

PPS12 4.9 states "The infrastructure planning process should identify, as far as possible: infrastructure needs and costs". Neither needs nor, especially, costs have been identified and the Core Strategy is therefore unsound.

The district's highways suffer from years of under investment and over use. The Core Strategy proposes to fund infrastructure improvements through use of Standard Charges. However, no detail is provided and no attempt made to identify the likely scale of such charges. It is therefore unclear if use of Standard Charges is financially viable.

Policy T2 provides a list of required highway improvements. The list contains most of the more major roads in the District including Rectory Lane, which has a single track, traffic light controlled railway bridge. 1200 dwellings are proposed for the northern end of Rectory Road and a further 175 at the southern end. The cost of addressing the railway bridge bottleneck will be significant but is not mentioned.

No attempt is made to either cost these charges or explain how improvements not linked to any one specific development will be paid for (eg B1013; Ashingdon Road; a network of walking, cycling, bridleways).

The concept of paying for improvements through use of Standard Charges is totally unproven and unsound.

SERT is put forward as a solution to reducing car use but it will only skirt the edge of the district and the Core Strategy acknowledges there is only "potential" to do so in the future. SERT is not realistic or reliable a solution and the proposal is therefore unsound.

Previous consultations ignored by RDC:
ï‚· The Hockley Parish Plan (dated 2007), clearly states that residents are strongly against any large scale housing development in Hockley, developments. and the proposals also ignore the 95% rejection rate of respondents to RDC's own Hockley Area Plan (HAAP) Consultation (2009), which included specific proposals for Eldon Way (although HAAP did not even mention the adjoining Foundry Industrial Estate). Why have a consultation and ignore it?

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

Previous consultations ignored by RDC:
ï‚· The Hockley Parish Plan (dated 2007), clearly states that residents are strongly against any large scale housing development in Hockley, but if there has to be additional housing, then there should be no loss of greenbelt or open spaces, and no large housing estate developments. It was also stated that any developments must be matched by the appropriate levels of infrastructure.
ï‚· The proposals also ignore the 95% rejection rate of respondents to RDC's own Hockley Area Plan (HAAP) Consultation (2009), which included specific proposals for Eldon Way (although HAAP did not even mention the adjoining Foundry Industrial Estate). Why have a consultation and ignore it?

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

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
ï‚· The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW businesses entirely
ï‚· the Foundry Industrial Estate has never even been previously mentioned in any plan version;
ï‚· The Urban Capacity study stated a "low probability" of housing and did not mention the Foundry Estate

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