OCTOBER 2020 – UPDATE ON EFDC’s NEW LOCAL PLAN

Local Plan, Updates

EFDC HAS TOLD THE INSPECTOR IT DOES NOT CONSIDER THAT ANY ADJUSTMENT IS NEEDED TO THE PROPOSED HOUSING NUMBERS (11,400) IN THE LIGHT OF THE 2018 ONS FIGURES.

Following on from our July 2020 update, EFDC’s response of 4 September 2020 enclosing a report from their Consultants, Opinion Research Services (ORS) (see documents ED114/114A here) to the Planning Inspector’s letter of 14 July 2020 was finally made public on 23 September 2020. This response related to the latest (2018 based) Government national statistics which indicated a reduction of around 50% in projected household numbers for our district. The Inspector had asked EFDC to consider whether these latest projections “represent a meaningful change in the housing situation” and “Whether the projected reduction in household growth affects the justification for the plan’s proposed Green Belt releases”.

It is, therefore, very disappointing that EFDC has reached the conclusion that the latest statistical projections…. “do[es] not represent a meaningful change in the housing situation” and that “the housing requirement in the Local Plan Submission Version does not need to be adjusted.” EFDC then summarises: “Given this conclusion the Council does not consider that it affects the justification for the plan’s proposed Green Belt releases.”

The report and conclusion of EFDC’s consultants, ORS, is based on the ‘ten year variant method’ which looks back over the past 10 years when inward migration was higher, rather than looking at the present decreasing figures from 2014, 2016 and 2018 towards the indication of future, and downward, trends. It should be noted that ORS have also produced a similar report jointly for the Strategic Housing Market Area of Harlow, East Herts and Uttlesford District Council’s.

In view of our Council’s decision not to take this very valid opportunity to reduce or remove planned development in our Green Belt and are effectively ‘not budging an inch’, TBAG took the opportunity to write to the Planning Inspector on 6 October to express our support for her view that she may consider it necessary to seek the views of other participants in the examination. TBAG received a prompt reply on the following day confirming “that the Inspector will be inviting comments on these documents”; i.e. the Government’s Office for National Statistics (ONS) latest, 2018-Based Household Projections, and EFDC’s response to the Inspector, including the commissioned 27 page response from the Council’s consultants, ORS.

TBAG have heard today that this consultation will end in early November. TBAG will therefore actively participate in the Inspector’s Consultation on the latest (reduced) Government figures for Household Projections in Epping Forest District and will point out deficiencies in EFDC’s response and its commissioned consultant’s report on housing numbers.

TBAG, whilst committed to protecting the Green Belt surrounding Theydon Bois, are also very much aware of the detrimental impact on the unique Epping Forest biosphere that will result should there be increased recreational pressures and atmospheric pollution resulting from excessive and unnecessary increased housing numbers and associated traffic movements.

JULY 2020 – UPDATE ON EFDC’s EMERGING NEW LOCAL PLAN

Local Plan, Updates

Latest Government statistics indicate that a dramatically lower number of new homes (greater than 50% reduction) will be needed in our District during the new Local Plan period to 2033. This should be good news for our District’s Green Belt.

The Planning Inspector examining Epping Forest District Council’s (EFDC’s) emerging new Local Plan for 11,400 homes has written to EFDC pointing out that the latest Government statistics, from the Office of National Statistics (ONS), indicate a drop by more than a half in the projected number of new homes needed in our District. See the Inspector’s letter of 14 July 2020 here. EFDC based their predicted need of 11,400 homes on the ONS 2014-based figures. The Inspector also pointed out that this “meaningful change” in the actual number of homes needed, continued the downward trend indicated in the ONS 2016‑based projections.

TBAG highlighted in its Winter 2016 Update that EFDC’s claim that 11,400 new homes were needed across the District to provide homes for our children up to the year 2033 was untrue. We pointed out that the growth purely from within the District was “fairly small” at about 200 per year as stated by EFDC in their own Issues & Options Consultation document.

The Inspector has now asked EFDC to consider, inter alia, “Whether the projected reduction in household growth affects the justification for the plan’s proposed Green Belt releases”. TBAG awaits EFDC’s reply to this question with great interest.

TBAG also note that in 2019 following the Examination in Public, the same Inspector, in her advice to EFDC, expressed concern about the impact that 11,400 new homes and their associated traffic movements would have on the District’s (already poor) air quality and, in particular, its detrimental impact on the integrity of Epping Forest (a Special Area of Conservation) and its habitats.

While we await EFDC’s response to the Inspector’s request, which is due to be submitted by Friday, 31 July 2020, TBAG can only speculate on the effects Brexit and Covid 19 will have on the future ONS 2020‑based household projections which, with the two year lag in production, will be published in around June 2022 and which TBAG anticipate could be lower still.

In the meantime, we trust that EFDC will embrace this opportunity to radically reduce housing numbers, thus protecting our Green Belt and Epping Forest and also delivering on their promise (19 September 2019) to address the ‘Climate Emergency’ challenge.

Air Quality In Epping Forest

Local Plan

[The original article appeared in Envirotec Magazine]

The environmental team at engineering consultancy Idom Merebrook Ltd (IDOM) has been appointed by the City of London to work on a project assessing the air quality of Epping Forest – the largest public open space in the London area, and a site of national and international conservation importance.

Epping Forest is a 2400-hectare stretch of ancient woodland between London and Essex; it is made up of more than 50 areas of woodland, grassland, bridleway, recreational space and is home to over 50,000 ancient pollard trees and 100 lakes and ponds. As a former Royal Forest it is owned and managed by the City of London Corporation, as Conservators of Epping Forest.

Epping Forest has been designated as a Special Area of Conservation (SAC) under the Conservation of Habitats and Species Regulations 2017 due to the presence of beech woodland and heathland. The forest supports over 80% of the UK’s ancient beech trees, many of which are in excess of 500 years old including some of the oldest in Europe.

However, surveys have revealed over 60% of the forest is in unfavourable condition and is at a uniquely high risk of adverse environmental impacts, when compared to other internationally important sites in the southeast of England.

IDOM has been engaged as part of the overall emerging Epping Forest Local Plan (EFLP) to review the air quality sections of the Habitats Regulation Assessment and advise on the appropriateness of the methodology used and robustness of the conclusions reached.

IDOM Project Manager, Kat Johnson, commented:

“Background levels of air pollutants are exceeding critical levels across Epping Forest. This is highly unusual as, although concentrations of air pollutants are typically elevated in close proximity to roads, they do decline with increasing distance, typically to concentrations which are below critical levels.

However, within Epping Forest this is not the case and continuing high levels of air pollution mean that the forest is highly vulnerable to additional threats such as the increase in traffic emissions, associated with future plans outlined by Epping Forest District Council.

Even at the point when air pollutants drop below the critical level, there will still be a lag time in the recovery of habitats to favourable conservation status. Any increase in emissions will therefore extend the period of recovery and is contrary to the conservation objectives of the SAC.”

The approval of the council’s Local Plan, which results in increased traffic along roads through the forest and a consequent inherent increase in air pollution, would be at odds with recent rulings in the Court of Justice of the European Union (the so called ‘Dutch Nitrogen Cases’).

IDOM contributed to the written representation submitted by the Conservators and attended the Examination in Public hearing at Epping Forest District Council’s Civic Offices on 21st May 2019. Representatives from Natural England also appeared at the examination and raised a number of issues which aligned closely with IDOM’s evaluation.

The future of the forest now hangs in the balance, the Conservators recognise that development is necessary and have been working constructively with Epping Forest District Council to devise mitigation strategies for other aspects of the plan (namely recreational impacts).

The Planning Inspector issued advice indicating that further work must be undertaken by EFDC in order to conclude, beyond reasonable scientific doubt, that the Local Plan will not adversely affect the integrity of the Epping Forest SAC.

The IDOM team will continue work to support the City of London to help determine the most sustainable future for the Forest.

Spring 2020 Update

Updates, Village News

Local Planning Matters – Applications awaiting decision, pending further Local Plan work on Environmental Impact on Epping Forest Special Area of Conservation (SAC):-
Mossford Green Nursery, Abridge Road – TBAG submitted a strong objection to this proposal to build 17 new homes on an isolated Green Belt site.
Piggotts Farm, Abridge Road – TBAG submitted a strong objection on clear Green Belt Policy grounds against the development of 6 new dwellings in place of agricultural barns.
Bowlands Meadow, Theydon Road – TBAG submitted a strong objection to the proposal for 2 large new dwellings within the Green Belt grounds of the existing property.
Ivy House, Coopersale Lane – A revised scheme for entrance wall/gates, security fence and hedge has recently been submitted. TBAG will consider whether this has addressed the reasons for our earlier objection.
Recently registered – Land adjacent to Magnolia House, Abridge Road –TBAG is currently considering an application for change of use of former agricultural buildings to create 6 new dwellings in the Green Belt close to the M11 motorway.

Update – Epping Forest District Council (EFDC) new Local Plan and Environmental Concerns
The next opportunity for residents to make further comments on the Main Modifications to the emerging Local Plan, (as required by the Planning Inspector), is likely to be July 2020.
It is clear that the Planning Inspector remains concerned about the impact of housing development, traffic movement and air pollution on the integrity of Epping Forest (SAC) and its habitats. This issue was raised by Natural England and the Conservators of Epping Forest at the Examination in Public last year. In August 2019, the Planning Inspector actioned EFDC to provide evidence “beyond reasonable scientific doubt” ……. “that any effects of development would not be adverse; or to seek to avoid the effects by altering (or potentially reducing) the pattern of growth proposed in the Plan.” The Inspector reiterated her view to EFDC on 25 November 2019 stating that “My advice indicates that you should remain open to this possibility.”
TBAG has always maintained that the proposed number of new homes (11,400), which will result in a loss of Green Belt land, is far too high for a District composed of over 90% Green Belt and which includes the special habitat of Epping Forest, which has both National and European protection.

Climate Emergency – the negative ‘double whammy’ of building on our Green Belt
At a Council meeting on 19 September 2019, EFDC formally declared a ‘Climate Emergency’ in the District and pledged to do everything in their power to make Epping Forest District carbon neutral by 2030 and, in recognising the special circumstances of this District, resolved to protect the SAC (Epping Forest) through the Local Plan. TBAG welcomes this approach and would like to see action taken to reduce the planned number of new homes which is an obvious starting point. Our existing green open spaces and Green Belt land are already doing a vital job in removing and ‘locking up’ carbon dioxide (a greenhouse gas) from the atmosphere. New homes and associated traffic will generate more carbon dioxide and when this development takes place on Green Belt land, the overall increase in carbon dioxide levels is magnified. The increase in nitrogen dioxide and toxic particles from vehicle exhaust, brake linings and tyres adds another harmful dimension, both to people’s health and the Epping Forest biosphere.
Back in November 2004, Eleanor Laing MP presented a residents’ petition in Parliament to the, then, Labour Government in an attempt to stop 11,000 new homes being built in our District because of the impact on our Green Belt and the Epping Forest biosphere. TBAG would urge all of our elected representatives, if they are serious about addressing EFDC’s Climate Emergency, to use their best endeavours to significantly reduce the unsustainable housing target of 11,400 new homes, the majority of which would be built on Green Belt land!