New Clean Air Zone and overdevelopment

CAZ, Updates

Old Foresters

There has been much debate about events on Station Hill and Old Foresters of late following the hacking back of much of the hedge and most of the trees along Station Hill and the track leading to the site, where most of the trees are protected by Tree Preservation Orders, the unlawful use of the EFDC and TfL logos on letters left on commuter cars and the failed recent attempt of persons unknown to deliver four mobile homes to the site. TBAG has been taking an active interest in these matters as we are well versed in the history of this Green Belt site. Last week, two containers were delivered to Old Foresters and are clearly visible from the public footpath. These containers are alleged, but not proven, to be for use in connection with a food bank. Following the earlier dubious activities, we have been informed that EFDC Planning Enforcement Officers are also keeping an active watch on events and have informed TBAG that the “operator” of the containers should have permission to place them on the site and does not. The operator has therefore been given seven days to remove the containers, but they have refused to do so. Should the containers not be removed by Friday, 25 February an Enforcement Notice for their removal will be served. TBAG note, with no surprise at all, that despite the recent change of recorded ownership of this site, the new management appear to be continuing with their activities in the same mould as its predecessors.

Epping Forest CAZ

EFDC are attempting to deal with the district’s air quality issues, which are seriously affecting Epping Forest itself (a Special Area of Conservation and Site of Special Scientific Interest) which is described as being in 60% unfavourable condition, by proposing a Clean Air Zone (CAZ) for the forest and which will charge motorists to pass through it. New development near the forest had been put on hold until EFDC could satisfy Natural England and the City of London that this proposed new development – and that proposed in the emerging Local Plan – would not increase the harmful emissions to the area. EFDC reason that by charging vehicles to pass through the forest, drivers will be encouraged to exchange their existing vehicles for ‘cleaner’ electric vehicles and the anticipated result will be that harmful emissions will be reduced sufficiently to mitigate the proposed developments in the vicinity of the forest. There was great opposition to this decision by many District Councillors who saw it as a political walkover and definitely not in the best interests of either the forest or the district’s residents.

TBAG consider that the CAZ is little more than an attempt by EFDC to overcome its decision to permit 11,400 new homes to be built in the District under the emerging Local Plan and not to reduce these numbers (in line with the more up-to-date 2018 ONS statistics which showed a drop in the number of homes required of more than one-half compared to the 2014 figures on which the plan has been based). Were the up to date statistics applied to the emerging Local Plan, it would enable the removal of the most environmentally sensitive sites from the plan including those around the forest. Simply put, reduce the amount of unnecessary development (and pressure on the forest from increased footfall and vehicle movements) and thereby eliminate the need to charge motorists to pass through. And of course the need for EFDC to fund creating the CAZ.

The Planning Inspector will soon be returning her report on EFDC’s response to her requested Main Modifications to the plan and we await her conclusions with interest. TBAG reported in its last update about the Facebook Group ‘Say No to Clean Air Zone’. Supporters will recall that an EGM on this issue was held on 8 February 2021 . An eleventh-hour amendment was proposed by Conservative Party majority Councillors with no prior consultation with cross-party Councillors and this was submitted just 72 minutes before the meeting, giving non-Conservative Councillors insufficient time to consider and consult on the amendment. Councillors resolved to form a cross party portfolio holder advisory group to assist the “administration” in the implementation of air pollution mitigation measures.  It will be telling to see whether this ‘cross-party’ group will indeed be politically balanced or still have a Conservative majority.

Epping Forest Parking Charges

Further forest news that could impact on Theydon Bois is the City of London’s (CoL) recent consultation with the public on its decision to introduce parking charges for many of the car parks in the forest. We know that many of our supporters have helpfully responded to this consultation. This follows hot on the heels of the CoL’s decision last summer to introduce double red line stopping restrictions onto the majority of the forest roads making the car parks the only place that vehicles may stop in the forest. City of London have stated, at a Zoom Committee meeting when the vote for this proposal was taken, that the reason for introducing parking charges is to raise money because they have a “deficit of £250,000”. It is of note that all four Verderers for Epping Forest unanimously voted against this proposal.

It seems to TBAG that by charging vehicles to pass through and park in the forest, not only does this go against the spirit of the Victorian Act dedicating the forest to ‘all the people for all time’ and put a financial burden on all local motorists, but will also have a deleterious effect on our village when forest visitors seek to park on the fringes of these restrictions to use the forest, or local residents circumvent the forest altogether by driving further through its fringes to avoid paying the CAZ charges until the day they can afford a newer, cleaner car. One cannot help but wonder how the forest has been permitted to get into a state of 60% unfavourable condition and why the causes were not mitigated earlier and whether these new measures are not yet more unfortunate steps towards ultimately failing the forest rather than helping it.

As ever, TBAG will keep residents informed on any matters that might affect the Green Belt in and around Theydon Bois.

New Clean Air Zone and overdevelopment

CAZ, Local Plan

New Clean Air Zone and charges for residents in exchange for overdevelopment of the District

An Extraordinary General Meeting (EGM) has been arranged for the full Council of Epping Forest District Councillors for 8 February 2021 at 7pm. This is the first EGM to be called in the District for over 40 years and it has been requested by some Councillors because of the recent decision by EFDC’ Overview & Scrutiny Committee to introduce a Clean Air Zone (CAZ) for Epping Forest. The impact of this for Residents will be a financial charge to drive through Epping Forest’s roads and it will be costly for EFDC to set up too. The options for residents would be to buy an electric car, take to the bicycle or walk.

TBAG believe that the Councillors on EFDC’s Overview & Scrutiny Committee who voted for the CAZ on 7 January (click here to view the webcast), have done so as mitigation to enable the development of 11,400 new dwellings as put forward in the new Local Plan. This number of dwellings is excessive having consideration to the latest Government statistics (published May 2020) which show a reduction in Household Projections for the district of more than a half. EFDC simply refuse to lower the numbers of dwellings in the Local Plan, flying in the face of this hard statistical evidence from the Government’s own Office of National Statistics (ONS). Building homes on our Green Belt will directly contradict EFDC’s declared Climate Change Emergency, Green Infrastructure Strategy and use of the emerging Local Plan to reduce climate change.

The Inspector examining EFDC’s new Local Plan indicated in August 2019 that she was concerned at the proposed development of 11,400 new homes, largely on Green Belt land, and that this number would impact detrimentally on Epping Forest, particularly with respect to air quality. Excessive housing numbers will reduce the sequestration (locking up) of Carbon Dioxide (a Green House Gas) and also increase localised flooding. The new developments will also put increased recreational pressure on the already ailing forest environment, not to mention local services.

EFDC had hoped that their ‘Interim Air Pollution Mitigation Strategy’, including the CAZ, could be quickly rubber stamped by Cllr Bedford, EFDC’s Planning Portfolio Holder. However, the matter was ‘Called In’ by concerned Councillors from the Loughton Residents’ Association and the Green Party. At the vote on 7 January 2021 the Interim Strategy, with its controversial chargeable Clean Air Zone, was narrowly voted through by 7 votes to 5, and with 5 Abstentions!

Public reaction was immediate, with a Say No to EFDC CAZ campaign Facebook group being quickly created. TBAG share many of the views of this campaign and have taken the decision to fully support its aims and objectives as ultimately, it accords with TBAG’s own objectives to protect the Green Belt around Theydon Bois from excessive and inappropriate development. We would encourage our supporters to also support this group by joining its Facebook page to keep abreast of developments with the campaign.

It is common knowledge that EFDC just want to get its new Local Plan over and done with and that they do not want to reduce the excessive number of 11,400 homes or to review and amend its choices of site selection in order to protect the forest. In spite of the opportunities afforded by the Planning Inspector to reduce the amount of development on Green Belt land, as set out in our earlier updates, EFDC is not prepared to reconsider and remove the most environmentally sensitive sites which will mean good profits for developers and land owners and costly financial burden for residents. TBAG look to EFDC, in the first instance, to reduce the unnecessarily high number of new homes, and to scrap their proposed Clean Air Zone, which will be costly to set up and costly for our residents. The proposed Clean Air Zone is being used in an attempt to placate the Inspector into approving the new Local Plan, in spite of its excessive level of proposed new homes, the majority of which would be built on “our precious Green Belt land”.

If ever a District could justify the ‘exceptional circumstances’ for not meeting a prescribed (and now outdated) housing target in its new Local Plan, it is Epping Forest District, which is over 90% Green Belt, has limited brownfield sites and our unique Epping Forest itself which is designated as a Site of Special Scientific Interest (SSSI) and is internationally recognised as a Special Area of Conservation (SAC).

TBAG will keep supporters fully updated on this topic and would recommend that Facebook users join the ‘Say No to EFDC CAZ’ campaign and all our supporters consider writing to our Local Councillors with your own views before the webcast of the EGM on 8 February 2021 at 7pm.

December 2020 Update

Local Plan, Updates, Village News

Local Planning Matters

Theydon Bois Action Group (TBAG) has continued to make successful objections to what it considers to be inappropriate development in the Green Belt around our village. TBAG had objected to a planning application to build two large, detached, 5 bedroomed houses in the extensive grounds of Bowlands Meadow, Theydon Road, which the developer described as ‘limited infilling in a village’. Planning permission was refused by EFDC and the developer subsequently appealed to the Planning Inspector. TBAG submitted further objections to the Inspector, who dismissed the appeal. We also raised objections to various applications relating to two properties at Theydon Hall Cottages, Abridge Road, near the M11 motorway bridge. These were in connection with:

i) the unlawful placement of a mobile home relating to one of the cottages and the proposed extension of the residential curtilage to include an agricultural field which lies behind all 4 cottages and:

ii) the proposed, excessive, extension of another dwelling.

These applications were all refused permission by EFDC.

The Emerging Local Plan and Question over Housing Numbers

In July, TBAG alerted the village, through our Website Updates and Mailshots, that the Inspector dealing with our new Local Plan had contacted EFDC, pointing out that the Government’s latest (2018-based) figures for Household Projections in Epping Forest District had shown a dramatic decline (by more than a half) in the number of new households required in the Local Plan. EFDC had based their original assessments on the Government’s earlier data for 2014, this being the latest available data at that time. The Inspector then asked, whether the projected reduction in household growth (also shown in 2016) justifies building on so much of our Green Belt? Our District Councillor, Sue Jones, asked a question on this matter at a Full Council Meeting on the 30th July, when a prepared statement from EFDC was read out. However, the statement made reference to “Nothing will stop us getting the plan through” and “getting the local plan over the line” and, almost begrudgingly, if necessary “to remove the most environmentally sensitive sites”—presumably relating to the impact of excessive development on the environmental integrity of Epping Forest, of which the Inspector had already expressed her concerns.

There is a view, locally, that EFDC just want to get the local plan over with, as more delays mean more time, work and expense. But TBAG take the view that it should be the right number of homes, in the right places. EFDC put the Inspector’s question to their commissioned consultants, who, unsurprisingly, backed EFDC against the Inspector’s question, and argued that the number of homes should actually be increased from 11,400 to 11,920! The Inspector subsequently invited a wider consultation on EFDC’s response supported by their consultant’s 27 page report. TBAG responded with an evidence based critique (see response in full here), stating that the consultants had ignored the impact of Brexit and Covid 19 on migration and economic growth and had chosen to use a 10 year average method which would dilute the currently low household projection figures, by combining them with previously higher figures which peaked in 2013/14, with migration into our district at +1,500, compared to only +550 during 2017/18.

TBAG also responded to two Government consultations on Planning, including its White Paper on ‘Planning for the Future’. This White Paper caused great debate in Parliament by dissenting Tory MP’s due to impact on their Green Belts and countryside, including the Cotswolds, whilst ignoring ‘Growth’ in the Midlands and the North and the Government’s proclaimed ‘Levelling Up’ policy.

TBAG extends season’s greetings to all villagers and wishes you all a safe and healthy New Year.

TBAG Response to Planning Inspector’s Latest Consultation

Local Plan

TO: The Inspector for Epping Forest District Council (EFDC) Local Plan
Mrs Louise Phillips MA (Cantab) MSc MRTPI

FROM: The Chair of Theydon Bois Action Group (TBAG)
Dr John Warren BSc PhD

Ref:- ONS 2018-Based Household Projections, EFDC Examination Documents ED114 and 114A

Dear Mrs Phillips,
Further to your invitation to make comment, we wish to refute the conclusions made by EFDC and Opinion Research Services (ORS) and wish to make the following comments and critique for your consideration.

ED114 and EFDC
The methodology used, taking all factors into account, on the 2014-based figures for household growth (14,374) produced an OAN of 12,573 homes. The dramatic reduction (by 54%) in the 2018-based household growth of 6,616, gives rise to, on the same basis, an OAN of only 5,787 homes in stark contrast to the 11,920 now cited by EFDC’s consultants, ORS. It is well known locally, that EFDC just want to get the local plan over with – done and dusted – as delays mean more time and work and cost money, particularly on outside consultants. In this respect, it is not in EFDC’s interest to have the OAN reduced as it will mean more work on site selections to remove the most “environmentally sensitive sites”. This was made clear at a Full Council Meeting on 30 July 2020, when a prepared statement from Alison Blom-Cooper was read out by the Planning Portfolio Holder, Cllr Bedford, along with the comments, “getting the local plan over the line” and “nothing will stop us getting the plan through”. This Agenda item was a late addition to cover the Inspector’s letter of 14 July 2020 to EFDC re-the latest 2018-based household projections and the justification for the plan’s proposed Green Belt releases (ED111).

TBAG takes the view that, it should be ‘the right number of homes in the right places’, whereas EFDC seem to be acting with expediency being uppermost in its mind.We are concerned that an excessive, unnecessarily high, number of homes built on our Green Belt land, will impact detrimentally on the environmental integrity of the Epping Forest (SAC & SSSI) as well as dealing a blow to EFDC’s declared (19 Sept. 2019)Climate Emergency, because they are not prepared to reduce the level of development on Green Belt land, which serves beneficial purposes in the sequestration of carbon dioxide (A Green House Gas) and in flood prevention.

We are also concerned by EFDC’s long delay in placing documents ED114 and 114A, (their reply to the Inspector’s letter of 14 July), onto its local plan website and thus into the public domain. The delay of 19 days (from 4 to 23 September) is unacceptable, especially as the ORS document is 27 pages long and includes much graphical and tabulated data. The ‘lost’ 19 days meant that interested parties were disadvantaged in having significantly less time to give their full consideration of such detailed information, in the event that the Inspector invited further comments.

TBAG is also aware of the Local Councils’ Liaison Meeting (7 Sept. 2020) with EFDC and chaired by Nigel Richardson, Director of Planning. Cllr Mary Dadd (Ongar) asked a question about the ONS 2018-based figures being reduced to 6000, and Mr Richardson replied that “this is all about Green Belt and all Green Belt Councils had been written to”, mentioning that is was really one for Ms Blom-Cooper. He then added “It is very clear, the numbers are not going to change”. No mention was made of Epping Forest. So had EFDC decided, in the light of the recent ORS document (ED114A), not to await on the Inspector’s consideration of the matter and her potential, wider consultation?

ED114A, The Opinion Research Services (ORS) Report-September 2020

Note;- In reviewing this report, we have consulted with the following ONS published documents;

(1) Quality and Methodology-Information, by Andrew Nash, 29 June 2020
(2) Impact of different migration trend lengths, by Andrew Nash, 24 March 2020
(3) Variant Household Projections for England, 2016-based, by Saffron Weeks, 16 May 2019

Re- the ORS report, we refute the assumptions, methodology and conclusions in the report as it applies to Epping Forest District. Our district, which is 90+% Green Belt, lies just outside of Greater London and attracts migration from adjacent London Boroughs including Redbridge and Waltham Forest. These, in turn, are subject to inward migration from within London and the ONS Reports make it clear that EU Accession has been a major driver of migration into London. This unlimited migration will cease under Brexit and so it is wrong to project, into the future, events of the previous decade. Covid 19 will have, at the very least, a medium term impact on economic activity and Jobs. Yet these are not mentioned in the ORS Report, which uses Jobs to justify houses.

The ORS Fig 5 for Epping Forest District, clearly shows what has been going on and the dramatic downwards and ongoing trend taking place – from +1500 at its peak in 2013/14 to only + 550 for 2017/18. Yet, ORS try to justify the use of a 10 year variant method to average out peaks and troughs (and so dilute the clear downward trend) against the fact that a “Systemic Change” (Ref2) has happened because of Brexit, and of course Covid 19. The ONS Report (Ref2) covers the disadvantages of the 10 year method, “dampening the effect of more systemic changes that occurred over the 10 years” and the “multiple methodological changes. For example, internal migration estimates have had 3 different methods over that time which will necessarily impact on the quality of the figures.”

ORS also produce a further 2,950 homes, almost as make weight, by way of “adjustments” for supressed household formation and market signals (with an additional 12% uplift).

Finally, we wonder if the purpose of paragraph 9 of their report, re the endorsement of the Inspector of an aspect of the East Herts local plan, is an attempt to “bounce” the Inspector for Epping Forest District?

Dr John Warren

Chair, Theydon Bois Action Group

4 November 2020

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.