December 2020 Update

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

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

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

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

[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.