TBAG has submitted a thorough and comprehensive group response to the Draft Local Plan consultation. Our letter dated 10 December 2016 may be downloaded and read here.
TBAG takes the Government to task over protection of the Green Belt. See our letter to Sajid Javid (Secretary of State for Communities and Local Government) urging him to take specific action to deliver on the Government’s many ‘promises’ to protect the Green Belt. We want to see Action from the Government, not Weasel Words.
Local Planning Matters
The Old School House, Coppice Row. Following the ‘demolition’ of much of the original building, the owner has now submitted a further application described as “The extension and conversion of” this historic, locally listed building – Ref. EPF/0811/17. The reality is that any development would now necessitate a rebuild, rather than a conversion. The present plans are for a more intensive development of 2 x 5 bedroom dwellings, instead of the 2013 approved plans for one 3 bedroom and one 4 bedroom dwelling. TBAG has submitted a strong objection to the increase in bedrooms, from 7 to 10, as this would result in an over-intensification of residential use on what is a highly sensitive Green Belt site adjacent to the Churchyard, War Memorial and the SSSI of Epping Forest.
Draft Local Plan & Protection of the Green Belt:-
EFDC have been holding Development Forum meetings with potential developers of sites around Harlow and across the rest of Epping Forest District. It appears that over 60 new sites have come forward but details have not been made public and no Minutes of these meetings have been published.
While residents were trying to get to grips with the enormity of the Draft Local Plan (DLP) Consultation, which ran from 31st Oct to 12th Dec 2016, we were unaware that EFDC, Harlow and East Herts District Councils had already made a joint application in October 2016 to the Department for Communities and Local Government (DCLG) requesting Government support for a new, “Locally-Led” Harlow and Gilston Garden Town, the huge impact of which was not fully publicised or appreciated at the time of the DLP Consultation and certainly not publicly consulted upon. Do not be misled with the description as a ‘new garden town’ since it is not a freestanding town but an extension to the existing Harlow Town and built upon the Green Belt land in East Herts and Epping Forest District. The Government euphemistically describes these tack-on developments as “transformational in scale”. In effect urban sprawl into existing Green Belt.
EFDC stated in their DLP Background Paper 4 (BGP4) at paragraph 3.4 that “The level of need identified for Epping Forest District [11,400 dwellings] is not, in itself, a sufficient justification for amending Green belt boundaries. Therefore, further analysis of the specific circumstances relating to the district is necessary.” In other words insufficient justification for building on our Green Belt.
However, it then goes on to justify that the expansion of Harlow, as part of the aspirational London, Stansted, Cambridge Corridor (LSCC), represented the “Exceptional Circumstances” which justified altering Green Belt boundaries in Epping Forest District – that’s ALL Green Belt boundaries including those around Theydon Bois. The proposal for growth and expansion around Harlow, as a new Garden Town, which includes land in Epping Forest District, gained Government approval in January 2017. This, so called, ‘locally led’ proposal, was supported by our MP, Eleanor Laing, as well as the MP for Harlow, Robert Halfon, but did not have the support of residents of Epping Forest District who were not consulted and were unaware of the impact that it would have on our Green Belt. As a consequence we are now faced with housing development on many Green Belt sites in Epping Forest District, including Theydon Bois.
EFDC had over 3,000 responses to the DLP Consultation and are still analysing these as not all responses used the Questionnaire format. A summary of responses, largely to the Questionnaire, have been published (see here) and the response to Question 3 (proposed development sites around Harlow) showed that only 8.1% strongly agreed, whereas more than 20% strongly disagreed; and this was without residents having the full knowledge of the implications for the rest of the Green Belt in Epping Forest District. A full report on the proposed LSCC and the detrimental impact it will have on all of our District’s Green Belt can be read on the TBAG homepage.
TBAG continues to work as an Executive Committee Member of the London Green Belt Council, in conjunction with CPRE, to do the utmost to protect the Green Belt around London. In contrast to our District, other MPs in Surrey and Kent are doing their best to protect their Green Belt, as can be seen in their responses to the recent Government White Paper Consultation on Housing, which can be viewed here.
It is clear that some Conservative MPs are prepared to put their heads above the parapet to protect the Metropolitan Green Belt, whereas our elected representatives and EFDC are actually facilitating development of our Green Belt land.
Local Planning Matters
The Old School House, Coppice Row. Many villagers who have walked past the Old School House have been appalled to see how little of the original building remains. Permission was granted in 2013 to extend and convert the existing building into two dwellings, not to demolish and rebuild it. Theydon Bois Action Group (TBAG) strongly objected to the large extension and change of use which would result in an intensification of use and a harmful impact on the sensitive Green Belt site adjacent to St Mary’s Churchyard. Many people considered that the best way to preserve this Locally Listed building was to approve the extension and conversion to residential use. Sadly, it is now evident that this was not the case as the majority of the building has been demolished, contrary to the planning permission which was granted.
Marcris Nursing Home, Coopersale Lane. Following Epping Forest District Council’s (EFDC) refusal of a proposal to demolish the care home and replace it with a new building containing 11 flats, a new proposal (EPF/3321/16) has been submitted to convert the existing building into 11 flats. TBAG has written a further strong objection to the loss of a much needed care home facility and change of use which would result in a harmful impact on the Green Belt and Protected Coopersale Lane due to the over-intensification of use of the site.
Draft Local Plan & Protection of the Green Belt
The level of housing development proposed for Theydon Bois in the Draft Local Plan, put forward by EFDC, would increase the size of our village by nearly 25%. Almost all of the development would be in the Green Belt with the largest proportion being to the east of the railway line, which has always formed a definitive and permanent Green Belt boundary to our village. TBAG have raised a strong and comprehensive objection, in particular to the proposed major expansion of our village and the associated encroachment into the Green Belt. The full letter of objection can be viewed here.
The Government is presently consulting on a new Housing White Paper in which it states that it is maintaining the existing strong protection of the Green Belt. However, this apparent protection fails in Districts with a large percentage of Green Belt as it is made clear that Local Planning Authorities (LPAs) can amend Green Belt boundaries if there are no other reasonable options (essentially, insufficient brownfield land) for meeting their identified housing targets. LPAs are advised to consult with neighbouring authorities to try to solve the problem. EFDC have indeed consulted with neighbouring Harlow District, who wish to expand Harlow Town (the recently announced, Government supported, new Harlow & Gilston Garden Town) as part of the greater growth plan, driven by the London, Stansted, Cambridge Consortium, along the M11 corridor. Unfortunately, this ‘plan’ involves development on our District’s Green Belt land and it is supported by EFDC who consider that the expansion of Harlow and the M11 corridor represent the exceptional circumstances which justify building on our Green Belt. This would appear to be at odds with the Autumn Budget Statement when the Chancellor of the Exchequer said “For too long economic activity has been centred in London and the South East.”
TBAG very much regrets that Harlow’s aspirations for growth will be to the detriment of Epping Forest District’s Green Belt. We are particularly concerned that, at present, our District Councillors seem to have acquiesced to the proposed loss of our Green Belt and are not standing up to the Government. Worryingly, our own MP wrote to the Minister of State for Housing and Planning (Gavin Barwell MP), in support of the creation of the new Harlow & Gilston Garden Town, in spite of the detrimental consequences for our Green Belt!
Local Planning Matters
Planning permission was finally granted for the development of 7 apartments and one ‘cottage’ on the site of the Sixteen String Jack PH (EPF/2000/16). In spite of the reduction in the number of flats, Theydon Bois Action Group considered that the final design, due to its height, bulk and insufficient set back, did not fully address the Planning Inspector’s reasons for dismissing the earlier appeal. TBAG raised a further objection as did the City of London (Epping Forest) and local residents. Only time will tell what the true impact of the development will be on this sensitive location at the edge of the village!
TBAG also objected to the application for 2 large dwellings to replace agricultural buildings in the Green Belt at Blunts Farm (EPF/2298/16), citing an earlier Planning Inspector’s appeal dismissal relating to this site. EFDC also recognised the relevance of the Planning Inspector’s reasons and refused the application.
We were disappointed that the two incidences of unlawful activity on secluded sites off the Abridge Road were both granted a Certificate of Lawful Development because EFDC accepted the evidence put forward and that the activity had continued without being detected for 10 years. TBAG objected on the grounds that insufficiently robust evidence had been provided. One of the applications was refused at Planning East Committee but this decision was, unfortunately, reversed by the higher District Development Control Committee. Had the matter gone to appeal, it would have been interesting to have had a Planning Inspector’s opinion.
Draft Local Plan & Protection of the Green Belt
Residents were concerned that three new development sites to the East of the railway line have been proposed in EFDC’s Draft Local Plan as the railway line is a permanent and definitive boundary between the village and the Green Belt. TBAG will raise the strongest objection to breaching this boundary and, along with the Rural Preservation Society, have been working with our Parish Council and their planning consultant. EFDC claim that 11,400 new homes are needed across the District to provide homes for our children up to the year 2033. This is not true as the growth purely from within the District is “fairly small”, about 200 a year, as stated by EFDC in their Issues & Options Consultation Document. This would only amount to a few thousand homes needed for our Local Plan. The Metropolitan Green Belt was put it place to protect the countryside around London and yet EFDC are proposing to alter our Green Belt boundaries, under pressure from Government, and take land out of the Green Belt for development due to outward migration from London by people who want, rather than need, to live here as well as pressure from Harlow Town who wish to expand by building on land in Epping Forest District.
The Green Belt land in our District is effectively being squeezed by pressures from London and Harlow due to Government policies for “Growth” and through promoting development along the M11 Corridor from London to Stansted and Cambridge, including Harlow, which will drive a brown field development “wedge” through the Green Belt where we live!
Government Ministers have consistently stated that they will “Protect our precious Green Belt land” and that “The Green Belt is absolutely sacrosanct” and that unmet housing need does not justify building on the Green Belt. Yet these promises are not being honoured in practice. Theydon Bois Action Group have launched a Petition to protect all Green Belts in England. Please visit our Website and sign the petition if you value our Green Belt.
TBAG extends season’s greetings to all villagers and wishes you all the very best for the New Year.
TBAG has launched a national petition through the 38 Degrees web site addressed to Sajid Javid MP, Secretary of State for Communities and Local Government, to protect all of the Green Belts in England. We would urge you to sign the petition and please spread the word to all of your friends, relations, neighbours, colleagues and contacts wherever they live, and encourage them to promote it via Facebook, Twitter, Streetlife, email and other social media. Apart we can make a noise; together we can make a difference.
The full wording of the petition can be found at https://you.38degrees.org.uk/petitions/to-protect-english-green-belts and the supporting evidence may be examined here.
18 July 2016, Sajid Javid MP (Conservative) Secretary of State for Communities and Local Government, in his first DCLG questions in Parliament said “The green belt is absolutely sacrosanct. We have made that clear: it was in the Conservative party manifesto and that will not change. The green belt remains special. Unless there are very exceptional circumstances, we should not be carrying out any development on it.”
18 July 2016, Gavin Barwell MP (Conservative) the new Housing and Planning Minister and Minister for London, said most development on the Green Belt is “inappropriate”.
22 June 2016, Mayor of London, Sadiq Khan (Labour), in a press release affirmed his pledge to protect London’s Green Belt, saying “I am determined to oppose building on the Green Belt, which is now even more important than when it was created.”
7 June 2016, In a letter sent to all Members of Parliament for English Constituencies and headed “Development on Brownfield and Green Belt land”, the Minister of State for Housing and Planning, Brandon Lewis, MP (Conservative) (“Mr Lewis”) stated that “The Government has put in place the strongest protections for the Green Belt ….. and that Green Belt boundaries should be adjusted only in exceptional circumstances, through the Local Plan process and with the support of local people. We have been repeatedly clear thatdemand for housing alone will not change Green Belt boundaries.”
11 February 2016, the Department for Environment, Food & Rural Affairs and the Department for Communities and Local Government, the Rt Hon Greg Clark MP (Conservative) (“Mr Clark”) and The Rt Hon Elizabeth Truss MP (Conservative) said in a press release on the Rural Planning Review, Call for Evidence that “…we are looking carefully at how our planning reforms can deliver this whilst at the same time ensuring local people have more control over planning and the Green Belt continues to be protected.”
2 December 2015, Mr Clark, announced “over 66,000 new affordable homes delivered in the last year – the highest annual increase since 1993; and numbers of new affordable and social rented homes up by nearly two-thirds in the last 12 months”.
20 November 2015, Mr Clark, Minister for Communities and Local Gov reported“186,000 more homes this year; over 753,000 additional homes since 2010; and highest annual increase in homes since 2008. So what’s the panic to build on Green Belt. Only urban sprawl will result from taking a Green Belt boundary here and putting it there.”
12 October 2015, David Cameron, Mr Lewis and Mr Clark said in a press release that “the Prime Minister is making crystal clear that he expects all councils to create and deliver local plans – making sure they take action to help reach the government’s ambition of delivering 1 million homes by 2020.” So it is Government ‘ambition’ that seeks to spoil our Green Belt by pressurising local authorities to deliver local plans which will be passed as deliverable by the Planning Inspectorate, despite the platitudes to protect Green Belts which proceeded this press release.
31 August 2015 In DCLG document ‘Planning and travellers: proposed changes to planning policy and guidance Consultation response’, it states “Unmet need and personal circumstances, Para 3.23, With specific regard to protecting the Green Belt the Government has decided to amend national policy and Planning Policy for Traveller Sites to make clear that (subject to the best interests of the child) unmet need and personal circumstances are unlikely to clearly outweigh harm to the Green Belt, and any other harm so as to establish very special circumstances. This change applies equally to the settled and traveller communities.”
14 April 2015 Conservative Party Manifesto states that the Party will “…ensure local people have more control over planning and protect the Green Belt.” and “We will protect the Green Belt. We have safeguarded national Green Belt protection and increased protection of important green spaces.” and that “Our plan of action: We will protect your countryside and Green Belt and urban environment … we will protect the Green Belt …”.
16 October 2014, Communities Secretary, the Rt Hon Sir Eric Pickles MP (Conservative) (“Mr Pickles”) said in a Coalition Press Release that “… these measures would ensure the green belt could continue to offer a “strong defence against urban sprawl in our towns and cities, …” and “…reaffirms how councils should use their local plan, drawing on protections in the National Planning Policy Framework, to protect the green lungs around towns and cities.” It also reported that Mr Pickles said “I am crystal clear that the green belt must be protected from development, so it can continue to offer a strong defence against urban sprawl.”
13 October 2014 Mr Pickles, reminded the House of the Government’s intention to protect the Green Belt saying “…housing need does not justify the harm done to the green belt by inappropriate development. … we have been very clear that there is no central diktatsdemanding that councils rip up the green belt.” And in a press release the same day, Mr Lewis referred to new planning measures that would “…at the same time protect our precious Green Belt.” And in another press release on this day he stated that new planning measures would include “- automatic planning permission in principle on brownfield sites – to bring forward more land to build new homes quicker, while protecting the green belt …”.
6 October 2014 Planning Practice Guidance is published by the Government which states that “Unmet housing need ….is unlikely to outweigh the harm to the Green Belt and other harm to constitute the ‘very special circumstances’ justifying inappropriate development on a site within the Green Belt”.
6 October 2014 Ministerial Statement made by the then Secretary of State for Communities and Local Government Mr Pickles, urged Councils to “protect our precious Green Belt land“ and saying “This Government has been very clear that when planning for new buildings, protecting our precious Green Belt must be paramount. Local people don’t want to lose their countryside to urban sprawl, or see the vital green lungs around their towns and cities to unnecessary development.” The press release went on to say “…Councils should consider how they will protect and preserve important sites in their area, especially Green Belt sites.”
17 January 2014 Statement made in the House of Commons by Mr Lewis as the Parliamentary Under-Secretary of State for Communities and Local Government: “… I also noted the Secretary of State’s [Mr Pickles’] policy position that unmet need, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the green belt and other harm to constitute the “very special circumstances” justifying inappropriate development in the green belt. The Secretary of State wishes to re-emphasise this policy point to both local planning authorities and planning inspectors as a material consideration in their planning decisions. …”.
9 January 2014 Press release from Downing Street, the Prime Minister’s (Rt Hon David Cameron MP (Conservative)) Spokesperson said: “the PM thought it was right to protect the Green Belt and development on green belt land was at record low levels. The government was putting local communities at the heart of planning decisions through Local Plans.”
1 July 2013 Ministerial statement, Mr Lewis as Minister of State for Housing and Planning said in the House of Commons that the Coalition Government had “… increased protection of the Green Belt …” and “Having considered recent planning decisions by councils and the Planning Inspectorate, it has become apparent that, in some cases, the green belt is not always being given the sufficient protection that was the explicit policy intent of ministers.”
1 July 2013 The Secretary of State, Mr Pickles, quoted saying “…unmet [housing] demand, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the Green Belt and other harm to constitute the ‘very special circumstances’ justifying inappropriate development in the Green Belt.“
17 September 2012 Downing Street Press Briefing, Prime Minister’s Spokesperson, when asked if the Green Belt was safe for the time being or until after the party conferences said ”… that the Government encouraged councils to examine flexibilities in the current planning regime. We had a national planning framework, which had been published recently and there are no plans to change that.”
17 August 2012 Coalition Government news article from the DCLG and Communities Minister Andrew Stunell MP (Liberal Democrat) said: “The Green Belt provides an important protection against urban sprawl, providing a ‘green lung’ around towns and cities. The Coalition Agreement commits the Government to safeguarding Green Belt and other environmental designations, which they have been in the new National Planning Policy Framework.”
27 March 2012 National Planning Policy Framework published.
23 November 2011 Coalition Government news article from the DCLG and Mr Clark, a Government spokesman said: “We have no plans to change Green Belt protection. It plays a valuable role in stopping urban sprawl.”
15 November 2011 Localism Bill receives Royal Assent. Alleges giving more power to local people.
20 October 2011 Government announcement from DCLG and Mr Bob Neill MP (Conservative) reported on plans to abolish regional plans and protect the green belt. “Pressure to build on the Green Belt is being removed with the revocation of Regional Plans according to environmental assessments published today. The Coalition Government is committed, through the Localism Bill now passing through Parliament, to abolishing Regional Plans, which imposed housing targets on local communities and put pressure on councils to cut the Green Belt in 30 towns across the country.” ‘Notes to editors’ at the end of the announcement stated: “6. The Government is introducing a stronger locally-led planning system, where local communities decide where development goes and receive benefits from that development through the New Homes Bonus and Community Infrastructure Levy.Communities will also have the power to prevent encroachment on the Green Belt and will benefit from a new special protection for green spaces under the Localism Bill.” And “7. The draft National Planning Policy Framework also safeguards valued, national protection for our countryside including Green Belt, Areas of Outstanding Natural Beauty and Sites of Special Scientific Interest to protect them from encroachment.”
28 September 2011 DCLG, The Rt Hon Grant Shapps, MP (Conservative), Minister of State for Housing and Local Government, in a Departmental response to Daily Telegraph story on planning reforms and house prices: “The Government is maintaining strong protections to safeguard the countryside, gardens, the Green Belt and other valued green spaces, including wildlife sites, from urban sprawl”.
14 September 2011 a spokesman for the Department for Communities and Local Government (“DCLG”) and Mr Pickles in response to a Daily Telegraph story suggesting that the Green Belt will have ‘no protection’ under the National Planning Policy Framework that “The Coalition Government stated its commitment to maintaining national Green Belt protection in its first weeks in the Coalition Agreement. The Green Belt has a valuable role in stopping urban sprawl and providing a green lung around towns and cities and this policy is continued in the new draft national planning policy framework. “In addition the proposed abolition of the unpopular Regional Strategies, through the Localism Bill, will remove top-down pressure on councils to review the extent of their Green Belt which was likely to effect more than thirty areas across England. Our new draft planning policy on traveller sites explicitly increases protection for the Green Belt and open countryside.”