Local Planning Matters
Lillicroft Nurseries: EPF/2528/17. The latest application to replace the existing wooden dwelling with a bungalow more than four times the existing size has been refused by EFDC. TBAG submitted a strong objection to this proposal as it is ‘inappropriate development’ in the Green Belt according to National Planning Policy.
Land adjacent to Gun Cottages: EPF/0102/18. TBAG raised an objection to an application for a retrospective change of use of this stable to ‘B8 storage and distribution’. We have highlighted the earlier attempt to get a change of use to residential, which was refused by both EFDC and the Planning Inspector, largely on the grounds of harm to the Green Belt and landscape character and, significantly, contrary to a Condition imposed in the original planning permission restricting use of this stable to private stabling only and not for any commercial or business activity (including livery). It is hoped that EFDC will honour the original condition and subsequent decisions and not permit this change to business use.
Macris House: EPF/3321/16. An application for conversion of the care home into eleven flats was finally refused by EFDC. TBAG raised an objection to this application in January 2017. The grounds of refusal were: (1) impact on the Green Belt; (2) loss of community facility and loss of employment; and (3) not being within a sustainable location or adequately incorporating principles of energy conservation or sustainable design.
EFDC Local Plan – December 2017
TBAG felt disappointed that our Local Authority only provided the minimal six week consultation period for consideration of the Submission Version of the Local Plan 2017 (SVLP) because this period included one week of Christmas holidays when EFDC offices were closed. During this closure, it was impossible to obtain hard copies of the Plan document(s) which were not available until the New Year (2018). The Submission Version of the Local Plan, together with its Appendices, totalled some 510 pages and this was in addition to the voluminous evidence base documents which are only available on-line or at the Council Offices. TBAG was also disturbed to see that this consultation was not given the same level of publicity as had been given to the earlier Issues & Options and Draft Local Plan consultations, when leaflets, road-shows and talks were given to reach out to all residents. EFDC appeared to be rushing to get this plan submitted for Examination in Public before the 31 March 2018 deadline*, under threat from Central Government of even greater housing targets (an additional 9,000 houses) being gratuitously imposed.
So, under pressure of time and at a busy time of year for us all, TBAG volunteers worked tirelessly to prepare a Group response to the Regulation 19 Pre-Submission Local Plan. A summary of our responses follows:
- The Inspector has been invited to travel on the Central Line during rush hours both from Theydon Bois and returning in the evening in order to experience the passenger numbers first hand.
- Exceptional circumstances for altering Green Belt boundaries appear to apply only around Harlow Garden Town and the London Stansted Cambridge Corridor and not in the rest of the District, including Theydon Bois.
- This plan is completely devoid of specific Green Belt planning policies e.g. replacement dwellings in the Green Belt, residential curtilage and basements etc.
- Provision for the retention of the Balti House as a long-established community asset has been specifically requested.
- Harlow Garden Town – we have pointed out that no meaningful public consultation has been undertaken by EFDC on this apparently pre-determined proposition.
- London Stansted Cambridge Consortium – whose main officials are based in the London Borough of Haringey – was established in 2013 as a developers’ concept to build a brownfield wedge along the M11 corridor from London and through Epping Forest District’s Green Belt.
- The 418 bus service (Loughton – Epping and Harlow via Theydon) should be ‘essential’ and not just ‘desirable’.
- Strong objection to a 4.1 hectare “essential” public park which has been put forward by EFDC for Theydon Bois.
TBAG’s full response can be viewed on-line by following the link from our website here.
Developers Campaign to build on Theydon’s Green Belt east of Railway Lines – January 2018
TBAG is fully aware of the deplorable on-line campaign by the development company Redrow PLC promoting the protection of Jessel Green, Loughton from development proposed in the Local Plan. Their proposal is to transfer the development to Green Belt land (upon which they have an option to buy from the landowner) in Theydon Bois east of the railway line and off Abridge Road.
We were deeply shocked and disappointed by Redrow’s cynical tactics to set neighbourhood against neighbourhood in an attempt to gain support for their own profitable scheme. TBAG believe supporters of the ‘Save Jessel Green campaign’, which we are informed are in no way connected with Redrow PLC, have been duped into signing Redrow’s petition to build in Theydon Bois without being given all the facts. This incident does nothing for the ongoing reputation of developers generally and we understand one of our supporters is in correspondence with Redrow to seek explanation for their actions.
Also, CK Properties Theydon Bois Ltd (CK) were disappointed that their site, to the east of the railway line, was not selected for development in the SVLP. CK have commenced Judicial Review proceedings against Epping Forest District Council, contending that they have been prejudiced by the unavailability of Appendix B to the Site Selection Report (Arup December 2017) during the Regulation 19 publication period. The Judicial Review hearing is scheduled for 23 and 24 May 2018 and EFDC cannot now submit the SVLP to the Planning Inspector by 31 March 2018* as was originally planned.
National Protection of the Green Belt
TBAG’s ongoing lobbying of Government to protect the Green Belt, not only via its own efforts but also through the membership and active support of organisations such as the CPRE, London Green Belt Council and National Organisation of Residents’ Associations, seems to be having a positive effect. In 2017, thanks to persistent campaigning by these organisations, Government acted on some of the ideas put forward in the White Paper consultation, including promises to protect our Green Belt. A further Government consultation on the revisions proposed for the NPPF is currently underway with a closing date of 10 May 2018 to which TBAG plans to submit a response. Government is also now recognising the long-held practice by developers of ‘land banking’. While there are arguments for and against this, it is the foundation of control of the ‘housing market’, as developers are able to govern the amount of housing reaching the market and thereby control prices, thus keeping them profitable. We were heartened by Sajid Javid’s announcement on 8 March 2018 that: “The [NPPF] reforms also include more flexibility to develop brownfield land in the green belt to meet affordable housing need with no harm to the openness of the green belt. Even the mention of the words “green belt” may cause some concern, but let me assure right hon. and hon. Members that this is about building homes on sites that have previously been developed, not about compromising in any way existing protections that govern the green belt. Our green spaces are precious and deserve our protection, which is why the Government are also delivering today on our manifesto commitment to give stronger protection to ancient woodland, which demonstrates that we do not have to choose between improving the environment and delivering the homes we need—we can do both.”
The All Party Parliamentary Group for London’s Green Belt wrote to Sajid Javid on 9 November 2017 with its first response to a Government consultation being the assessment of housing need. See https://londongreenbeltcouncil.org.uk/lgbc-cpre-and-the-all-party-parliamentary-group-for-londons-green-belt-respond-strongly-to-the-goverments-consulatation-on-assessing-housing-need/ to read this and other responses. The APPG convened for the second time recently on 30 January 2018 and this meeting coincided with the publication of its first paper entitled An Introduction to the All-Party Group for London’s Green Belt. Read this paper (as an attachment) at https://www.blunt4reigate.com/news/parliamentary-group-londons-green-belt-launches-its-manifesto. The APPG have also issued a Press Release entitled ‘All-Party Group calls for ‘more clarity’ on green belt housing.’ You may read this document at https://www.blunt4reigate.com/news/all-party-parliamentary-group-londons-green-belt-calls-more-clarity-green-belt-housing.
This all demonstrates that the groundswell of disquiet from voters opposed to development of Green Belt land nationally is finally being heard. Hopefully, Government will realise that allowing developers to build thousands of houses will NOT fix the “broken” housing market because what the market needs is AFFORDABLE and SOCIAL homes – not a surfeit of executive homes, or even small family homes if they are not available to those that actually need the housing by reason of being simply unaffordable. Trends coming from London indicate that a lot of young people and families now resort to one-room living (with shared facilities) as was the case in Georgian times when owning or renting a whole house was financially out of the question for most. Do we really want to return to those times? We rely on the common sense of our political leaders to control development accordingly.
It is of particular note that the Mayor of London, in the Draft London Plan, categorically states that the Green Belt should be protected within Greater London. If that is the case, TBAG would ask: Why should migration from London cause development in the London Metropolitan Green Belt outside of Greater London, such as in Epping Forest District, when there is sufficient brownfield land available in London? EFDC has stated that the natural population growth within Epping Forest District is ‘fairly small (approximately 200) net gain of population most years, purely from the District’s existing residents.’ (Ref. Issues and Options Consultation 2012). So there is clearly not the local need within our District for 11,400 new homes, which will destroy 1,250 acres of our Green Belt land.
It is increasingly felt that the issue of Green Belt protection, both around London and Nationally, could feature significantly in the next General Election.
TBAG works hard to keep its finger on the pulse of the fast-changing world that is today’s planning legislation scene and the events that lead to changes therein, with the ultimate goal of protecting the Green Belt around Theydon Bois.
*As we go to publication of this newsletter, Cllr Philip has announced in the Guardian that the 31 March 2018 deadline has been extended and our further enquiries of EFDC confirm that they are awaiting the outcome of the court case before they can submit our SVLP. What happens with regard to submission of our local plan in each of the possible outcomes of the Judicial Review for EFDC is unknown. There is also a suggestion that SVLPs will not be required to be submitted before the outcome of the NPPF consultation has been processed and the new Framework formally published. We understand that Government are hoping to get the new NPPF published before the Summer Recess on 24 July 2018. This leaves residents in the position that we do not know when the SVLP will be submitted, nor can we know if it will remain in its present form, as it appears entirely dependent on the outcome of the Judicial Review proceedings.