In his Conservative Party Conference speech on Wednesday Boris Johnson said (reported in The Telegraph) that houses should not be built on “green fields” as ministers abandoned proposals for a vast overhaul of planning rules.
Local Planning Matters
Whilst Theydon Bois Action Group’s (TBAG) primary ‘Mission Statement’ is the protection of our precious Green Belt, we will also raise objections to any planning applications that we consider would be detrimental to the village and/or its residents and could create an undesirable precedent for similar developments in the future. We take the view that telecommunication masts fall within this ‘category’ and previously made a successful objection to a proposed telecoms mast in the green verge at the junction of Station Approach and Slade End, back in 2012.
Proposal for a Telecoms Mast in Orchard Drive:-
TBAG have made a very strong objection to this application which, if successful, would result in a 15 metre high telecoms mast and associated cabinets, being placed in the pavement outside of Theydon Bois Primary School and in front of the caretakers house. We consider that the proposal is fundamentally flawed and possibly made as a ‘chancers’ application. The Vice Chair of TBAG spoke strongly against this proposal at our Parish Council Planning Committee Meeting which was well attended by concerned residents. TBAG subsequently emailed our supporters to encourage them to send their objections to Epping Forest District Council (EFDC).
Proposal to develop 28 new homes on Green Belt land to the North of Forest Drive:-
It is unlikely that any decision will be made in the near future. In addition to objections from TBAG, the Parish Council, Rural Preservation Society and residents, there have been a number of objections from County and District Council consultees due to concerns regarding trees and landscape protection, design and layout, drainage, noise levels etc.
The Former Old Foresters Sports Ground:-
TBAG have registered three complaints with EFDC Planning Enforcement relating to this site which is in the Green Belt. The complaints relate to:- (i) The unlawful placement of two containers for the storage of food, (ii) The continued presence of Travellers on the site, and (iii) The unlawful works being carried out to increase the area of hard standing on the site. EFDC issued an Enforcement Notice to have the two containers removed, but the site operator has since appealed to the Planning Inspector, who will carry out a site visit prior to making a decision on the case. TBAG wrote to the Planning Inspector with detailed objections. However, we understand that the containers were subsequently broken into and now remain empty. It is not known whether or not the site owner has given permission for the travellers to stay on the site!
TBAG have been and will continue to monitor the situation and will mailshot supporters when any action is required. If not already signed up, you can do so here.
EFDC’s Emerging Local Plan to build 11,400 homes in our District, mostly on Green Belt land
TBAG has already stated its grave concerns about the unnecessarily high number of homes put forward by EFDC, against the latest Government data showing that only half are actually required. We also take issue with our locally elected representatives who, in the main, seem to be content to follow EFDC and Central Government policy to build its way out of the recession, rather than listening to residents! We are also concerned about the detrimental impact that the proposed development will have on Epping Forest, especially in terms of atmospheric pollution and air quality.
The Main Modifications (MM’s) put forward by the Inspector to EFDC’s Draft Local Plan, are now out for consultation, prior to the Inspector deciding whether or not the Local Plan is found to be sound. However, it has recently been announced that the Inspector will be on maternity leave, commencing early in November and an ‘understudy’ Inspector has been appointed.
EPF/2151/21 Application to determine if Prior Approval is required for a proposed 15m Phase 8 Monopole C/W wraparound Cabinet at base and associated ancillary works.
Location: The highway outside Theydon Bois Primary School, Orchard Drive, Theydon Bois
In a departure from our usual remit of protecting the Green Belt around Theydon Bois, TBAG have submitted a robust objection to the above planning application. The closing date for comments is 1 September 2021 (next Wednesday) and comments can be made here or by email to email@example.com quoting ‘Planning Application: EPF/2151/21 – Orchard Drive, Theydon Bois CM16 7DH’ in the email subject header.
This application is very similar to EPF/982/12 for determination as to whether prior approval was required for a 12.5m Vodafone/O2 monopole with antennae on the corner of Slade End and Station Approach in 2012. TBAG also strongly objected to this application and the Planning Officer decided prior approval WAS required and it was REFUSED. TBAG have expressed our expectation that EFDC Planning Officers are consistent in their determination of this current application.
Our Parish Council have helpfully given guidance on planning issues that may be cited as part of your own comments, but you are advised to put these suggestions into your own words as unique comments will carry more weight than many copied ones. The Parish Council’s comments are here. Please also note that any concerns over the health implications of this installation are not planning considerations and will carry no weight in determination of this application.
LOCAL PLAN: EFDC continues to push through its emerging Local Plan for 11,400 homes, with the majority to be built on Green Belt land in this District, despite the latest Government figures demonstrating that around half this number is actually required (see our February newsletter for details). The impact on existing local community infrastructure (doctors, schools etc) is simply unsustainable
In TBAG’s opinion if EFDC do not want to have their Local Plan to be found unsound, they need to reduce their housing numbers in line with the latest Government household projections for Epping Forest District and remove all polluting development sites closest to Epping Forest.
FAKE NEWS: It is absolutely FAKE NEWS to claim that if our local plan is not found to be sound, the Government will impose 21,000 new homes on our District under the Government’s latest Standard Housing Needs Formula (the Algorithm), instead of the already unnecessarily high number of 11,400. The Government Planning Inspector has already expressed concern that this number is TOO HIGH and would detrimentally impact the Forest (and no doubt residents) and has already rejected a push from Developers at the Examination in Public to increase the 11,400 to 12,500. This fake news amounts to pure scare tactics to attempt to silence those interested parties who actually want the numbers justly reduced in order to preserve the environmental integrity of Epping Forest, in line with the concerns expressed by the Inspector. It is quite clear that if the Inspector is already unhappy with the impact of 11,400 new homes on the integrity of Epping Forest, she (or any other Inspector) could hardly condone any increase in numbers.
CAZ: Last February EFDC tried to placate the Inspector’s concerns regarding atmospheric pollution by voting in a proposal for a Clean Air Zone (CAZ) designed to charge motorists using Forest roads. Since our last newsletter, TBAG have heard from a considerable number of concerned supporters about this disastrous proposal. When it is introduced by EFDC, TBAG anticipate that this scheme will merely push LOCAL TRAFFIC from Forest roads onto those roads which skirt around the Forest, including roads through Theydon Bois. This will in turn cause congestion on those roads while the chargeable roads are left free for HGVs and commercial vehicle operators that can afford to pass on the cost of using them to their end customers. As a result, slow moving traffic and the greater increase in numbers will only INCREASE the pollution on non-toll roads in residential and Green Belt areas, thus causing a ring of pollution around the Forest. What with the anticipated increase in local pollution from 700 daily HGV movements from the proposed Next warehouse development on Green Belt land in Waltham Abbey, J26 of M25 (if EFDC ultimately grant planning permission), from the M25 and M11 generally, and the ultimate 11,400 new homes, TBAG anticipate that little benefit to the Forest will ultimately result and great detriment to residents will follow. To introduce local vehicle exclusion zones, which for some residents will be simply unaffordable, and yet to STILL build the excessive number of homes planned is pure folly for residents’ wellbeing and futures.
CAR PARKING CHARGES IN THE FOREST: Introduction of charges for car parking in the Forest by the City of London (CoL) doesn’t give people CHOICE; it merely DISCRIMINATES. If the car is so damaging to the Forest; why are CoL encouraging it at all and not deciding to restrict car access? TBAG would rather see the Forest retained as a natural environment which does not accommodate or introduce any more man-made elements regardless of how the ‘times change’ around it (i.e. parking signage, meters, gates, enforcement officers’ cars simply adding to numbers). It is an ancient forest and should look like one; not a budding Center Parcs. How about a useful forest-wide stop-on-demand bus service instead?
GREEN INFRASTRUCTURE STRATEGY: The EFDC Cabinet recently approved this Strategy document, which includes the so-called ‘enhancement’ of the Woodland Trust site between Theydon Bois and Debden (alongside the M11) with better signage and trackways, arguing that residents of the proposed new developments in Theydon Bois, Debden, Loughton and Buckhurst Hill, will visit the 38Ha site INSTEAD of Epping Forest. This outcome is highly unlikely due to the remote location of this Woodland Trust land, its immediate proximity to the M11, its remoteness, and the fact that there is no parking there. TBAG pointed this out to EFDC, in its consultation last year, as did Theydon Bois Parish Council, but these comments were ignored and, incidentally, NOT PUBLISHED. We see this as another attempt by EFDC to try and justify building 11,400 homes in a District which already has huge constraints against development, being over 90% Green Belt and having Epping Forest, which is nationally and internationally recognised as an SAC and SSSI.
THE REAL SITUATION
In 2020, the Government carried out two consultations and TBAG responded to both of them. The first consultation was on the Government’s proposals on “Changes to the current planning system” and included their so-called Standard Method For Assessing Local Housing Need – the Formula or Algorithm. The second consultation was on the Government’s White Paper called “Planning for the Future,” which was strongly debated in parliament following a call for debate by Conservative MP Bob Seely (Isle of Wight), who was supported by some 50+ of his colleagues. In the light of these two consultations and the critical debate in parliament, the Government published its response to the first consultation, which included the proposed changes to the Standard Method For Assessing Local Housing Need. In back tracking, the Government Response made it quite clear that “Within the current planning system the standard method (Algorithm) does not present a ‘target’ in plan-making, but instead provides a starting point for determining the level of need for the area, and it is only after consideration of this, alongside what constraints areas face, such as Green Belt, and the land that is actually available for development, that the decision on how many homes should be planned is made.” In Epping Forest District, we also have the ADDITIONAL, internationally recognised, constraint of the Epping Forest to protect as well.
NO CHALLENGE TO THE LOCAL PLAN HOUSING FIGURES: TBAG remain deeply concerned that our elected representatives, including District Councillors, have not grasped every or indeed any opportunity to challenge EFDC about those constraints but rather to take the softer option of following the Government’s line that development, whether inappropriate in the Green Belt or not, will boost the national economy. The Prime Minister, in PMQ’s on 8 July 2020, announced the Conservative agenda to be “Build, Build, Build for Jobs, Jobs, Jobs“, so are we to expect an ongoing loss of our “precious Green Belt” to developers; land which the Government had also declared to be “absolutely sacrosanct“?
In stark contrast to Epping Forest District, we are aware that elected representatives in Surrey, Sussex and Kent have fought hard to protect their local Green Belt land, along with newer, independent councillors (pledging to protect the Green Belt). The Member of Parliament for Sevenoaks, in Kent, Laura Trott MP (Conservative) has been particularly active in this respect.
TBAG wonder if development of our Green Belt is really all about money. Grants to Local Authorities, like EFDC, from Central Government have been dramatically reduced, often by more than 50%, and so it follows that Local Authorities who allow more development will get more money coming in from the Council Tax. Land owners who have their Green Belt, possibly agricultural, land developed for housing, will make a financial killing, and large development companies will acquire their preferred ‘shovel ready’ sites in their quest for profit margins in excess of 20%. Developers do not want the difficulties of building on previously developed, brown field land, which is often urban and potentially contaminated. During the parliamentary debate in the House, on the ill-fated Government’s White Paper on “Planning for the Future“, which had many dissenting Conservative MPs, Apsana Begum, MP for Poplar and Limehouse (Labour) stated that the Government’s party-political funds had received £11m from property developers, and referred to the White Paper as a “Developers’ Charter”.
THYB.R1, VIRGIN GREEN BELT LAND AT THE END OF FOREST DRIVE EPF/0292/21: Thank you to all those who wrote to TBAG expressing their objection to this planning application. Many residents attended the Parish Planning meeting on 18 March 2021 to make their own views known and the Parish Council made a strong objection to the application. TBAG also submitted a robust letter of strong objection to EFDC and included all the concerns that supporters had expressed. Since the Parish Council objected to the application, it will now likely be pushed up to District Planning Committee for consideration, that is, unless the Planning Officer refuses it first. Another way to make your feelings known about this application is to lobby our Ward Councillors John Philip and Sue Jones at firstname.lastname@example.org and email@example.com respectively and encourage others to do the same. TBAG feel these two Councillors have had and will have the greatest influence on the District Committee concerning this development site and, as our elected representatives, it would be appropriate for them to robustly reflect the views of the residents they represent within their ward. Statutory consultation expires on 5 May, so we should know more after that.
FORMER OLD FORESTERS: The operator of the food bank containers, Pesh Kapasiawala, remains in breach of planning law by not removing the two containers from this green belt site. The EFDC Enforcement Notice that was served is now put on hold because the operator has lodged an appeal with the Planning Inspectorate. We await the outcome of this appeal.
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.