TBAG Responds to Government Consultation

Government Consultations

TBAG has responded robustly to a Government (Ministry of Housing, Communities and Local Government, MHCLG) consultation on the Draft National Planning Policy Framework (NPPF) (Dec 2025) Proposed Reforms and other Changes to the Planning System. TBAG consider that the Government has failed in its duty of care to get developers to build out 1.4 Million existing approved planning permissions for new homes and instead is promoting the construction of a further 1.5 Million new homes on grey and green field sites including on designated Green Belt land.  Read TBAG’s full consultation response given below:

Response from Theydon Bois Action Group (TBAG) to MHCLG Consultation on the Draft 2025 NPPF-Proposed Reforms and other changes to the Planning System.

To:- MHCLG Consultation Draft NPPF 2025

From:-   Dr J Warren
Chair
Theydon Bois Action Group
[Address redacted]

 

The Proposed draft NPPF is based on a false premise and is therefore fundamentally flawed!

The Government, in this draft NPPF, does not seem to recognise, or possibly accept, that the rate of actual home building is controlled by the developers, who ‘land bank’ and ‘drip feed’ development onto the housing market in order to keep prices high and maximise their profit margins (typically 15-30%).  On the supply side, there is already no shortage of approved, extant planning permissions for building new homes, but the developers have simply not chosen to proceed with building them.  The number of granted planning permissions for new homes, not yet built out by developers, is very substantial, at well over 1 Million homes.  The Institute of Public Policy Research (IPPR) has reported that there are currently planning approvals for 1.4 Million new homes, being sat on by developers and not being built out.

The Government’s desire to build 1.5 Million new homes over the 5 year parliamentary term is, incidentally, the same as the last Government’s aim of building 300,000 new homes a year.  What is clear, is that the current Government’s aim of building 1.5 Million new homes can be met NOW, if developers got on and built out.  But developers control the market and will be only too happy to continue to ‘land bank’ and will fully approve the draft NPPF, because it will give them a bigger reserve of land to ‘bank’.  Furthermore, developers prefer easy, green field, ‘shovel ready’ sites, as more profit can be made on developing them!  So, the Government’s effective attack on Green Belt land, and the so-called, spurious, ‘Grey Belt’ will suit developers just fine, along with a default YES to building in the Green Belt alongside rail stations.  Where is the thrust for building on brown field first, or is it just lip service, whilst promulgating building in the Green Belts under the guise of calling it Grey Belt?

Developers also use the trick of citing ‘unviability’ on the number of agreed affordable homes in a development, after they have gained planning permission, and the Local Authority gives in, so as to keep the number of homes built within the approved number in their local plan, under pressure from Central Government to meet housing targets.

We have seen no evidence in Epping Forest District, to suggest that the planning determination process is being delayed or blocked by the local authority or interest groups or residents who raise legitimate planning points.  In any event, minor and major planning applications must be determined within strict time scales, or the applicant can apply to have the planning application determined by the Planning Inspector.  In this respect, we consider that the Government is fundamentally wrong to assign delays in planning to local authorities and third parties, and to propose a two-tier system of getting an ‘in principle’ outline decision followed up by the detail.  This removes the democratic process away from residents with local knowledge.  We consider that the Government,  at a political level, is following party dogma and spin in attempting to fix the so-called, broken planning system, which is not broken at all but controlled by developers, who game the system.  We look forward to firm legal action, which must be back dated, to ensure that developers are punished if they don’t build out.  ‘Use it or lose it’, and with appropriate fines, restrictions in considering new applications, etc, etc.

The Government’s NPPF Consultation does not robustly address the problem of the house build-out rate being, effectively, controlled by developers and not Local Authority Planning Systems.  We are, therefore, forced to conclude that many aspects of the draft NPPF proposals are driven by party political dogma – to be seen to be doing something, and are fundamentally flawed, especially with respect to allowing building on Green Belt land, by reducing its current level of protection, and making it easier for developers.  Whereas they should be focussing on a brownfield first approach and ensuring that the backlog of, already approved, planning permissions are built-out as a priority.

Is this proposed new NPPF all in aid of party political spin and hype?  The real issue of ensuring that developers build the right homes in the right places and in a timely manner, instead of land banking and profiteering, has sadly not been addressed.  The draft NPPF, as it stands, is a developers charter to line their own pockets, and at the expense of the openness of the countryside and by downgrading the current protection of our ‘precious Green Belt land.’

Please find below Theydon Bois Action Group’s response to your specific Questions 133 and 137, covering draft Green Belt Policies GB3 and GB7.  We also wish our narrative above to be taken into account as it relates to the overall thrust of the document and potentially to other questions in the full list of 225 questions.

Question 133:   ‘Do you agree with proposals to better enable development opportunities around suitable stations to be brought forward?’

We ‘strongly disagree’ with draft policy GB3: Altering Green Belt boundaries at point 1a- ‘This would enable the development of land around stations.’

Reason—We consider that this is something of a ‘knee jerk’ reaction by Government and has not been properly thought through.  It is another example of lowering the protection of Green Belt land, particularly if the land in question lies outside of the settlement edge of a village and with an established defensible and physical Green Belt boundary which is defined in the Local Plan and approved by the Government Inspector and voted in by Council.  It also goes against the concept of ‘brown field first’ in terms of potential and suitable development of brown field land/car parks adjacent to rail stations.  It is insufficient to imply that if a station receives 2 trains an hour (in one direction) in the Green Belt, then the surrounding land could be developed and removed from the Green Belt.  Full transport considerations, including capacity along the whole line, would be an issue, including any ‘knock on’ effect occurring further down the line with passenger overcrowding, etc.  Furthermore, in the Green Belt, the landscape character, sensitivity, and setting must be an issue, along with any potential impact on Heritage & Conservation assets.

Question 137:  ‘Do you agree policy GB7(1h) successfully targets appropriate development types and locations in the Green Belt, including that it applies only to housing and mixed-use development capable of meeting the density requirements in chapter 12?’

We ‘strongly disagree’ with draft policy GB7: Development which is not inappropriate in the Green Belt, particularly at point 1h (i) and (ii)– Development which is not inappropriate in the Green Belt; Development for housing and mixed-use development which would: (i) ‘be within reasonable walking distance of a railway station….’.  Also, we ‘strongly disagree’ with (ii)- be physically well-related to a railway station…’

Reason—We consider that it is inappropriate to be able to develop Green Belt land just because it is within reasonable walking distance of a railway station.  This is yet another example of trying to down grade the protection of our ‘precious Green Belt land.’

In conclusion, we consider that much of the draft NPPF, in its current form, is fundamentally flawed and driven by party political dogma and spin. The casualty would be the Green Belt, particularly around villages in a rural setting which just happen to have a station, and the problem lies with the developers who land bank approved permissions and don’t build out.  We contributed to the Government’s previous consultation on ‘Transparency on Build Out Rates’ and we expect to see Government take the necessary executive actions to ensure that developers build out the 1 Million Plus, approved permissions for building new homes.

Dr J Warren, Chair

Theydon Bois Action Group (Epping Forest District, Essex)

9 March 2026.

URGENT – Application Received for 150 Houses in Theydon Bois

Land adjacent to Theydon Bois Station, NPPF

An Outline Planning Application (with all matters reserved) has been registered at EFDC for development of the land adjacent to Theydon Bois Station, Abridge Road, Theydon Bois. The application number is EPF/0354/26. The proposal is for up to 150 residential units.

The deadline for making comments to EFDC is 23 March 2026. Comments may be made online under the EPF number link ‘Comments’ tab, or by post. Instructions for making comments are given on the EFDC website.

TBAG have not yet scrutinised the application but can say with certainty:

  • This is currently Metropolitan Green Belt Land.
  • The proposed development breaches the so-called ‘Defensible Boundary’ (railway line) of our village.
  • There do not appear to be any special circumstances to warrant despoilment of this agricultural land, some of which is a pre-eighteenth century field.
  • Development of this site was NOT approved for inclusion in our Local Plan which is valid until 2033.
  • There have been no changes to the Green Belt boundary around the village since adoption of the local plan and, typically, this could only be considered when preparing the next local plan.
  • No changes to the NPPF have been ratified which would override any existing local policies.
  • The development would be within the setting of, and detrimental to, Grade II listed farm buildings.
  • Our local infrastructure could not cope with hundreds more vehicles on the deteriorating roads locally, the many more places required at all levels of local schools and nurseries, more appointments which will inevitably be needed at doctors, dentists and local hospitals, etc.
  • The railway carrying passengers into Epping or London only will become even more overcrowded than it is at present, especially considering the poor service provided of late, with delays,  cancellations and apparently fewer trains.
  • Our bus service is very scant, at once every two hours, which does not provide a viable alternative to car or railway use.
  • The negative impact on Epping Forest Special Area of Conservation would be huge from increased pollution and footfall.
  • The negative effect for residents through the impact on our rural environment, our Dark Skies Policy, the loss of some green-field footpath and the loss of prime local agricultural land.
  • Any development on the other side of the railway line will only encourage other, neighbouring landowners there to similarly develop.  Theydon Bois will then cease to be a forest village and will become a town, comparable with Epping, but without the established facilities and transport links.

You are urged to make your own representations to EFDC on this application by 23 March 2026. If approved, it will irreversibly change the face of Theydon Bois. There are several documents submitted, but you are urged to do your best in understanding the proposal and making planning-orientated comments. As ever, statements like ‘I don’t like it’ are not planning considerations.

TBAG will update you when we have more information to share on this application.

If you haven’t already done so, please sign up to our emails, and encourage your friends and neighbours to sign up too so we can have more ‘clout’ when writing officially to EFDC.

Spring 2026 Update

NPPF, Updates, Village News

LOCAL PLANNING MATTERS

Appeal by 29 Piercing Hill EPF/0173/25 As reported in our last article, this application for demolition of existing side extensions and garage, construction of two-storey side and rear extensions and creation of basement, also to include an enlarged roofscape, of this locally listed, Metropolitan Green Belt, dwelling, was refused by EFDC. The applicant appealed this decision, and TBAG submitted a strong objection. The appeal was dismissed by the Planning Inspector on 20 January 2026. The main reasons for the Inspector’s refusal were: impact on the openness of the green belt, the effect of bulky additions on a heritage asset due to the proposed additions not being subservient to the host building, and the potential detrimental impact on the setting of the neighbouring group of locally listed Manor Villas, of which this property is one. From reading the report, TBAG believe that this inspector was a specialist planning inspector for heritage assets as well as having the usual extensive planning qualifications.

Green Belt Fields behind Theydon Bois Station, Abridge Road Following the somewhat disquieting confirmation from EFDC that an Environmental Impact Assessment (EIA) Screening Opinion – for a proposed residential development of up to 150 dwellings, associated infrastructure and landscaping – would not be required, no planning application has been received. The land is currently designated Metropolitan Green Belt in our local plan until 2033, and only Government changes to the planning regime would override this security. We understand that the same decision that no EIA is needed, has been taken for green belt farmland at Stewards Green Fields, Epping east.

GOVERNMENT PLANNING SITUATION

A further Government planning consultation concerning the Government’s National Planning Policy Framework (NPPF) is now open and closes on 8 March 2026. The NPPF has already been altered many times since it was first introduced on 27 March 2012 and it continues to evolve and its goalposts are constantly altered! TBAG will be submitting comments with particular reference to Chapter 13, Protecting Green Belt Land. TBAG consider that the proposed changes to this Chapter will downgrade the security and permanence of the Green Belt that we have today.

TBAG are strongly opposed to the Labour Government’s idea that all that is needed is to get a planning approval for “outline permission” and then fill in the crucial details afterwards. TBAG are of the opinion that this knee-jerk approach by Government will override local democracy by removing the right for Town and Parish Councils, interest groups and residents to comment, with the benefit of local knowledge, on specific aspects of yet to be disclosed detailed plans.

The whole thrust of the Labour Government’s planning policy changes is to allow developers to be able to obtain outline planning permission by default, claiming that this will speed up the planning process. Yet there are still 1.4m extant planning permissions for new homes as yet unbuilt by developers who landbank and drip-feed properties onto the market to keep prices high. Government appear to be deliberately ignoring this ‘elephant in the room’.

EFDC has commissioned a Green Belt/Grey Belt review by Arup, outside consultants, looking at which areas of green belt could be classed as grey belt, and their justification. Surprisingly, this review is being funded by Central Government! The completion date is to be the end of March. Epping Forest Heritage Trust are apparently very concerned about this review.

TBAG are fundamentally opposed to any local Government reorganisation that removes the freedom of local residents to object to any proposed developments in their area.

Winter 2025 Update

Government Consultations, Local Plan, NPPF, Updates, Village News

LOCAL PLANNING MATTERS

Blunts Farm EPF/1406/22 Change of use from agricultural barns to B8 storage and associated development. Withdrawn from the agenda for the 17 September 2025 Planning Committee and subsequently refused by the Officer on 22 September 2025. Reasons cited were: due to poor location being unsustainable development in terms of accessibility and highway safety issues being contrary to local and national planning policy.

Green Belt Fields behind Theydon Bois Station, Abridge Road EPF/2137/25 Request for Environmental Impact Assessment (EIA) Screening Opinion – Proposed Residential Development of up to 150 Dwellings with Associated Infrastructure and Landscaping. Developers are seeking to build on the two Green Belt fields behind our Station. The request was for EFDC to decide if an EIA Report was necessary and they have decided that they DO NOT need to provide an EIA. The planning consultants feel “there are limited potential impacts arising and those that will arise would not have a significant impact that would require an Environmental Impact Assessment”. TBAG informed the Conservators of Epping Forest of this application to ensure they were fully aware and also assisted the Parish Council by providing relevant information. TBAG will be watching closely should any formal planning application be made for these two Green Belt fields.

Appeal by 29 Piercing Hill This was an appeal against the refusal by EFDC to allow extensive demolition and rebuilding of this property. The Planning Inspector opened up the application to further comments and TBAG submitted comments supporting the refusal of the planning permission on this application which is in the Green Belt and proposed extensive alterations to this Locally Listed dwelling.

GOVERNMENT PLANNING SITUATION

In the Opening Statement to her Budget Speech, Chancellor of the Exchequer Rachel Reeves said, inter alia, “Over the last 16 months, we have overhauled our planning system to get Britain building;”. TBAG find this statement difficult to accept as the Planning and Infrastructure Bill has not yet been completed and ratified. TBAG also understand that there is due to be yet another revised version of the NPPF in the New Year. TBAG are disgusted that there still remain 1.4m extant planning permissions for new homes which the Government seem to be deliberately ignoring and are failing to legislate to demand that these homes are built out. It seems easier for them to demand 1.5m new dwellings and leave it to developers to decide the timing of these new builds. As TBAG have said many times before, developers have to organise their workload and will only build when it suits them and their response to the housing market from which they expect to return 15-30% profit on any development. It is well known that developers land bank and drip feed development onto the market in order to keep the price of new homes high. TBAG have expressed these views to our MP Dr Neil Hudson with whom we have an ongoing dialogue.

The Ministry of Housing, Communities and Local Government have launched a consultation on proposals for the reorganisation of local Government in Essex, Southend-on-Sea and Thurrock. The consultation will last for 7 weeks from 19 November 2025 to 11 January 2026, see here for details. TBAG would urge supporters and residents alike to respond to the consultation and give your views on the proposals.

TBAG are fundamentally opposed to any local Government reorganisation that removes the freedom of local residents to object to any proposed developments in their area.

TBAG would like to wish our supporters and all villagers a very merry Christmas and all the best for the New Year.

Autumn 2025 Update

Blunt's Farm, Government Consultations, Updates, Village News

LOCAL PLANNING MATTERS

Marcris House EPF/0507/25: Change of use from care home to residential and conversion to 8 x two bedroom flats. TBAG objected to this application on grounds of unsustainability, lack of safe pedestrian links to the village and other issues. This application has been REFUSED by EFDC Planning on grounds of loss of valued community facility, loss of specialist accommodation and employment, and the lack of a Section 106 Agreement protecting Epping Forest Special Area of Conservation.

Blunts Farm EPF/1406/22: Change of use from agricultural barns to B8 storage and associated development. TBAG reported on this in March of this year having raised an objection to this revised application. No decision has yet been made, but it appears that the Officer on the case is preparing to have this application heard before EFDC’s Planning Committee B in September October where our District Ward Councillors may speak but are no longer permitted to vote on this application.

Government planning situation

Further to TBAG’s letter to our MP, Dr Neil Hudson, regarding build out rates in England, we were pleasantly surprised to receive an immediate response. Dr Hudson kindly forwarded our letter to Baroness Taylor of Stevenage, Parliamentary Under-Secretary of State at the Ministry of Housing, Communities and Local Government. Baroness Taylor also responded promptly, sending several links which are yet to be fully explored. This issue is something that the Government is aware of and monitoring. Dr Hudson expressed his deep concern of the Government’s plans to release areas of the Green Belt for development, under their own subjective ‘grey belt’ definition, which in reality simply waters down all Green Belt protections. He also recognised that the Government are forcing top-down reforms whilst simultaneously silencing local voices by stripping council planning committees of their ability to consider applications.

Subsequently, two Government technical consultations, one on ‘Implementing Measures to Improve Build Out Transparency’ and one on the ‘Reform of Planning Committees‘ were launched and TBAG has responded to both of them. We were not happy just responding to the ‘tick-box’ questionnaire, because some questions were clearly leading. So, in addition TBAG wrote a narrative response to both entitled ‘The Planning Situation As We See It’. See  our responses to the build out rates and Planning Committees consultations. We mention in our response the issue of developers being fined £100m after the Competition and Markets Authority said they may be sharing commercially sensitive information that affects the price of homes!

Devolution plans for Epping Forest District Council trundle on with no apparent movement, but TBAG maintain that under a Unitary Authority the valuable local knowledge which is currently able to be input by residents and local Councillors will be completely lost and removed from the planning process. TBAG have expressed this serious matter in our consultation responses referred to above.

Local Public Footpaths

Residents may have noticed the deterioration in condition of several of our local public rights of way in the Green Belt surrounding our village. One path has had a bridge completely removed and another has two bridges in a precarious state. TBAG has written to the appropriate authority to report this and have been assured that the corrective work will be carried out in due course. We would encourage residents to explore our footpaths and appreciate our rural surroundings while one still can.

In Memoriam

TBAG would like to acknowledge the sad passing of Graham Law who was a staunch TBAG supporter from its inception and more latterly a member of our Committee. Our heartfelt sympathies go to his wife and his wider family.