Urgent Update March 2023

Local Plan

COUNCIL TO VOTE BUT PLAN UNSOUND

The Planning Inspector examining our Local Plan has submitted his final report declaring the Plan ‘Sound’. TBAG are not satisfied that this Plan is sound for several reasons (see below). The submission version Local Plan is to be discussed at an EXTRAORDINARY GENERAL MEETING of the Council next Monday 6 March 2023 at the Civic Offices. Your elected local District Councillors may vote either for or against adoption of this Plan and we would urge our supporters to lobby these Councillors and ask them to vote AGAINST adoption, on the grounds that this Plan is UNSOUND in its current state and should properly be revised. Your Councillor’s contact details are below. Note also that there is to be a demonstration organised by The Epping Society at 18:30 on Monday 6 March outside EFDC Civic Office, Epping which you may wish to join.

Theydon Bois Action Group believe that this plan is UNSOUND and would comment as follows:

  • As TBAG have been citing for several years now, the Plan proposes too large a number of new dwellings (11,400) based on out of date, nine-year-old Office for National Statistics (ONS) data. EFDC refuse to use the 2016 and 2018 ONS figures plus the 2021 census figures which would mean less than HALF this number of new homes are actually required in our District.
  • The majority of these proposed dwellings would therefore have to be built on our precious Green Belt land which the Government had previously declared as being “absolutely sacrosanct”.
  • TBAG have major concerns about the impact of the proposed number of dwellings upon the integrity of Epping Forest SAC with respect to visitor numbers and air quality issues. EFDC propose to mitigate against this excessive number of houses, and the knock-on effects caused by them, by the introduction of an aspirational scheme of making a Clean Air Zone along Forest roads. This will only cause resentment and even more pollution when drivers detour to avoid these charges or be obliged to pay £12.50 per day.
  • There is no guarantee that the dwellings to be developed will meet any of our District’s needs. Developers historically prefer to build executive homes (which will have lovely Green Belt views) to see the greatest return on their investment. This district does not need more executive homes – it needs affordable homes.
  • TBAG do believe that the concerns of the original Inspector, Mrs Louise Phillips, about the impact that development on this scale would have on the Forest, have not been addressed. Instead, it is proposed that development to within 400m of the Forest shall be allowed and closer still if a ‘case’ can be made. So much for protecting our Forest.
  • TBAG do not believe that taking cash from drivers and installing chemical absorption pits to allegedly remove oxides of nitrogen etc., are the ways to protect our Forest. The only way to protect the Forest from atmospheric pollution is to reduce the excessive number of dwellings proposed in this Plan and their resultant emissions.
  • Since the conception of this Local Plan, Government have done a policy ‘U’ turn on planning, accepting that Green Belt land should not be built on to meet housing needs and that this need should be determined by actual local needs and not top-down, inflated figures imposed by Central Government.
  • Government are currently consulting on further changes to the National Planning Policy Framework which is used as a basis for formulating Local Plans, particularly with regard to housing numbers. TBAG feel the proposed Local Plan should now be held in abeyance until these new Governmental policies are made otherwise our new Local Plan will be out of date too soon after adoption, to the detriment of our District.
  • Many Tory MPs voiced discontent with the excessive and enforced housing numbers, and loss of Green Belt and surrounding countryside, and rebelled against the Government’s proposed White Paper on planning policy and then forced amendments to the current Levelling up and Regeneration Bill currently going through the House of Lords.
  • TBAG has long thought that the excessive number of dwellings proposed by Government is purely a quest to raise the general level of economic activity through development and its supporting supply chain to overcome the effects of the original 2008 recession. This is despite the fact that there are already 1.2m extant planning permissions on land banked by developers which have not been built out.
  • Michael Gove, Secretary of State for Levelling Up, Housing and Communities and Minister for Intergovernmental Relations, wrote to all Conservative MPs on 5 December 2022. He said, inter alia, that reforms have been made e.g. “scrapping policies like top-down regional targets that built nothing but resentment”. And of the Green Belt he confirms that “we will be clear that local planning authorities are not expected to review the Green Belt to deliver housing.” “This is in line with commitments made by the Prime Minister in the Summer.” “The effect of these changes will be to make absolutely clear that Local Housing Need should always be a starting point – but no more than that – and importantly, that areas will not be expected to meet this need where they are subject to genuine constraints.” Epping Forest District is very much constrained by being 92% Green Belt and the Forest SAC.
  • Most importantly, Michael Gove MP went on to confirm in his letter that “Where authorities are well-advanced in producing a new plan, but the constraints which I have outlined mean that the amount of land to be released needs to be reassessed, I will give those places a two year period to revise their plan against the changes we propose and to get it adopted.” EFDC should take full advantage of this two-year transition period and revise housing numbers in the District and their sites to properly reflect need, protect our Green Belt and the Forest SAC. There can be no excuse for not taking advantage of this Ministerial statement.
  • In a House of Commons debate on 20 February 2023, Michael Gove MP reaffirmed his commitment to protecting the suburban Green Belt and to ensuring that communities receive the new homes that they need.

TBAG would strongly urge supporters to approach their elected District Councillors (contact details below) to impress upon them that blindly voting politically to adopt this local plan will be letting down their residents very badly in the light of Michael Gove’s December letter which gives EFDC every chance with a two year transition period for them to revisit the required housing numbers in our district using the latest ONS statistics (not outdated statistics) and REDUCE the number of dwellings to be built in our district up to 2033 AND to take into account the obvious constraints this district has being 92% London Metropolitan Green Belt. This will at one fell swoop not only protect our Green Belt and our Forest, but will also put the housing where it is needed and in the numbers and types that are needed and not in the volume that will bring favour from developers and increased revenue through new council tax payments etc. without providing supporting infrastructure (schools, doctors, shops etc.). It’s our district and we must be heard that we want it to stay green and pleasant and not concreted over and lost forever. If we do not need the volume of houses proposed, why should we lose Green Belt to accommodate them? We will never get that Green Belt back, and if ‘alternative sites’ of green belt are allocated to compensate for such loss, what good will that be to us, the residents who live adjacent to the existing Green Belt?  Pushing the Green Belt out further from London does not compensate residents, nor does it appeal to Londoners who choose to visit our countryside for their recreation who will then have to travel further to reach it WITHOUT the convenience of the London Underground, and likely increasing emissions in the process. Our Epping Forest District Green Belt has been in existence for nigh on 90 years and while not all of this land is especially scenic nor necessarily possessed of a wild and romantic beauty, it is its undeveloped character that is of importance. The aim of Green Belts was not as long-term land banks for developers, but to resist the pressure to build, and it is this point that EFDC seem loathe to recognise. Moreover, Green Belts everywhere are a wildlife resource remaining vital not only for ecosystem services it provides for humanity, but also the natural world’s intrinsic right to exist. As climate change causes animals and plants to migrate as their climatic niches move, it is vital to retain linked green areas for corridors for these animals and plants. We must remind Councillors and EFDC of these points.

Councillor Clive Amos:
Phone: 01992 813876
Email: cllr.camos@eppingforestdc.gov.uk
Address: 37 Woburn Avenue, Theydon Bois

Councillor John Philip, Finance Portfolio Holder:
Phone: 01992 812473
Email: cllr.jphilip@eppingforestdc.gov.uk
Address: 28 Woodland Way, Theydon Bois