Epping Society Response to Proposed Latton Priory Development.

Response from the Epping Society to the Latton Priory Planning Application EPF/1793/24

Dear Sir / Madam,

The planning subcommittee of the Epping Society, after consideration, wishes to make the following Comments:

1050-1340 new dwellings, local centre, health facilities, new primary & site for new secondary schools, SANGs, vehicle access via Rye Hill Road & London Road.

Firstly there 6 pages of c. 20 documents each. The consultation period  (11 October) for reasonable consideration of this application is unrealistic. The public and various bodies involved should have an extended period to give this a fair viewing.

Design & Access Statement (DAS) 1

3.37 “the Central line in Epping is likely to be a popular route for travel to London”, but no assessment of possible numbers. This is a main basis for our concern, see Discussion later.

3.34 “Cycling will only be for confident cyclists at present” Agreed! Local roads are narrow, with no possibility of bike lanes.

That and the distances to key services make estimates of Modal Shift optimistic. There are precious few successful examples (outside urban areas), where modal shift has been significant; those have had huge investments in walk/bus/bike infrastructure both within and beyond the target area. Kenilworth – much quoted - is semi-urban with new bridges, lanes, routes to centre.

DAS2 Section 4 “lack of capacity on …Epping Road”. It is therefore outrageous that EFDC should even have to consider an application which adds to a known problematic situation.

DAS4 Section 6 –  a new junction on London Road (number J43), car exit only to the left (ie North) & traffic lights, & special arrangement for buses.. How to stop drivers spinning in the farm gateway, or using McDonalds, or going around the roundabout?? This design might mitigate the new junction, but will have an unknown and probably limited real impact on increased Southbound traffic.

Traffic Assessment 9.19 does not asses likely traffic from J43 Southbound – because of left-only turn! No attempt to assess increased traffic as drivers do the spin around.

In the Local Plan Public Hearings, Inspector Louise Phillips noted that she “would not want to see the London Road as a main access for Latton Priory”. This did not appear in the final written Report.

New 40mph limit – how far? Why? Again it may mitigate the junction, but not ease congestion, nor make cycling safer.

The Transport Assessment makes much mention of the proposed Sustainable Transport Corridor (STC) from Latton Priory into Harlow centre. Later we read that it is a long-term aspiration, “in due course”, “not in the short term”. Further we read that the lack of such an STC would have minimal impact on travel patterns..if so, why was it planned? Why did it feature so heavily at the many Master Plan & Consultation stages?? It was made out to be the solution to transport problems; now we surmise it will never happen.

Transport Assessment (7.8) suggests 1900 vehicles out in AM rush, 2100 vehicles back in PM. Yet the possible midibus service might initially be one per hour (in 6.15). We think these estimated figures are too low; with 1000+ new dwellings, and little employment on the estate, many will commute. Looking at the school run, no account has been taken of the existing local pattern of parents not seeking the nearest school for their children. Also many new residents will be moving “out” partly to get what they believe will be greater freedom of movement.

We have concern about the Vision-based philosophy behind transport infrastructure; rather than a Predict and Provide mindset. The former seems to fail with unerring regularity. As an example, when parking provision in developments is kept low to “reduce demand”; the result is cars on pavements and grass areas, spoiling the architect’s lovely sketches! Local examples include the recent project in Epping called the Arboretum, also Walter Mead Close, in Ongar. Once it is realised that the behaviour of residents does not match the Vision of the architect, it is too late, and the development loses function and appeal. A sequence of “built to fail” is established.

Discussion. Reflecting back to DAS 3.37, the Epping Society considers that many of the likely numbers of cars moving London-wards will want to travel South down the London Road, particularly seeking the Central Line connection in Epping, because:

·       The Tube fare is substantially less than Rail

·       Oyster ticketing is more convenient at subsequent changes

·       Trains are much more frequent

·       Epping being the start of the line there is a greater chance of a seat

·       Links from the Central into other lines eg Overground, Elizabeth etc are more numerous and convenient than Rail

·       Many new residents will have come from the Northern part of Greater London, or inner Essex, they will have a natural affinity for tube travel, it being their dominant experience.

·       The M11 alternative is often congested at the M25 interchange, and the London end is fed into A12, N. Circular etc; the A406 is often at a stand-still in rush hours.

·       Harlow railway station is not easily accessible; roads are congested, buses slow. This problem will be exacerbated by the non- delivery of the STC.

However the Southward option to the Tube system has many problems:

·       Rush hour tube trains are over capacity from 2 or 3 stops down the line

·       Rolling stock is old & unreliable, it is an unpleasant experience

·       Significant improvements to the system are unlikely for many years (TFL email, presented to the Local Plan)

·       Epping station building is already over capacity, especially in the evening as a trainful of passsengers head for just two exit gates

·       The station approach is heavily congested with cars, buses, taxis; plans to remodel this are many years and millions of pounds away

·       The station car park is generally full by 7am or so; all adjacent roads are Parking Control Zones

·       The London Road B1393 is extremely congested; road and junctions being beyond capacity (Ringway Jacobs data for the Local Plan). Progress at rush times being little faster than walking, from Lower Wood / The Plain, sometimes as far as Bell Common.

·       This increased car congestion will impact further on bus journey times – but there appears to be no assessment. Roads are too narrow for bus lanes.

·       Most of the pavements quoted are overgrown and even if cleared are too narrow for a pram. Lorry wingmirrors overhang them.

·       This congestion on the B1393 will lead to drivers seeking “side routes”, such as Upland Road through Epping Upland, or even East via Coopersale. These are narrow twisting country lanes. No assessments are offered.

·       The alternate exit from Latton Priory, Southwards, is Rye Hill Road which can still lead to the London Road.

·       Southbound traffic heading South, but not attempting to reach Epping tube, has to go through Epping Forest SAC. In the Local Plan – no development is permitted which will increase traffic/ pollution therin, without mitigation measures. Not considered in the application.

Lastly, two other issues - Affinity Water report supply problems, and demand water efficiency strategies. This is water companies making life difficult for all because they have not planned nor invested, but it indicates that meanwhile, we are looking at regional overdevelopment. Some developments in South Essex have been postponed for this reason.

The proposed secondary school provision is described in some places as a “site for..”. this could have several meanings, but could suggest that such a build is not guaranteed?

Therefore the Epping Society wishes to Object to this Application.