South Epping Strategic Masterplan Framework and Design Code – Formal consultation on the strategic masterplan framework document (May 2024) and design code for the South Epping masterplan area (SEMA).
1. Epping Forest Heritage Trust
Epping Forest Heritage Trust (EFHT) is a membership organisation and charity dedicated to preserving and protecting Epping Forest, its flora, fauna, culture and heritage for people to enjoy now, and for generations to come. Our 1,000 plus members largely live in the various communities throughout the Epping Forest area. We have been engaged with, and committed to, the Forest for over 60 years and are a member of the Epping Forest Consultative Group run by the City of London Corporation.
Epping Forest is a hugely important ancient Forest, much of which is both a Site of Special Scientific Interest (SSSI) and a Special Area of Conservation (SAC), with iron age camps, 1,000 year-old trees and rare wood pasture habitat and species. It now faces the gravest threats that it has seen since it was first protected by the 1878 Epping Forest Act. Climate change, increasing levels of pollution, the acceleration of nearby developments and increased visitor numbers have led to a reduction in the biodiversity of the Forest (flora and fauna). Future development, including plans to build 68,000 housing units in its vicinity, further threaten its resilience through anticipated increases in visitor numbers and pollution. In addition, budget.cuts have meant that conservation, habitat improvement and maintenance are curtailed, and biodiversity is reduced.
At the same time the Forest has the potential to help us tackle the crucial issues of our time: it helps us tackle climate change by reducing temperatures and capturing carbon; it provides a vital amenity for people’s health and wellbeing as a space to walk, cycle, ride, relax and enjoy.
It is therefore essential that we protect and preserve the Forest not just for our own current enjoyment, but also for generations to come, and for the sake of the planet.
2. That is why we have the following comments on the Masterplan.
We recognise the need for new housing in the District, and that the development of the area is in the adopted Local Plan, but the development should still not be to the detriment of Epping Forest which is already being damaged by air pollution and increased visitor footfall. Natural England’s assessments of the Forest conclude that many parts of it are already in an “unfavourable” condition. Of the masterplan areas, the SEMA is the closest to the Forest. It is approximately 1km away from the main Forest SAC, and some 2.5km from the Lower Forest to the north which is an SSSI. It is only several hundred meters away from smaller Forest sites such as Bell Common and Shepherds Meadows. This proximity means that the development is likely to have an adverse impact on the Forest.
The adopted Local Plan and the accompanying Habitat Regulations Assessment (HRA) recognise that the Forest has already suffered damage from air pollution and visitor footfall and that robust mitigation measures are required if the many new developments in the District are not to cause further damage.
The need to protect the Forest is consequently reflected in a number of Local Plan policies, specifically DM2 on protecting the Forest SAC and, indirectly, through other policies including: Policy SP5 - Green Belt and Local Greenspace: Policy SP6 - The Natural Environment, Landscape Character and Green and Blue Infrastructure; Policy T1 - Sustainable Transport Choices; the other DM policies under the “Natural Environment and Green Infrastructure” heading; Policy DM20 - Low Carbon and Renewable Energy; and Policy - DM22 Air Quality. Action needs to be taken across all the above policies to ensure that the Forest is not damaged by the South Epping development.
While mitigation measures are also included within the Local Plan, these should not be relied upon as the sole means of reducing damage to the Forest. Every effort should be made by EFDC and the developers to ensure that the various contributors to causing the damage are minimised from the outset of the planning process. While the draft masterplan and design code are to be commended for proposing measures to mitigate the impact of the 450 to 550 new dwellings on the Forest, we still have major concerns.
3. Air Pollution/Traffic
Vehicle traffic is already causing air pollution damage to the trees and plants in the Forest. Additional traffic from this development using the local roads in, or close to, the Forest and the roads heading into London, and to the M25 and M11, will increase this.The Local Plan is clear that traffic volumes in the District as a whole are reaching capacity and that pollution is a problem in the south Epping area in particular:
“3.83 An initial analysis of traffic growth across the District has shown that even without development in the future, parts of the highway network will be operating over-capacity, in some cases by 2026 and in other cases by 2033.”;
“3.85 Traffic based pollution also plays a major role in contributing to issues in relation to the ecological health of the Epping Forest SAC and on human health within the Bell Common Air Quality Management Area in particular.”
EFDC’s Interim Air Pollution mitigation strategy of December 2020 seeks to mitigate these impacts on the Forest and states that:
“1.4 It is clear from the evidence that without appropriate mitigation development proposed through the emerging Local Plan, in combination with other plans and projects, would have an adverse effect on the integrity of the Epping Forest SAC as a result of atmospheric pollution. A key contributor to that atmospheric pollution arises from vehicles.”
However, the effectiveness of the proposed mitigation and performance measures, for example a reduction in pollution levels, has not yet been demonstrated, nor, as far as we are aware, has planning of the introduction of a CAZ been taken forward. It is therefore essential that all possible measures are set out in the Masterplan and the Design Code to reduce vehicle trips and to encourage alternative and more sustainable forms of transport. This would also contribute to EFDC’s aim, following the Council’s declaration in September 2019 of a Climate Emergency, of doing everything within its power to become a carbon neutral District by 2030.
The best way for EFDC to manage pollution levels coming from this site, and to keep them appropriately low moving forwards, is to absolutely minimise car use, through the appropriate design of the scheme.Future residents of the development should therefore be encouraged by the design of the development, from housing design and car parking provision to new road and walkway layouts, to walk and cycle to the town centre, schools, the Underground station and to the Forest itself, including providing safe and attractive routes for people to walk or cycle, rather than to use cars.
The introduction of sustainable transport measures will need to go beyond the development sites, as necessary, to ensure the onsite routes are linked with a wider path network and that there are safe means for people to walk and cycle into the town centre and Underground station. If this is not the case, any onsite measures will be ineffective.
We note that a “transport assessment” will consider both onsite and offsite travel but we believe these requirements should be firmly committed to in the Masterplan.In addition, the number of parking spaces provided in the development should be kept to an absolute minimum. The site’s proximity to the town centre and the Underground station presents an opportunity to move away from the Essex County Council set standards and, as stated in paragraph 3.94 of the Local Plan enabling EFDC:
“...to take a more locally focused approach to parking standards across the District.... These parking standards will be developed based on:... the different levels of current and future access to services and facilities across the District;”
Given the proximity of the town centre, we would envisage that parking spaces would be calculated at a much lower rate per dwelling than the County Council standard and believe that such a commitment should be stated in the Masterplan and not wait until planning permissions are submitted. The Trust is not opposed to car ownership but it must be recognised that pollution from vehicles is one of the greatest threats to the biodiversity of the Forest.
There are likely to be over 1200 people resident in the new development. Committing to the provision of onsite shops and health facilities within the new development and, crucially, to local public transport services including shuttle services, will be vital to help reduce car journeys into the town centre and the associated pollution. Consideration should also be given to how the wider public transport networks in the area, particularly bus services,
should be improved now there will be a larger local population and customer base.
These issues will, we understand, also be considered as part of a wider Epping Forest Sustainable Transport Strategy.
It is also essential to understand the forecasts of additional traffic movements both in the immediate vicinity of the development and also on the routes to the north and west to the various motorway junctions and into London, many of which go through the Forest SAC. It will be important to establish how these compare with the forecasts included in the HRA which accompanied the adopted Local Plan and, if they are higher, to establish whether additional mitigation is necessary.
Given the likelihood of increased congestion on the roads in the immediate vicinity of the development, the assessment should specifically look at traffic around the Bell Common area where air quality is already an issue. It will also be essential to ensure that ongoing pollution monitoring measures are put in place by EFDC, that the results of pollution monitoring are published promptly, and action taken to address pollution levels that are too high.
And while we note that there were 2,847 Electric vehicles in EFDC as at October 2023, this still represents less than 5% of the total of at least 59,000 vehicles in EFDC [ONS Census data plus House of Commons Library data on EV ownership by local authority]. We also note that, similarly to vehicles in EFDC, the vast majority of vehicles travelling to, through and around the Forest will continue to be polluting petrol or diesel vehicles for many years to come.
4. Reducing the likely impact of additional visitors to the Forest
We also want to ensure that there is sufficient, high quality green space created around the development for residents to enjoy, as well as provision for people to easily walk to the
Forest rather than drive to it.
The provision of Suitable Alternative Green Spaces (SANGs) and other green spaces is vital given the proximity of the Forest. The extent of green space proposed is welcomed but the areas need to be made attractive in order to reduce visits to sensitive Forest habitats where additional footfall, disturbance and fouling by dogs can have a major impact.
We are concerned, however, that the proximity of the M25 and the large electricity pylons next to the site will significantly discourage recreational use of the sites proposed. We note the proposed creation of bunds and installation of acoustic fencing but cannot see how they will sufficiently mitigate vehicle noise, and they will a minimal effect on the visual impact of the electricity pylons.
It also needs to be made clear that a binding commitment to the long-term management of the SANGs is required from the developers if they are to develop, and to be maintained, as attractive sites and consequently reduce the use of the Forest.If the proposed SANGs are assessed as likely to be ineffective in reducing visitor footfall in the Forest SAC, this will mean that the EFDC, as the competent authority, is not complying with the terms of the Habitats Regulations legislation. Natural England’s views on the adequacy of the SANGs will be vital.
At the same time, if residents are to visit the Forest, which we are sure they will want to, it would be much better for the Forest, and for their wellbeing, as well as for local road capacity, if they visited by walking or cycling rather than by getting in their cars and driving to the Forest. Serious consideration should also be given to providing high quality walking
access to the Forest on the existing public footpath, or on new routes, to the south of the site, in order to avoid residents travelling to the Forest by car.
5. Smaller local nature conservation sites
We are also concerned that the development will place additional visitor pressure on the small and very sensitive sites nearby including Ivy Chimneys, Bell Common and Shepherds Meadows. These sites are relatively small and it is unlikely that they will be able to accommodate increased visitor numbers without suffering damage. These sites are not covered by the normal visitor mitigation arrangements that apply in the Forest SAC and, where this land is Forest land, this needs to be considered in consultation with the Corporation of London, with adequate funding provided for the Corporation to mitigate impacts and to improve these specific facilities, as appropriate, for what is likely to be greater usage – for example for better paths and signage.
We believe the issues raised above need to be reflected, as appropriate, as requirements in the draft Masterplan and the Design Code to ensure they direct and inform the more detailed planning applications which will follow.
We recognise that mitigating the impact of this development presents major challenges for the Local Authority and the developers but, if this is not done to the fullest extent possible, and planned for from the outset, avoidable and lasting damage will be done to the Forest. On the other hand, if the development is planned well, car usage minimised, and walking
and cycling optimised, the development could become an exemplar for sustainable 8
development near a precious, protected site, and contribute to the health and well-being of its future residents.
Yours faithfully
Peter LewisChief ExecutiveEpping Forest Heritage Trust
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