The Epping Forest District Plan and how it could affect Epping Forest

A response from the Epping Forest Heritage Trust.

 

Introduction

Epping Forest Heritage Trust (EFHT) exists to protect, conserve, grow and celebrate the Forest’s biodiversity, heritage, and culture, and to engage, educate and inspire other people to do the same.

This paper sets out the Trust’s response to Epping Forest District Council’s District Local Plan for 2023-33.

 

epping forest district council local plan

The Epping Forest District Local Plan

On the 6th of March 2023 Epping Forest District Council (EFDC) adopted its District Local Plan (DLP) for 2023-33. The DLP (EFDC Local Plan – Planning our future ) is the Council’s strategic framework for housing, commercial, and industrial development across the district over the next 10 years. In short, it describes where development will happen, what type, and how much. For EFHT this is a vitally important document containing, as it does, the Council’s obligation to protect the Forest when making decisions about these developments.

Within the plan are proposals to build 11,400 new dwellings in the EFDC area. This growth in housing could see the number of households in the district rise from 54,600 to 66,460 by 2033; an increase of 21%. As each new household can be expected to have 2.3 residents then this growth in housing is likely to increase the population of EFDC by over 20,000 people. As the most common form of transport within the district is the car then we can expect the levels of vehicle traffic to, through and around the Forest to also grow. For the foreseeable future the vast majority of those vehicles will be powered by internal combustion engines (ICE).

The plan also proposes further industrial development in Waltham Abbey and the commercial development of the district’s town centres. Similar levels of growth in housing, industrial, and commercial development are planned by the councils adjoining EFDC, most notably in and around Harlow. Again, we believe that these developments will increase the levels of vehicle traffic in and around the Forest.

Epping Forest, the DLP, and the Council’s duties under the Habitat Regulations.

Epping Forest and its buffer lands make up 7% of EFDC’s landmass.

The Forest is designated as a Special Area of Conservation (SAC). As it is a SAC under the Habitat Regulations, EFDC have to show that the DLP will not have an adverse effect on the Forest’s SAC status, or do anything that prevents the SAC from meeting its conservation objectives. Furthermore, the regulations require EFDC to conduct a Habitat Regulation Assessment (HRA) that shows the DLP will not have a detrimental effect on the Forest’s status as a SAC.

EFDC’s HRA can be found here: https://www.eppingforestdc.gov.uk/wp-content/uploads/2023/03/EFD-Local-Plan-2011-2033-HRA-Adoption-Statement-140323.pdf

epping forest

The Forest is currently under stress.

Though the Forest is protected by its status both as a SAC and as a Site of Specific Scientific Interest (SSI Site of Special Scientific Interest – Wikipedia) it is still an environment under stress. One example of this is the harmful effect air pollution from vehicles is having on the Forest – for example on the trees and lichen – see EFDC’s Air Pollution Mitigation Strategy for the Epping Forest SAC (EB212-Final-Interim-APM-Strategy-for-EFSAC-101220.pdf (efdclocalplan.org)) for more information on this. As we have already mentioned, the DLP’s proposals for new households and further industrial and commercial development are likely to increase traffic levels in and around the Forest.

Alongside the HRA, EFDC has several other plans relevant to mitigating the effects of air pollution caused by traffic. They include their Clean Air Plan (Air Quality Action Plan 2023- 2028 Consultation – Epping Forest District Council (eppingforestdc.gov.uk) and the Climate Change Action Plan – Epping Forest District Council (eppingforestdc.gov.uk). That latter plan points out that 65% of EFDC’s carbon footprint comes from transport emissions. Reducing transport emissions and the district’s carbon footprint go hand in hand.

However, EFHT is not wholly convinced that the proposed actions in the Council’s plans will be enough to offset any increase in air pollution from petrol and diesel-fuelled traffic. There’s a great reliance on an uptake in Electric Vehicles (EVs) to reduce increases in pollution and reduce the district’s carbon footprint from transport emissions. Given the current slow uptake in EVs, not least due to their cost and the cost-of-living crisis, we would like to see stronger commitments and more action by EFDC to support active travel and provide more and better public transport in order to reduce car journeys to, from, through and around the Forest.

If pollution levels remain high, continuing to damage both people and the Forest, then EFDC may need to make the Forest a Clear Air Zone (CAZ).

 

EFHT’s response to the DLP: collaborating with the Council and others to enhance and preserve Epping Forest.

EFHT welcomes the Council’s commitment to protect the Forest and the action it is proposing to take through the DLP, its Climate Change Plan, and Clean Air plan to help preserve and enhance the Forest’s unique landscape. Nonetheless, EFHT is concerned about the negative effects the DLP’s proposals for increased housing and commercial development could have on the Forest.

We would, therefore, like to see EFDC:

  • implement the recommendations of the 2020 Interim Air Pollution Management Strategy for the Epping Forest SAC.
  • provide regular and accessible information on air pollution and traffic levels in and around the Forest.
  • do all it can to speed up the transfer from to EV vehicles.
  • monitor the effect the growth of households, industrial, and commercial developments are having on traffic and pollution levels in the Forest and to takes steps to mitigate any increase in air pollution arising from this.
  • regularly refresh the HRA and amend it when it is shown that the implementation of the DLP is compromising EFDC’s responsibilities under Habitat Regulations to preserve the Forest as an SAC and an SSI.

 

Epping Forest Heritage Trust June 2023.

 


Our previous response: 

To view our previous responses, please click here: EFDC Local Plan: Consultation on Further Main Modifications (efht.org.uk)