Waltham Forest Local Plan Part 2-Consultation on the Main Modifications to the Plan

Updated: 18th September 2025

Members will be aware that the Local Authorities in which the Forest is located are planning the building of thousands of new dwellings to meet central Government targets. The Trust is concerned about the scale of these new developments (at least 65,000 new homes over the next 15 years) which will increase recreational pressure and air pollution in a Forest which is already being damaged by the current levels of use without sufficient mitigation, and vehicle traffic.

In 2024 Waltham Forest Borough Council (WFBC), which has many of the areas of the southern Forest within its boundaries, published Part 2 of its Local Plan “Site Allocations”, which is used to determine which sites in the Borough are designated for housing and commercial development as well as those for recreation.  This is approved by the Council and by central Government, and the Council is currently consulting on the changes to the Plan required by the Planning Inspector.

Part of this process requires WFBC to carry out a Habitats Regulations Assessment (HRA) to assess the impact of developments on the Forest and to propose mitigations to any damage the developments would cause. This is considered by the Government’s conservation body, Natural England.

The Trust commented on the original Site Allocations Plan. We voiced our concerns that the sites earmarked as Suitable Alternative Natural Greenspaces (SANGs), which are designed to attract recreational visits rather than the Forest where the more sensitive habitats are located, were largely on the western side of the Borough and so would not offer practical alternatives to residents living on the eastern side who would be more likely to use the Forest.  Natural England advised that the proposed SANGs met the agreed criteria.

We also commented on the impact of there being a significant number of proposed developments very close to the Forest.  This can bring additional problems, and Natural England has agreed a package of measures to mitigate the impacts with the WFBC and the City of London Corporation (CoLC).

We remain extremely concerned about the impact on the Forest of the scale of development in Waltham Forest, which will increase the number of dwellings by 2035 by around 30,300 to meet the Borough’s housing requirement of 27,000 homes.

While it is debateable whether any mitigation measures can entirely compensate for growth of this size it is nonetheless essential that WFBC and CoLC deliver as soon as possible the various measures required to mitigate the impact of the new developments including improving the path network, protecting the more sensitive areas of the Forest and ensuring visitors are aware of the sensitivity of the Forest and, importantly, of their responsibilities to act respectfully towards the Forest as visitors.

If the additional pressure on the Forest is not managed effectively, we risk further damaging its biodiversity, as well as losing its “natural aspect” to the point that it might become more a park than a Forest, and no longer provide a sense of wilderness in the heart of London.

Notes:

• Image 1: Waltham Forest Local Plan Part 2: Sites Allocations Cover. Credit: Waltham Forest Council. Source: Local Plan Part 2 – Proposed Submission Version (2024)
• Image 2: Waltham Forest Green Spaces and Places and proposed Suitable Alternative Natural Green Spaces (SANGs). Credit: Waltham Forest Council. Source: Suitable Alternative Natural Greenspace (SANGs) Strategy 2024.pdf

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