The effects of air pollution on Epping Forest

This discussion paper is written by Edward Ward, EFHT’s Policy Volunteer

1. Introduction; air pollution and its effect the Forest

Before the passing of the final Epping Forest Act the greatest threats to the Forest’s integrity came from the encroachment of London’s suburbs and piecemeal enclosure by local landowners; the Forest was slowly being eaten away. Whilst the 1878 Act halted this, preserving the Forest as we now know it, there’s a new and growing threat to the health of the Forest: air pollution from the motor vehicles that pass through the Forest. Levels of pollution, i.e. ammonia (N02) and particulates from petrol- and diesel-powered vehicles, are now at levels that place the Forest’s status as a Site of Special Scientific Interest (SSI) and a Special Area of Conservation (SAC) at risk.

The  UK will, over the next 25 years, decarbonize its transport systems (Decarbonising Transport – A Better, Greener Britain (publishing.service.gov.uk ) and by doing so remove internal combustion engines and their pollutants from our roads.  Yet at the Trust we worry that this won’t happen soon enough to preserve the integrity of Epping Forest. We fear that a continued reliance on diesel and petrol vehicles and the growth of housing developments near to the Forest will increase the levels of traffic passing through the Forest, worsen air pollution, and further damage the Forest’s fauna and flora.

2. About this paper

To better understand the threat to the Forest from air pollution and what the Trust can do about it I will, in this paper, describe the sources of air pollution, how it is measured, and who is responsible for reducing it. I’ll then, in more detail, look at the effect of air pollution on the Forest, the problems of measuring air quality in and around the Forest, and what local authorities are doing to reduce air pollution in the Forest. Lastly, I‘ll make some suggestions as to what EFHT can do to reduce the threat of air pollution to the health of Epping Forest.

3. Air quality and Pollution in 2024 and how it’s measured

In London and SE England, the main sources of air pollution come from the heating of buildings, industry, and transport. Though overall levels of air pollution are decreasing, due mainly to changes in how homes are heated, the introduction of the Ultra Low Emission Zone in London, and the Euro 6 engine standard (1), there remain times when air pollution levels exceed the World Health Organisation’s (WHO) recommended levels.

Unfortunately, it’s not easy to know quite what the level of air pollution is or where it’s highest. Unlike the smogs of the 1950s, this isn’t pollution you can see. Though several websites provide data on air quality they rarely provide real time or truly local data.

4. Measuring and recording Air Quality and Pollution

In finding out about air pollution levels in the UK, London, or Essex I found these websites to be the most useful.

• Home – Defra, UK: DEFRA provide information on air pollution, has forecast levels and postcode searches. It also provides links to reports on Local Authority (LA) performance in reducing air pollution. DEFRA is also the body with overall responsibility for policy on reducing air pollution in England.
• Breathe London: an independent site which maps London’s air quality
• London Air Quality Network:  Run by Imperial College for the London Air Quality Network. Though it includes some Kent and Essex LAs neither Waltham Forest nor EFDC are members of the network.
• Air Quality Data – London Datastore  The Greater London Authority site.

Of the three London sites Breathe’s is perhaps the most helpful. It’s easy to use, provides some real time data and has a postcode search. You can make comparisons with the WHO guidelines and UK targets. Otherwise, getting hold of useful, relevant, and timely information on air quality in London is a challenge. Unfortunately, the same is true for Essex.

• Essex Air  contains data for Essex as a whole and maps air pollution in each district. It also contains each authorities’ air quality plans.

Having explored the Essex site I found that it contained little real time data for air pollution in the county. Only two local authorities currently provide this and neither of them are Epping Forest District Council.

Image: A104 Epping New Road runs through Epping Forest

5. Local Authority’s responsibility to maintain Air Quality and reduce pollution

The 2021 Environment Act required all local authorities (LAs) to improve air quality within their area and to publish air quality action plans (AQAPs) showing how this will be achieved. DEFRA, the Department for the Environment, Food, and Rural Affairs monitors the LAs performance. See the DEFRA website for more information on how this is done Local Air Quality Management (LAQM) Support Website | DEFRA

6. Our Local Authorities’ plans to improve air quality

The London Borough of Waltham Forest (LBWF) and Epping Forest District Council (EFDC) are the local authorities with the primary responsibility for monitoring and improving air quality within Epping Forest. They are also both “competent authorities” under the Habitat Regulations Act 2017 which gives them a separate but complementary responsibility to the protect those parts of the Forest designated as a Special Area of Conservation (SAC) which also includes a requirement to prevent air pollution from damaging its flora and fauna. There’s more on this role and SACs later in this paper.

The London Borough of Waltham Forest (LBWF)

Waltham Forest’s Air Quality Plan is here. Air Quality Action Plan 2023-2027_v3 LR_0.pdf (walthamforest.gov.uk).

Whilst there’s a welcome trend of better air quality across Waltham Forest you can see from the plan that there are elevated levels of NO2 in Chingford, especially on the border with the Forest. It’s expected that this will decrease following the extension of the ULEZ to the GLA boundary. Whilst there will be significant growth in housing in the borough (about 26,000 extra units) over the next 10 years, with much of it close to the Forest, these developments will be car free. Hopefully, this ought not lead to an increase in traffic through or around the Forest.

Epping Forest District Council (EFDC)

Epping Forest District Council’s plan is here Environment – Epping Forest District Council (eppingforestdc.gov.uk)

On the face of it, air quality in the Epping Forest District area is improving. None the less, I recommend looking at Appendix B of the plan which contains both source data for air pollution and pollution maps and notice the elevated levels of NO2 on the Epping New Road, especially at the Wake Arms. We know from Epping’s Local Development Plan’s Habitat Regulation Assessment (HRA) that vehicles using this road were less likely to meet the Euro 6 engine standard (i.e. they are not ULEZ compliant) and that about a third of them were diesel fuelled. There is more information on HRAs and their importance in the next section

And then there’s the Bell Common area, where the M25 goes under the Forest. This was designated as an Air Quality Management Area (AQMA) in 2010 and remains so to this day. Being an AQMA means that air pollution in an area has continually exceeded levels set by the government and the local authority must take steps to reduce it.

Epping Forest is designated as of national and international nature conservation importance, and contains a diverse mosaic of habitats, including Europe’s largest single population of ancient beech pollarded trees. Image: Beech in Epping Forest, Autumn 2023.

7. Air Pollution and the Special Area of Conservation (SAC)

As mentioned earlier, large parts of the Forest are designated as a Special Area of Conservation (SAC) under the 2017 Habitat Regulations Act. A SAC is an area containing internationally important natural habitats and/or species which are deemed to require a higher level of protection. The Forest was designated as a SAC because it contains:

• Inland water bodies (Standing water, Running water) (6%)
• Bogs, Marshes, Water fringed vegetation, Fens (0.2%)
• Heath, Scrub, Maquis and Garrigue, Phrygana (3.8%)
• Dry grassland, Steppes (20%)
• Broad-leaved deciduous woodland (70%)

Under the Habitat Regulations Act Waltham Forest and Epping Forest District Council are designated as “competent authorities which requires them “them to ensure that the integrity of the SAC is maintained.” Hence the link to their responsibility to reduce air pollution. Furthermore, before taking any decision that may affect the status of the SAC, for example housing developments, the LA must make an appropriate assessment of that development. These are known as a Habitat Regulations Assessment or HRAs, and both authorities completed Habitat Regulations Assessment when writing their local development plans. You can find them here:

• EFDC LDP: Epping Forest Local Plan HRA June 2021 final for issue CH v2.docx (efdclocalplan.org) and the Council’s adoption statement: Epping Forest District Local Plan 2011–2033 Habitats Regulations Assessment Adoption Statement (eppingforestdc.gov.uk)
• Waltham Forest’s LDP Habitat Regulation Assessment is here 2338 (walthamforest.gov.uk)

Both of the HRAs contain data on air pollution, it’s effect on the SAC, and what each council will do to protect the SAC. Any development with 6.5 km of the SAC area usually requires its own HRA.

8. Epping Forest District Council and the SAC

Given that the largest part of the SAC is within EFDC then the best source of information on air pollution in the Forest and the damage it causes has been in their LDP.s Habitat Regulation Assessment (HRA).

The full EFDC HRA is here: Microsoft Word – Epping Forest Local Plan HRA 2019.docx (efdclocalplan.org) .

It’s a long and detailed document as it also covers the Lea Valley SAC, for which EFDC is also a competent authority; but it’s rich in information on the Forest, the SAC, traffic levels, and the effect N02 air pollution has on the Forest.

Its key messages are:

• air pollution levels within the SAC may be dropping but remain unacceptably high
• air pollution from vehicles continues to damage and degrade the SAC especially beech trees, lichen, and moss within the Forest.
• there are concerns, shared by Natural England, about the effect of pollution on the sphagnum moss in bogs near the Wake Arms.

There’s also evidence to suggest that vehicles passing through the Forest are less likely to be Euro 6 compliant and the number of EVs remains low.

To mitigate and reduce air pollution within the Epping Forest SAC the HRA proposed the following:

• Minimise as much as possible any increase in traffic flows through the SAC.
• Introduce initiatives to support walking, cycling, and increased public transport use.
• Introduce initiatives to stimulate uptake of ULEVs.
• Introduce a Clean Air Zone (CAZ) covering the SAC from 2025.

However, based on what has been said by the leader of the Conservative Group on EFDC Council we think it’s unlikely that the Council will introduce a CAZ within the Forest in the near future. Their strategy remains one of supporting the increased use of EVs, relying on the increase in Euro 6 compliant vehicles, and supporting a switch to public transport and active travel. This is all contained in their Air Quality Action Plan –  see the Executive summary (eppingforestdc.gov.uk). We remain uncertain as to what progress EFDC is making in delivering this plan.

As was mentioned earlier, the Trust is also concerned that proposed developments at South Epping, North Weald, Latton Priory, and various nearby small-scale developments will both increase motor traffic through the Forest and, unless there’s a significant increase in electric powered vehicles, increase pollution.

9. Waltham Forest and the SAC

Waltham Forest’s Local Development Plan HRA can be found here: 2338 (walthamforest.gov.uk). In this case the challenge to the integrity of the Epping Forest SAC will come from the borough’s plan to significantly increase housing in the borough. Over the next 10 years LBWF aims to add an additional 27,000 units of housing to the borough. This is almost double the number of units planned by Redbridge or Newham and much of this additional housing will be close to the Forest. Although these targets may change with the new government.

Whilst most of these units are intended to be car free, it is possible we could see more traffic on Ranger’s Road in Chingford or towards Sewardstone. We can expect increased visits to the Forest.

Interestingly, EFDC’s HRA has some interesting data on the effects visitors and their dogs can have on a SAC; not all of them are good. Natural England  further explain the damage that can arise from an increase in visitor numbers in this paper written for EFDC Natural England Advice on the EF SAC

10. Monitoring Air Quality Action Plans and protecting the SAC

For a plan to be effective its delivery must be monitored. So how is each LA doing this: are they receiving regular reports on progress, what action will they take when objectives are missed?

But monitoring delivery is hard if you don’t have the data and, as we have seen from the national, London, and Essex air quality sites, it’s not always easy to get regular, local, and timely information on air quality. For EFDC to know how pollution from ammonia and particulates affects the SAC we need regular data on levels of these two pollutants on the roads going through or around the Forest. The same can be said for the records of the number of non-compliant Euro 6 vehicles passing through the Forest.

We understand that EFDC has recently monitored N02 levels laces at the Wake Arms and along the Epping New Road and it will be helpful for us to see the results. It would also be good to know if they intend to conduct a further analysis of ANPR data to establish if there’s any increase in the number of electric vehicles and if the number of non-Euro 6 compliant vehicles is decreasing.

To a lesser extent, the same applies to Waltham Forest, but they do propose to increase the monitoring of ammonia levels near SAC areas.

Epping Forest is considered to be ancient woodland. Image: Bluebells in Epping Forest. Spring 2024. 

11. Summary

As you can see, the Forest is being damaged by air pollution from petrol and diesel engines with the highest levels of pollution being found within the area of the SAC overseen by EFDC. To reduce pollution EFDC proposes to rely on encouraging a major switch to electric vehicles passing through the Forest alongside an increase in vehicles meeting the Euro 6 standard. If this fails, then EFDC’s Local Development Plan suggests that they should consider introducing a CAZ for the Forest.

However, the irregular monitoring of air pollution within the SAC makes it hard to know if this policy is succeeding.

We understand new air pollution monitoring data for the Forest is likely to be published soon, and look forward to seeing what it says, and what action EFDC intends to take on the back of it.

So, what can EFHT and its members can do to reduce air pollution in the Forest?

Our initial thoughts on the ways EFHT can make a difference are that:

• If members/supporters are interested we could set up an EFHT working group on reducing air pollution within the Forest with membership open to EFHT members and other interested individuals or groups. Let us know if you would be interested in getting involved.
• EFHT should monitor EFDC and LBWF action to reduce air pollution within the Forest and, in particular, look at how active travel can play a bigger part in visits to the Forest
• EFHT should try to work more closely with EFDC, the City of London Corporation, Essex County Council, and other interested bodies on understanding the levels of pollution along the Epping New Road and especially at the Wake Arms roundabout, and the impact of those levels on the Forest. This will necessitate having regular data on air pollution in the Forest, as well as the number of vehicles passing through the Forest, including how many are EVs and how many are Euro 6 compliant.
• EFHT should review pollution data as it is published to see whether EFDC and Waltham Forest are meeting their targets to reduce air pollution
• In order to reduce the number of vehicles on the Epping New Road EFHT continues to ask for better public transport to, from and around the Forest.

EFHT should play as full as possible a role in the development of the next sustainable transport strategy for the Forest.

Notes:

1. More information on the Euro 6 Engine standard and Euro Engins standards in general can be found here. European emission standards – Wikipedia. It’s interesting to note that a Euro 7 standard has been proposed which will include a restriction on brake particulates.

You may also be interested in