Preservation Society EERA News

The Theydon Bois & District Rural Preservation Society has been monitoring the development of this plan. The consultation phase for the plan is now open and we are considering our detailed response but believe that it is important that as many people as possible submit a response before the closing date on the 16th March 2005. A copy of the plan in pdf form is available to download here and we have added a number of useful links below to help you respond. We hope to up date this page with our views as we work on our response. The first report is one to our committee made by Peter Newton & Jim Watts who attended some of the first consultation meetings.

East of England Plan

The file size is 2.7mb and download time should be about 12 minutes on a 56k dial up and about 1 minute broadband. We suggest you right click the link above or those below and select Save As.

Non Technical Summary of the Report of the Sustainability Appraisal
(pdf 189Kb) Report of the Sustainability Appraisal

Report of the Sustainability Appraisal (pdf 1.3Mb)

Please make a response to this plan either on the EERA web site or download the EERA Word document response form to post here.

You may find that if you wish to make more general observations on the plan that our own Word reply form is more user friendly. General Reply Form.

Representation on the East of England Plan
from Theydon Bois and District Rural Preservation Society.

Policies SS1 & SS10:
The notion that 478,000 homes and the creation of 421,000 new jobs are needed in the South East of England is totally misguided. The South East is already 'overheated' economically and the region's environment, natural resources, character and quality of life are already showing adverse affects as a result of the pressures this has brought. The scale of development proposed will not be sustainable. The problems of social inclusion and deprivation are "key issues" but these need to be focussed nationally. There is a real need to encourage economic development in the North and West of our country and these are the areas where any large-scale growth should be planned. Here deprivation and social exclusion are still high and there is a real need for new jobs and regeneration around urban centres. If this fails to take place and further development is encouraged in the South East the population drift to the this part of the country will continue with disastrous environmental consequences for the South and further deterioration in the North.

Policies E2 & ST2:
The figures of 421,500 new jobs for the region as a whole and 116,000 for Essex are totally unrealistic. The regional share of jobs would need to increase from 12.5% to 21% to achieve this target. The details of how this increase in new jobs will be achieved are not adequately explained and the Bone Wells Associates analysis has largely been based on 'selective' historic precedents which are not a safe guide to future trends.. They are further contradicted by other studies. The Harlow area has lost 20,000 jobs in recent years.

If the proposed jobs do not materialise and the growth in dwellings is allowed to proceed or has already taken place then the result will be even greater amounts of commuting by road and rail on links that are already over stretched. The job numbers for Essex are not based on need but on the further growth areas, clearly a chicken and egg situation. Again such growth areas need to be located further north where there is a real need for further employment.

Policies SS13 & ST4:
The proposed 478,000 housing units are not justified, as realistic job numbers do not support them as described in Policy E2. Such numbers would not be sustainable and would severely impact unfavourably on the environment, and quality of life in the region.

Although it is clear that some affordable homes are needed in the region, these should only fulfil the needs of the region's present communities. The large numbers proposed have been arrived at by a discredited 'predict and provide' approach and an untried methodology. There is no indication as to how 'affordable homes', even if in the first place built cheaply using government owned land, will resist long-term market forces. The proposals to extend 'the right to buy' or partial ownership to Housing Association tenants would soon see house prices rising well above any affordable levels for low-income families in the South East. Essex is already 30% behind in its provision of affordable homes because of market and other pressures.

123,000 new dwellings in Essex is excessive and represents an 18% increase on current planned levels and is higher than other counties. The Epping Forest District will see a 37.5% increase in proposed housing levels, more than double all other areas excepting Maldon at 26.3%. This figure is clearly in conflict with the other stated objects of the plan as in SS1, SS4, SS7, SS9, ST2, Map 7.1 &ENV9. Of this number of dwellings 80% would have to be built in the Green Belt and the 2,700 to the South & West of Harlow would be a 100% on Green Belt land.

If 6,000 houses are allocated to North Weald, currently only 1,800, using the plans own definition of a similar number near Cambridge, it would be considered a 'New Town'. These proposed developments would stretch north as far as the M11, junction 7 and adjoin an expanded Harlow and to the South West would also be less than 2 miles from Epping. This would result in a virtually continuous built up area from the edge of Epping Forest to the northern limits of the expanded Harlow, forming a massive barrier in the London Arc. It would swamp the separate communities of North Weald, Thornwood and Hastingwood and these would no longer then have a separate identity.

With no proposed road improvements to the south of North Weald and no improvements to rail infrastructure the narrow winding lanes that pass through Coopersale, Theydon Bois, Fiddlers Hamlet etc. would become shortcuts causing parking and traffic chaos in these villages and overloading the Central line services at Epping and Theydon Bois. To stop such commuter madness the North Weald development would need to be self sustaining with the required number of jobs in place first, but nowhere is it stated that in this specific location these jobs will precede the house building. The almost certain result of a development on this scale at North Weald will be that it will become a dormitory town for London Commuters.

The plan with regard to its proposals for the Epping Forest District should be scaled back to a more realistic figure of 5,000 new dwellings. This could be achieved by continuing the present rate of house building up to 2021. This would also be more in keeping with house building levels in other parts of Essex. It would also be less likely to breach the limit of 60% of housing on Brownfield sites.

Policies SS6 & ST6:
It is already recognised that many of the strategic highway routes and many more of Essex's local roads will be heavily congested by 2016 even without further house building. Although the plan does propose a number of transport improvements in Essex it is far from certain that these will be delivered on time or ahead of housing provision. Strategic rail routes have inadequate capacity and future rail investment at the level needed seems unlikely. EERA at this present stage will not endorse their own plan because the government will only commit to a quarter of the £1.5 Billion needed for the first three years of transport infrastructure alone. None of this reduced allocation is designated for Essex. As previously stated a lack of transport infrastructure will result in traffic chaos and gridlock in the Epping Forest District and throughout Essex.

Policies SS12, ENV9 & ENV10:
The historic experience for Essex has been that in recent decades there has been insufficient infrastructure with regard to Hospitals, Education, Transport, Emergency Services, Water Supply and Waste Management etc. A lack of skilled essential staff; Doctors, Nurses and Teachers etc further exacerbate this. The Plan glosses over the detail of how this infrastructure will be provided to meet the needs of a much-increased population. At present there are insufficient Doctors, Teachers etc. in training to meet current needs let alone the South East's increased needs under the plan. Will the intention be to 'poach' these skilled people from other areas leaving them deprived in this provision?
Key water infrastructure projects such as the Abberton Reservoir extension have not yet received planning permission and even if approved will have long lead times. Essex is the driest county in the country, already struggling to meet current needs. It is vitally important that how the method of supplying adequate sustainable water supplies that do not cause environmental damage are to be met, is spelled out. The plan lacks all detail on how this key provision is to be met.

With waste management the plan again (9.51) merely indicates that Local Authorities will need to ensure their development plans, framework and documents reflect the aims and policies of the plan, but it in no way indicates how the Local Authorities will be able to achieve this. It does though say "That failure in this respect will undermine the ability of the region to achieve its aims".

Policy SS7:
Many parts of the plan seem to be in conflict with others and the Sustainability study when it comes to the Green Belt. S.E.A. Chapter 14 states; "The baseline shows that a number of aspects of the environment-area are already seriously stressed by human impacts. Further development on any significant scale is likely to have serious negative impacts on water resources, biodiversity, tranquillity, air quality, recreational access and congestion. The larger the volume of development the harder it will be to avoid increased flood risk, erosion of the quality and distinctiveness of settlements, the built environment and landscape".

The London Arc Green Belt is already suffering from these environmental pressures with Epping Forest being particularly at risk from air pollution caused by traffic congestion and its inability to maintain its biodiversity. The level of development proposed for Epping Forest District will require 80% of the dwellings to be built on Green Belt land (note the North Weald site is all Green Belt and not a mixture of Green Belt and Brownfield as suggested) the proximity of all this development to the forest with the resulting pollution would eventually result in its death.

The plan indicates that areas taken out of the Green Belt will be replaced by including other areas in it. The major point of the Green Belt is its permanence, which prevents further urban sprawl. The only way 'replacement' could be achieved is by including areas on the perimeter, effectively moving the Green Belt outwards. Along with permanence, the prevention of the coalescence of settlements is another important function of the Green Belt but this coalescing will certainly happen in the Epping Forest District unless it is maintained in its present form. Tranquillity and Quality of Life are other important functions and the removal of any Green Belt from the inner London Arc will be to the detriment and chances of sustainability of the remainder. A loss in the Quality of Life for all those who at present access it is the certain result of the plan in its present form.

Sustainability Study:
As mentioned above The Sustainability Appraisal Report (Based on the Non-Technical Summary) is clearly at issue with the Plan in many places. It claims to accept the stated aims of The Plan, which appear "as we are all against sin and for a better life for all" but then at every stage it lists at length the environmental factors that negate what The Plan sets out to achieve.
A few quotations will suffice to underline this point.
P.22 A strong element of 'predict and provide' based on past trends and projections appear to underpin the overall housing numbers and allocations.
P.22 The policies are likely to have significant negative effects on the water resources of the region, particularly in the southern areas where water availability is lowest and housing allocation is highest.
P.29 The SA/SAE states that it will be extremely difficult to implement the RSS in a way that meets all its policy objectives because of the 'step-change' in delivery of housing employment and infrastructure are called for in the RSS.

Tables' 3.1h & 3.1i contain many items under the heading Problems and Issues that if taken seriously would make it impossible to allocate 11,000 dwellings in the Epping Forest District. This is especially relevant to the 6000 homes, plus 56 hectares for employment, directed to North Weald. This is guaranteed to destroy all the environmental attributes described in the report. These attributes are not just an accident of history but are due to the adherence over many years to the principle of the Green Belt - the very essence of which is its permanence.

Conclusion:
1. The Plan in its present form is deeply flawed and should be opposed.
2. The arguments for the proposed number of jobs are not well made and not supported by other sources of research.
3. Further development in the South East should be discouraged, not encouraged. Development other than for essential needs should be allocated in the North and West where there is a real need for new jobs and regeneration around urban centres and where there will be less environmental impact.
4. The housing numbers proposed are not sustainable and any increase in the level of housing numbers should only be on the basis that the jobs and infrastructure are in place first.
5. Essex and Epping Forest District are being required to take a disproportionate proportion of the housing burden.
6. There is inadequate funding for transport infrastructure, which will result in congestion and traffic chaos.
7. There is insufficient detail and analysis as to how other infrastructure requirements will be met in the areas of Health Care, Education, Water Supply and Waste Management etc.
8. Any change in the present boundaries of the Green Belt is unacceptable and will cause uncontrollable environmental damage and a loss of The Quality of Life for the regions population.
9. The Sustainability Appraisal Report (Based on the Non-Technical Summary) contains some of the best arguments as to why The Plan is flawed and this level of development should not be allowed to proceed.

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Preservation Society & Parish Council Notice 1st March 2005:

Theydon Bois Parish Council & Rural Preservation Society
Important Notice

East of England Plan Consultation Closing Date: 5pm, 16th March 2005

We strongly urge you to add your voice to this consultation. This plan will affect us all.

The East of England plan is a strategy to guide development in the East of England for at least the next 20 years. It has implications for housing, economic development, the environment, transport, health care, the protection of our countryside and our quality of life. The East of England Regional Assembly devised the 'Plan' or Regional Spatial strategy, but they were an appointed body, not one democratically elected by us.

Theydon Bois Parish Council and District Rural Preservation Society has severe reservations about the plan in its present form as we believe that the excessive amount of housing development involved is not sustainable and will have devastating effects on the environment and quality of our own and our children's lives in the future. The 'Plan' is now in the consultation phase and the closing date is the 16th March 2005. We think it is important for as many individuals as possible to make their views about the plan known, as every individual submission will count.

The plan and sustainability studies will be available at local libraries or you can request your own free copy by phoning EERA at the number below*, but it is a 300page document. You can if you wish download and respond to the plan by chapter on the EERA web site at: www.eera.gov.uk or you can visit the Theydon Bois Village Web Site; www.theydon.org.uk where the Preservation Society has copies of the plan for downloading together with further information and many useful links and addresses. The EERA reply form is also available, but as this does not make it clear that you can make a general, rather than a detailed reply to the plan proposals, you may prefer to use our Response Form to indicate if you agree with the plan and to make more general comments on it. One is enclosed and further copies are available from the Parish Council Office at the Village Hall and on the Village Web Site. Please do not enclose this notice with your reply.
We believe that this plan should be opposed in its present form. Please make your views known.

Some Key Issues for Essex and Epping Forest District

· The plan fails to show how sufficient new jobs will be created in line with new houses. The statistics used are based on selected periods in the past and are very suspect. It is suggested that 116,000 jobs will be created in Essex but where will these come from? Harlow has lost 20,000 jobs in recent years!
· There will be significant negative impact on our environment, sustainability and the quality of life in our district together with the destruction of large parts of the Green Belt.
· The plan proposes more new homes than can be accommodated in Essex.
· 'Affordable' home numbers in the plan are based on a partial assessment using a discredited demographic 'predict and provide' approach and untried methodology.
· While we would agree that some new 'affordable' homes are an essential requirement for our own communities needs, there is no indication as to how all these new builds will resist market forces. The result will be immigration from other areas into our district with people commuting to London bringing further negative environmental impact and still no affordable new homes for our children.
· There are serious doubts about the delivery of the required infrastructure, transport, health care, water supply etc. EERA will not endorse their own plan at this stage because the government will only commit to a quarter of the £1.5 Billion needed for the first three years of transport infrastructure alone. None of this reduced amount of money is designated for Essex.
· The 6,000 houses proposed at North Weald and 2,700 to the South of Harlow with inadequate transport infrastructure will have disastrous effects on traffic levels in Theydon Bois.
· Epping Forest District will see a 37.5% increase in proposed housing levels more than double other all areas in Essex except Maldon (26.3%).

Send your response to:
*EERA (RSS), Flempton House, Flempton, Bury St. Edmunds, IP28 6EG.
Tel: 01284 729443

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Report on EERA Meetings & Developments:
PN & JW attended both the EERA Consultation at Harlow on Thursday 6th January and The West Essex Forum Meeting (of E.C.C.) at North Weald Golf Course on Tuesday 11th January and made the following reports:

EERA Consultation:
It was noted that a Group of 'Stop Harlow North' protesters were allowed to demonstrate outside before the meeting. The relevance of this is that they were very well organised and clearly are a strong pressure group and there is a danger that EERA and the Government may play one group off against another with the most powerful groupings eventually reducing the amount of development in their area at the expense of areas that have not protested or are less well organised. We do not wish to be NIMBY about our response to the plan and should look at its implications for the whole of Essex but we also cannot afford to take the view that we are not badly affected and therefore do not need to respond to this plan.

Despite the many questions (at the end) about EERA not being an elected body and therefore undemocratic (which is the case) we thought there did seem to be a proper attempt at consultation but this body is costing £3 Million a year or 55p for every person in the region and there are still problems. One of the problems about the consultation is the size of the East of England Plan (over 300 pages) and the fact that it is only available to individual applications (a body can't order a number of copies, we tried) making it more difficult for individual member of the public to obtain a copy and respond even though they are requested to do so.

The first point to come out of this presentation (and an earlier letter about the plan) is that EERA themselves will no longer endorse their own plan. The reason for this is the Government is not meeting the financial commitment required for infrastructure. An EERA press release "deplores the Government's grossly inadequate funding of transport infrastructure costs" despite there being "repeated written assurances that growth will not be imposed without the associated infrastructure". The first bid was for the first 3 years only and was £1.5 Billion but the Government will only commit to a quarter of this with Essex, so far, getting nothing. EERA's view is that without the proper commitment to infrastructure the plan will fail but when we asked what were the implications if EERA failed to support the plan into the "Examination in Public" and beyond there were vague mentions of getting the Government to see sense and put up the funding. But it was also said "EERA had no intention of carrying out Megaphone Diplomacy with the Government". It will then surely become the Government's (top down plan) with inadequate funding for the necessary infrastructure.

The good news for Theydon Bois is (but note first paragraph) that large amounts of the proposed housing to be located to the south of Harlow is now to be located to the North, but 2,700 are still to be built to the South & West of Harlow and as there is now no provision for infrastructure here and few roads in this Green Belt area at present (as well as a strong and well funded protest group) we fear there is a possibility that this block of housing could be relocated to Debden (note the Harlow Options Study).

Development is still supposed to be "Sustainable" and built upon Jobs in the area. Thankfully EERA has come out against a second runway at Stansted but still bases its plan on the creation of 421,000 jobs in the plan area. Most views are that this is very optimistic (it's 12.5% of suggested national job growth targets). Harlow alone has lost 20,000 jobs over the last few years and the while the plan specifies 20,700 homes in Harlow and 11,000 in Epping Forest it is very non specific about job numbers for these housing areas. Clearly if there are not 'Local Jobs' this will encourage commuting to London with all the associated problems.

Another main tenet of the plan is the need for "Affordable Housing" and while in principle this is something most would wish to support, the detail in the plan as to how this would work is very thin. 30% of the 478,000 homes proposed for building between 2001 and 2021 would have to be "affordable" to meet the required need and there is already a backlog of 50,000 affordable homes. Unless there was some form of secured public ownership of homes to rent it seems unlikely that many of the homes, even if started at affordable prices, would remain so for long.

Detail for infrastructure needs other than transport is also thin in the plan. The whole of the Region and Essex especially already imports a high proportion of its water in the summer. Where will all this extra water come from? When questioned EERA officials would only say they have spoken to the utility companies who say they should be able to meet it? Again the detail on the provision of Health Care is poor. There are at present no figures for our Sub-area but the Thames Gateway Sub-area is already short of 21 GP's and the proposed population increase, even with some extra provision, would increase this to 69.

The notion of sustainability in the plan is based on the proper implementation of Plan, Monitor, Manage and therefore if the Jobs and Infrastructure are not forthcoming the housing should not be built, but in practise if you get the developers to start house building it is very difficult to turn off the tap.

West Essex Forum Meeting: Essex and Hertfordshire County Councils were allowed to put their views at the EERA consultation meeting and at this well attended forum, with many Town and Parish Councils from across Essex attending, Essex C.C. expanded on its own response to the EERA Plan. This is well argued with many good points (we distributed the Essex Response handouts to all committee members present and also passed copies to T.B. Parish Council who were not represented at the meeting) but still favours a maximum of 110,400 homes in Essex against 123,000 in the East of England Plan which is still a very high number. In Epping Forest District they support 8,000 homes against the 11,000 in the plan. EFD RP increase was 37.5%, more than double any other area apart from Maldon, so 8,000 would still give this area a relatively bigger increase than other sub-regions. The plans original proposal was for 18,600 homes in the EFD area.

The Keynotes of EERA's Regional Spatial Strategy Vision are "To develop a more sustainable, prosperous and out-ward-looking region, while respecting its diversity, maintaining and enhancing its assets, and sustaining and improving the quality of life for all people who live and work in or visit the region". ; Our people, The future, Quality of Life for All and Quality of the Region. It's hard to accept that our Quality of Life will be improved if the plan goes ahead in its present form.

There was considerable discussion on this report and members indicated they would respond to the Essex Questionnaire that was distributed with the handouts. The committee also saw the need for as many individuals and organisations as possible to be part of the consultation process. It was requested that we should make our own Parish Council fully aware of the Consultation and the need to respond. We need to get as many individual responses from villagers as possible to the plan and therefore need to make sure that the consultation and its closing date on 16th March 2005 is well publicised around the village. We are aware that the next issue of Village News will be past the closing date so PN & JW will talk to the Parish Council about possible posters and leaflets in shops. JW will ensure an article with relevant links goes on the Village Web Site. HM will try to get a piece in the next St. Mary's Newsletter and JW will circulate a Press release from the Society. PN & JW will prepare the Society's response to the plan and other committee members were encouraged to get copies of the plan and give their inputs.

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Links:
www.eera.gov.uk Home Page

www.eera.gov.uk/ Download page for East of England Plan in total or by individual chapter headings.

www.eera.gov.uk/ Sustainabilty Study Page & Technical Appraisal.

www.essexcc.gov.uk Home Page

www.essexcc.gov.uk Essex East of England Plan Guide.

www.planninghelp.org.uk CPRE's planning response help.

www.cpressex.freeuk.com CPREssex's Home Page. Up dates on responses to the plan.

The Plan Download Page at EERA

Closing Date for East of England Plan Response: 5pm 16th March 2005.

Patrick Amos
Planning Service Group
Essex County Council
County Hall
Chelmsford, CM1 1QH
Tel: 01245 437557
www.essexcc.gov.uk
E-Mail: Patrick.amos@essxcc.gov.uk
There are good summaries and info about statistics on the Essex CC site.

The Campaign to Protect Rural England (CPRE)
Tel: 020 7981 2800
www.cpre.org.uk
E-Mail: info@cpre.org.uk
www.planninghelp.org.uk
Good information about the new Planning Laws and up dates about the EERA Plan.

CPREssex
www.cpressex.freeuk.com
E-Mail: cpressex@freeuk.com
Info on the Plans implications for Essex.