Charging to drive through an Epping Forest Clean Air Zone?
5 May 2023
More housing allowed at appeal without any sign of the District Council's Pollution Prevention Strategy being implemented
Planning Inspector has recently approved an application to demolish a
house in Algers Road and replace it with an oversized building
containing 6 flats. LRA Plans Group had objected to the application
because of the impact that pollution from the extra vehicle traffic
would have on the Epping Forest Special Area of Conservation (SAC) and
the pressure for parking spaces on Algers Road. The District Council
did turn down the application because of the impact on the SAC; an
earlier appeal had dismissed the overdevelopment of the site and poor
living accommodation arguments. However, since the refusal of consent, the Council has adopted a new Local Plan
which refers to a pollution-prevention strategy (the “IAPMS”, which
purports to provide for ways of preventing increases in traffic from
worsening pollution in the Forest).
LRA is concerned appeals
such as this are being allowed when the Council has not yet brought any
of the proposed measures into effect (in fact, they don’t even seem to
have started the process of doing so). This means that any increase in
building near to the Forest, such as the Algers Road flats, is bound to
increase pollution in the Forest, during the time the flats are being
built, and when they are occupied, until some future unknown date when
the Council finally brings pollution-prevention measures into force.
Cllrs have argued consistently that the Council should carry out the
mitigation measures before any more new housing is built. Although this
was not upheld during the adoption of the Local Plan, the Council
should at least have an implementation plan showing how and when the
measures will be put in place. It is very disappointing that the
Planning Inspector and Natural England have fallen for the promise of a
pollution-prevention strategy without any guarantees it is going to
We also note the reluctance of the District Council to go along with the expanded Ultra Low Emission Zone
(ULEZ) scheme covering all London boroughs proposed by London Mayor
Sadiq Khan, and also their own tardiness to do anything about reducing
the air pollution that is poisoning the Forest. It is somewhat ironic
that a scheme similar to the ULEZ has been proposed in Council's
30 April 2021
Planning Applications delayed by EFSAC issues
District Council’s Development Management Committee meeting on April
26th, LRA Cllrs secured a delay in the release of planning permissions
on the two sites (51 High Rd and 113 Church Hill) in Loughton very near
the Forest. These sites will be reassessed by the officers and a
further report made to the committee.
were supported by Green Cllr Simon Heap, who pointed out that because
of the slow activation of catalytic convertors, vehicles starting from
new developments very near the Forest would have much more deleterious
an effect than those just passing through.
comment: LRA considers that the Council’s Interim Air Pollution
Mitigation Strategy completely fails to meet the requirements of the
relevant legislation. The developments being considered are small, the
largest one in Loughton being 10 units, but the principle is important,
as the law refers to all developments, singly or with others, and
implementing these approvals would inevitably lead to further damage to
the Epping Forest Special Area of Conservation.
11 April 2021
advisory panel set up by the District Council to look at the mitigation
strategies needed to avoid a Clean Air Zone has started to meet. The
Council is still resisting the idea of preventing any new residential
building close to the Epping Forest Special Area for Conservation.
We'll keep you updated as much as we can, but the panel has been told its proceedings are confidential. (LRA says why?)
13 March 2021
the recent Extraordinary District Council meeting on the District
Council’s Interim Strategy, social media comment has continued. One
resident managed to sum up the situation precisely and pithily: “We
have listened to the Conservative Councillors rhetoric and reject it.
They knew two years ago of the effect of air pollution on the forest.
They knew they had a legal duty to protect it and help restore it due
its status as a SAC. At the same time the Inspector of the Local Plan
gave them the opportunity to decrease the number of houses to be built
in the district which they declined. They even prepared plans for
various building proposals in Epping in the light of all this. Let’s
not pretend local residents, other Councillors and the Inspector of the
Local Plan are at fault. It was their choices and their responsibility
alone that have created this situation.”
At the meeting,
Conservative Cllrs were at pains to present the current delays in
providing decisions on planning applications as affecting local
residents wanting to make changes to their properties. LRA Cllr Michael
Owen made a Freedom of Information request and asked how many Granny
annexes and extensions have been on hold.
The answer was: zero.
In fact, the postponements only affect proposals for new homes that would increase the number of car movements.
comment: While Clean Air Zones in principle can work well, these need
to be considered carefully to ensure the claimed environmental benefits
can be practically realised, and without simply shifting the burden to
other areas, such as traffic travelling longer distances and polluting
local roads. Thought also needs to be given to those residents who can
ill afford additional transport costs to enjoy a natural asset that
should be available to all, irrespective of financial means.
13 February 2021
on a Friday just before Christmas, the District Council announced a
decision to introduce an Interim Air Pollution Strategy, including a
Clean Air Zone (CAZ) for the Epping Forest Special Area of Conservation
(SAC) - essentially the main Forest south of Epping. It is common
ground that the Forest is in a poor state from the effects of pollution
from vehicles and from domestic gas boilers.
Groups of District
Cllrs, led by LRA Cllr Chris Pond, used Council procedures to challenge
the decision at a committee meeting in January, and on Tuesday this
week at an Extraordinary Full Meeting of the Council (see the recording
of the meeting here).
On both occasions the Conservative administration closed ranks to
defeat the challenges. It was very clear from comments on social
media in the run-up to Monday's meeting that a large number of District
residents were upset about the Council’s approach, which will allow
extra housing to be built close to the Epping Forest Special Area of
Conservation. LRA believes the Council should have waited for a few
months until the whole subject could be properly and publicly discussed
in front of the Planning Inspector as part of the debate on the draft
On Monday evening the Conservative
administration forced through a change to the motion which retains
their original decision and sets up an all-party to consider the
Interim Strategy and possible additions to it to reduce the likelihood
of a CAZ being needed.
This is ironic, as the Conservative
administration could have approached the problem this way after a
Council discussion on the topic last July; instead, they stayed silent
and produced the Interim Strategy as a fait accompli in December.
Public pressure has now forced them to agree to this being discussed in
detail. They obviously hoped it would go through "on the nod".
District Council can now start granting planning permission to
applications that have been held up, (although this does not include
sites allocated in the draft Local Plan such as those on Borders Lane -
Lucton's Field and the Middle Site). However,
there will now be no way of reversing the permissions once they’ve been
granted if the Inspector rules against the Interim Strategy.
comment: we are disappointed by the Conservative administration’s
response and by some of the petty party-politicking some Conservative
Cllrs indulged in. We will continue to resist damage to the Forest SAC
by drowning Loughton and Epping in extra housing.
8 February 2021
Join other residents at 7pm tonight to see a group of District
Cllrs, led by LRA Cllr Chris Pond, challenge the Council’s decision to
introduce a possible Clean Air Zone and to
allow new building near to the
Epping Forest Special Area of Conservation, without going through the
process of discussion in front of the Inspector who is
examining the Council’s draft Local Plan (and of course without any new
infrastructure to go alongside the new developments).
can watch the meeting here from 7pm and the
agenda papers are here.
LRA has done all along, we will argue
strongly that there should not be new building close to the Forest. The
Inspector has already removed Jessel Green from the list of sites for
development, and could remove more of the Council’s proposed sites –
Council cannot know this unless they go through the proper process.
23 January 2021
There is more to report on about the District Council’s controversial
decision to introduce a Clean Air Zone (CAZ) to protect the Epping
Forest Special Area of Conservation (EFSAC).
The Council’s press
releases purport to give the 'facts' behind their Air Pollution
Mitigation Strategy - we think that they don’t tell the full story.
And Council supporters have put out messages on social media which
don’t stand up to proper scrutiny either.
Below is the key point with this proposal, what the Council are
saying, what you can
do, and we
look at what's been said. For
the story so far, see below.
The key point
the key point is that this is not really just about protecting the
Epping Forest Special Area of Conservation (EFSAC) – there are other
ways of doing that, by allocating new building elsewhere in the
During the long-drawn out discussions on the draft Local
we have suggested (on record) that the areas round Harlow should be
revisited, and LRA Cllr Chris Pond has suggested the Council should
consider the idea of a garden village near Norton Mandeville, feeding
into Chelmsford and that council's wish for a western by-pass and park
In any case, the new Local Plan will have to be
updated in accordance with the new NPPF at the first review (which we
understand will begin almost immediately the current draft Local Plan
The current debate is really all about the Council
allowing new building near to the EFSAC* without going through the
of discussion in front of the Inspector who is examining the Council’s
draft Local Plan (and of course without any new infrastructure to go
alongside the new developments).
As LRA has done all along, we
would argue strongly that there should not be new building
to the Forest. The Inspector has already removed Jessel Green from the
list of sites for development, and could remove more of the Council’s
proposed sites – the Council cannot know this unless they go through
the proper process.
*Including 285 residential dwellings
in a series of blocks ranging from 2 to 5 storeys in height and a new
Wellness Centre and other associated development on Lucton’s Field,
opposite the College on Borders Lane.
Extraordinary Council Meeting
Last Sunday, a group of District Cllrs, led by LRA Cllr Chris Pond,
released the following statement:
Statement on call for Extraordinary Council Meeting
non-Conservative members representing all the opposition groups have
written to the Chairman today requisitioning an Extraordinary Meeting
to discuss this subject. So far as is known, this is the first
requisition in 40 years, such is the importance of the matter. Be sure
those members who support the Conservative administration know your
development that will harm the Forest; no need for a CAZ.”
There is now a Facebook page called SAY NO
TO - EFDC - CAZ (Clean Air Zone).
It is independent of LRA, although we have spoken to them. This is
urging District Council residents, particularly those in areas
represented by Conservative Cllrs, to contact as many Conservative
Cllrs as they can to let them know their views on the CAZ.
The date and time of the Extraordinary Meeting which you will be able
to watch online is Monday February 8th at 7pm. Details
will be published here, and we will let you
know on Facebook
Council have put out two press releases which we consider to be
significantly misleading, and there has been a lot of discussion on
social media, some of which has been even more misleading. You can see
the Council’s press preleases here
and our comments on them and on the social media comments below.
In passing, we think it regrettable that, during the discussion on the
Interim Strategy at the District
Council committee meeting on January 7th, a member of the
Conservative Cabinet descended to a personal verbal attack on LRA Cllr
What you can do
If you oppose the introduction of a CAZ, before the Extraordinary
also encourage anyone you know in District wards outside Loughton with
a Conservative District Cllr (names and email addresses below)
to let their Conservative Cllr(s) know their views.
Please do not email other parties’ cllrs.
looking at what’s been said
1. There will be full
and open consultation
comforting. But the Council has taken a firm decision to have a CAZ
(Clean Air Zone). It’s only the 'details' that haven’t yet
decided – like exactly what area it will cover, which vehicles which
will be charged and which won’t, and how much they’ll be charged each
Other measures will be taken into account before a CAZ is introduced.
have seen speculation that this might mean there wouldn’t actually be a
CAZ in 2025. But it’s just speculation. In the meantime, new dwellings
would go through the planning process and be built, without any new
infrastructure to support them.
The Opposition Parties knew about the Strategy in July and could have
commented, scrutinised and raised at committee.
matter didn’t come up at any Council meeting after July. The
presentation to the Cabinet in July (marked "working draft") made it
clear that a lot more work was needed on the proposals, of which a CAZ
was only one. The next we heard of the mitigation strategy was on
December 11th, when the Policyholder announced a firm decision to go
ahead with the CAZ.
Anyway, as we were expecting, the proper
place to discuss the mitigation strategy is as part of the debate on
the draft Local Plan.
The Council has a legal duty to consult Natural England and to take
Natural England have said is that if the Council were to introduce a
CAZ in 2025 that would be a way of meeting the requirements. The
Council haven’t actually published the letter in which they asked for
Natural England’s advice, and seem very coy about producing it in
public. LRA Cllr Chris Pond has asked for it but has received nothing.
This could see local housing number double.
Council has contributed to the delays in discussing the draft Local
Plan, and so they missed the chance to hold a proper debate in front of
the Inspector last autumn, and we await a new date.
As we have
said above, there are other ways of solving this issue within the draft
Local Plan as it stands, and rejecting this Interim Strategy does not
necessarily mean the Plan itself would fail.
Many small developers, local businesses & residents have been
sympathise with those who are caught up in the restrictions, but the
answer is to sort this out properly through the Local Plan process. In
any case, the restrictions are only on new developments for extra
dwellings near the EFSAC which would create extra vehicle movements, so
many other planning applications have been proposed and approved, and
can be implemented.
The LRA want no development at all, this means no additional
LRA don’t want development near the EFSAC – we have never said we don’t
want any development in the District. And any additional infrastructure
will presumably be built to cope with the extra stress on local
services, already under pressure, and as usual won’t be built until
well after all the new developments.
The Council aren’t proposing any new infrastructure for the new
developments they want to push through now.
"Fake" £12.50 claim
was the Council itself that gave the examples of CAZ charges elsewhere
(of £8 in Bristol and £12.50 in London). As they say, the charges are
up for future consultation and discussion, so they can say that £12.50
is unlikely but they cannot guarantee what the charge will actually
be….. or won’t be.
The Green Party want tougher measures which will cost you more.
Whatever else they may want, the fact that the Green Party is opposing
a Clean Air Zone surely speaks for itself.
The Labour Party have already implemented a CAZ in London and plan to
expand it further.
London, there isn’t the alternative that Epping Forest District Council
have (of not building near the EFSAC). Under the Council’s plans,
anyone driving into London from the District through the EFSAC might
have to pay two CAZ charges each time. The Labour Party have
seats on the District Council.
Cllrs on the District Council
8 January 2021
Charging to drive through an Epping Forest Clean Air Zone
years’ time, you may have to pay to drive through Epping Forest. The
Council’s Conservative administration's Air Quality Mitigation Strategy
involves road charging to drive a vehicle on main and side roads
Forest Special Area of Conservation (SAC) - for example on the A121 to
Buckhurst Hill, Epping or Waltham Abbey or the A1069 to Chingford.
Electric cars (which have no gaseous
emissions, but do cause
particulate pollution through tyre and brake dust) would be exempt.
sorts of cars and lorries etc would have to pay isn’t yet known, but
those that don’t meet the standards for Ultra
Low Emission Vehicles. Quite how charging would be done, and
how the toll
would be collected, is unknown. The Council’s other aim is to force
avoid the area by taking alternative routes or by using other forms of
LRA believes the principal
way of preventing further
damage being done to the Forest should be severely restricting extra
near the Forest, not by a cumbersome charging system which would be in
of diverting traffic into residential areas and alienating residents’
(Thursday January 7th) a group of local District Councillors attended a
meeting at Epping Forest District Council on the Council’s decision,
taken without any prior public discussion, let alone any formal public
consultation, to introduce a Clean Air Zone (CAZ) in the Loughton area
The CAZ would be similar to
the London Congestion Zone. Its effect would be that some
private and commercial vehicles entering a zone around and including
the Epping Forest Special Area of Conservation (EFSAC - see map below) will be charged,
presumably on a daily basis. The Council has suggested possible ways to
determine which vehicles would be charged, which could be those that
don’t meet the standards for Ultra Low Emission Vehicles,
but this could change between now and the start of the CAZ. No details
have been given of how charging would be done, and how the toll would
be collected, or of the level of charges (see note 2 below for the
examples given by the Council).
The Council’s decision was
taken on December 11th by a single Cabinet
member, without any notification, let alone consultation, with the
local Cllrs for areas affected. As part of the Council’s Constitution,
there is a process – a “call-in” - for such decisions to be challenged
by Cllrs so that the decisions can be discussed before they take
effect. A group of LRA and Green Cllrs led by LRA Cllr Chris Pond
therefore called-in this decision. (As a result they have been
criticised by the Council and by our local MP.) At the meeting, the
call-in was eventually defeated by a narrow margin (7 votes to 5, with
Council is trying to avoid the effect of
laws which prohibit the building of new homes if the
effect of the
extra residents (singly or along with other new homes) would adversely
affect the EFSAC. A backlog of planning applications for developments
large and small has built up over the last 18 months, and
understandably those developers affected are putting pressure on the
Council to resolve the issue.
By introducing an Interim Air
Pollution Strategy and committing themselves to introducing a CAZ in
2025 the Council are aiming to resolve the situation. However, it does
not lie wholly in the Council’s power to introduce a CAZ - they will
need to get various other bodies to agree, or in order to do so alone
they may need to put a Private Bill through Parliament. All this
without any apparent public consultation. Our understanding is that,
without any absolute certainty that the CAZ will in fact be introduced,
the Interim Strategy may not meet the relevant legal requirements for
protecting the EFSAC.
Unfortunately this is not the first
that it has been necessary to firmly challenge the Council’s
development proposals under the draft Local Plan. The
attempting to force over 1,000 new dwellings on Loughton,
pressure has already forced it to drop its plans to allow building on
Jessel Green, after ignoring the overwhelming views of local residents
and local Cllrs for several years.
believe that the
course would be for the Council to have raised the Interim Strategy,
and the CAZ, as part of the ongoing discussions on the draft Epping
Forest Local Plan, where the proposals could be fully and publicly
discussed and consulted upon, and the proposal (if agreed by the
independent Inspector) could then integrated into the provisions of the
EFSAC is the whole of the main body of the Forest south of Epping (that
the Lower Forest or odd outliers like Knighton Wood or Kings Green).
A significant proportion of the
EFSAC lies within the Epping Forest District
Council administrative area. The remainder lies within the London
Waltham Forest and Redbridge.
The main routes affected by the CAZ would be:
- the A121 (High Road/Goldings Hill).
- the A104 (Epping New Road).
- the A121 Woodredon Hill.
- the A1069 (Rangers Road).
1. Background material
- The Council’s decision can be found here
and their press release here.
The discussion at the Council Cabinet meeting last July, which mentions
a CAZ as one of a number of possible approaches, can be found here
(paragraph 5.41 to 5.65).
- For the history and background of the draft Local Plan, see below.
2. Examples of charging
levels (or proposed levels) for other schemes of a similar nature.
The London Ultra Low Emission Zone (ULEZ):
- £12.50 for most vehicle types, including cars, motorcycles and vans
(up to and including 3.5 tonnes).
- £100 for heavier vehicles, including lorries (over 3.5 tonnes) and
buses/coaches (over 5 tonnes).
- £8 for cars, vans and minibuses
- £50 for HGVs, buses and coaches.
Council report on Managing the Effects of Air Pollution on the Epping
Forest Special Area of Conservation (paragraph 5.52)
3. London Ultra-Low
separately, from 25 October this year you will have to pay a charge of
£12.50 a day to take an older diesel or petrol car into that part of
Greater London within the North Circular Road (that is, beyond the
Waterworks, Wadham Road, or Charley Brown's in our area). Details.