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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

A 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.

LRA 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 happen.

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 pollution-prevention strategy.

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30 April 2021

Planning Applications delayed by EFSAC issues
At the 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.

LRA Cllrs 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.

LRA 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

The 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
Help look after Loughton
After 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.

LRA 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

Late 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 Local Plan.
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".

The 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.
LRA 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 proper 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).

You can watch the meeting here from 7pm and the agenda papers are here. 

As 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 – the 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
First, 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 District.

During the long-drawn out discussions on the draft Local Plan, 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 & ride.

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 is concluded).

The current debate is really all about the Council allowing new building near to the EFSAC* without going through the proper 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).

As LRA has done all along, we would 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 – 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 called
Last Sunday, a group of District Cllrs, led by LRA Cllr Chris Pond, released the following statement:

Statement on call for Extraordinary Council Meeting
"Five 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 views.
No 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 and Twitter.
Other matters
The 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 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 Chris Pond.
What you can do
If you oppose the introduction of a CAZ, before the Extraordinary Meeting, please 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.

Now looking at what’s been said

1. There will be full and open consultation

Sounds 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 been 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 day.

2. Other measures will be taken into account before a CAZ is introduced.
We 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.

3. The Opposition Parties knew about the Strategy in July and could have commented, scrutinised and raised at committee.
The 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.

4. The Council has a legal duty to consult Natural England and to take their advice.
All 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.

5. This could see local housing number double.
The 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.

6. Many small developers, local businesses & residents have been detrimentally affected.
We 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.

7. The LRA want no development at all, this means no additional infrastructure.
The 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.

8. "Fake" 12.50 claim
It 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.

9. 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.

10. The Labour Party have already implemented a CAZ in London and plan to expand it further.
In 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 no seats on the District Council.

Conservative Cllrs on the District Council

Councillor Nigel Avey Conservative Broadley Common, Epping Upland and Nazeing cllr.navey@eppingforestdc.gov.uk
Councillor Aniket Patel Conservative Buckhurst Hill West Cllr.apatel@eppingforestdc.gov.uk
Councillor Jo Share-Bernia Conservative Buckhurst Hill West cllr.jsharebernia@eppingforestdc.gov.uk
Councillor Brian Sandler Conservative Chigwell Row cllr.bsandler@eppingforestdc.gov.uk
Councillor Darshan Sunger Conservative Chigwell Village cllr.dsunger@eppingforestdc.gov.uk
Councillor Basil Vaz Conservative Chipping Ongar, Greensted and Marden Ash cllr.bvaz@eppingforestdc.gov.uk
Councillor Paul Keska Conservative Chipping Ongar, Greensted and Marden Ash cllr.pkeska@eppingforestdc.gov.uk
Councillor Chris Whitbread Conservative Epping Lindsey and Thornwood Common Cllr.cwhitbread@eppingforestdc.gov.uk
Councillor Holly Whitbread Conservative Epping Lindsey and Thornwood Common Cllr.hwhitbread@eppingforestdc.gov.uk
Councillor Les Burrows Conservative Epping Lindsey and Thornwood Common cllr.lburrows@eppingforestdc.gov.uk
Councillor Alan Lion Conservative Grange Hill cllr.alion@eppingforestdc.gov.uk
Councillor Gagan Mohindra Conservative Grange Hill gmohindra@eppingforestdc.gov.uk
Councillor Sheree Rackham Conservative Grange Hill cllr.srackham@eppingforestdc.gov.uk
Councillor Richard Morgan Conservative Hastingwood, Matching and Sheering Village cllr.rmorgan@eppingforestdc.gov.uk
Councillor Maggie McEwen Conservative High Ongar, Willingale and the Rodings cllr.mmcewen@eppingforestdc.gov.uk
Councillor Brian Rolfe Conservative Lambourne cllr.brolfe@eppingforestdc.gov.uk
Councillor Richard Bassett Conservative Lower Nazeing Cllr.rbassett@eppingforestdc.gov.uk
Councillor Yolanda Knight Conservative Lower Nazeing cllr.yknight@eppingforestdc.gov.uk
Councillor Paul Stalker Conservative Lower Sheering cllr.pstalker@eppingforestdc.gov.uk
Councillor Ian Hadley Conservative Moreton and Fyfield cllr.ihadley@eppingforestdc.gov.uk
Councillor Jaymey McIvor Conservative North Weald Bassett cllr.jmcivor@eppingforestdc.gov.uk
Councillor Peter Bolton Conservative North Weald Bassett cllr.pbolton@eppingforestdc.gov.uk
Councillor Heather Brady Conservative Passingford cllr.hbrady@eppingforestdc.gov.uk
Councillor Mary Sartin Conservative Roydon cllr.msartin@eppingforestdc.gov.uk
Councillor Nigel Bedford Conservative Shelley Cllr.nbedford@eppingforestdc.gov.uk
Councillor John Philip Conservative Theydon Bois cllr.jphilip@eppingforestdc.gov.uk
Councillor Sue Jones Conservative Theydon Bois cllr.sjones@eppingforestdc.gov.uk
Councillor David Stocker Conservative Waltham Abbey Honey Lane cllr.dstocker@eppingforestdc.gov.uk
Councillor Sam Kane Conservative Waltham Abbey Honey Lane cllr.skane@eppingforestdc.gov.uk
Councillor Steven Heather Conservative Waltham Abbey Honey Lane cllr.sheather@eppingforestdc.gov.uk
Councillor Ann Mitchell Conservative Waltham Abbey North East cllr.amitchell@eppingforestdc.gov.uk
Councillor Jeane Lea Conservative Waltham Abbey North East cllr.jlea@eppingforestdc.gov.uk
Councillor David Dorrell Conservative Waltham Abbey Paternoster cllr.ddorrell@eppingforestdc.gov.uk
Councillor Helen Kane Conservative Waltham Abbey South West cllr.hkane@eppingforestdc.gov.uk

8 January 2021
Charging to drive through an Epping Forest Clean Air Zone

In four years’ time, you may have to pay to drive through Epping Forest. The District Council’s Conservative administration's Air Quality Mitigation Strategy involves road charging to drive a vehicle on main and side roads through the 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. Which other sorts of cars and lorries etc would have to pay isn’t yet known, but could be 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 traffic to avoid the area by taking alternative routes or by using other forms of transport.

LRA believes the principal way of preventing further damage being done to the Forest should be severely restricting extra housing near the Forest, not by a cumbersome charging system which would be in danger of diverting traffic into residential areas and alienating residents’ support.


Yesterday (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 in 2025.

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 5 abstentions).

The 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 time that it has been necessary to firmly challenge the Council’s development proposals under the draft Local Plan. The Council has been attempting to force over 1,000 new dwellings on Loughton, and public 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.

We believe that the proper 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 Local Plan.

Epping Forest Clean Air Zone The EFSAC is the whole of the main body of the Forest south of Epping (that is, not 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 Boroughs of 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).

Birmingham CAZ:
- 8 for cars, vans and minibuses
- 50 for HGVs, buses and coaches.
Source: District Council report on Managing the Effects of Air Pollution on the Epping Forest Special Area of Conservation (paragraph 5.52)
3. London Ultra-Low Emission Zone
Quite 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.