Epping Forest District Council’s (EFDC) Local Plan sets out how the district’s housing and employment needs will be accommodated in the period up to 2033 and includes proposals for development at Latton Priory, south of Harlow and North of Epping. Latton Priory is also part of the Harlow and Gilston Garden Town, which was one of the areas designated as a Garden Town by Central Government in January 2017. The development will include places to live, work, learn and socialise, with a range of community facilities, sports and play provision on land around Latton Priory Farm.
The Latton Priory masterplan includes:
* A minimum of 1,050 homes
* Primary and secondary schools
* 1 hectare of employment land
* 0.5 hectares for up to 5 Gypsy and Traveller pitches
* A vibrant local centre
* Community facilities
The Masterplan proposal is being consulted on by EFDC prior to a formal endorsement and planning consents.
You can add your own comments to the consultation here: Latton Priory Strategic Masterplan Framework consultation – Epping Forest District Council (eppingforestdc.gov.uk)
You can also review the detailed proposals here: Home – Latton Priory
As Conservators of Epping Forest, it is our responsibility to protect and mitigate any impact of development to the delicate eco system of the ancient forest. Our response to this consultation is outlined below.
Dear Sir/Madam,
Re: City of London as Conservators of Epping Forest response to Latton Priory Strategic Masterplan Framework (SMF) Consultation 2022-2023.
Epping Forest is owned by the City of London and comprises some 6000 acres (2,500 hectares). The Epping Forest Act 1878 charged the City as Conservators of Epping Forest, with a duty to conserve varied vegetation and preserve the Forest’s natural aspect.
Epping Forest is of international importance for its woodland and heathland habitats and for the presence of certain species such as the Stag Beetle. The site is designated as a Special Area of Conservation (SAC) and thus afforded full protection by law under the provisions of the Habitats Regulations (2017, as amended). It is the role of Epping Forest District Council, as competent authority, to ensure that the requirements of the Habitats Regulations are met before deciding whether to authorise any planning application. Where a particular application would be likely to have a significant effect on the SAC, an appropriate assessment and integrity test is required before that application is authorised.
The proposed Latton Priory development is situated within the 6.2km “Zone of Influence” of the Epping Forest Special Area of Conservation (EFSAC), within which it is considered that building new homes could result in more visits to the EFSAC, resulting in increased recreational pressure. In order to avoid recreational pressure in the EFSAC, it is essential that any development of this scale provides attractive visitor destinations, known as SANGS (Suitable Alternative Natural Green Space)
The Conservators observe that it is intended that over 50% of the proposed development will comprise of green/open space, with 28.8ha of this being dedicated as SANG. The landscape character of which includes new meadows, grassland, trees, and scrub with the intention to provide an onsite, attractive recreational space, with the added benefit of increased biodiversity. The Conservators agree that the SANG creation should be part of Phase 1 of the proposed development, so that it more greatly established on completion of the first phase of dwelling inhabitation.
Whilst this design and approach are observed by the Conservators as being correct and positive steps in creating a meaningful SANG that will achieve reduction in uplift of recreational pressure upon the EFSAC, the Conservators wish to make the following observations and concerns on this element of the development.
Future development to the south of the proposed SANG
The Conservators wish to state as this time, that the proposed SANG does benefit from extensive views in the southern panorama towards with the open farmland between the site and Epping Green, Epping Upland and Thornwood, with the Forest as a backdrop. These views would contribute to the attractiveness of the SANG. However, any extensive future development to the south of this SANG would greatly reduce the appeal and success.
Management of the SANG
The Conservators understand that a further consultation regarding a Stewardship Charter, is to be produced detailing the future management of the SANG and the Conservators would wish to be included in this consultation and make comments where necessary.
Fire Risk
The creation of meadows and grassland as part of the SANG allocation of the proposed development do present a significant fire risk to the site, especially for the dwellings on the eastern side of the site. This potential risk is increased by the prevailing wind in conjunction with the aspect of the site (the site is higher than the land to the south/west and therefore would increase wind speeds). It has been the experience of the Conservators that grassland, meadows, and scrubland present the biggest fire risk on public access sites, due to the increase footfall generating more litter (cigarettes or glass), disposal BBQs or deliberate arson. With the forecasting of drier summers and higher temperatures predicted in association with climate change, the Conservators believe that this factor must be assessed when SANG design is more greatly considered with the use of managed fire breaks.
We only need take as an example the 45 acre wild fire incident that occurred at Wanstead Flats in July 2018, where 18.2 hectares of grassland were lost. This event led to the closing of local roads and the mobilisation of 50 fire appliances from London and Essex. At the proposed location, there is a significant risk of fire spreading to more ignitable conifer plantation of Mark’s Bushes (Rundell’s Grove/Latton Woods) and potential for road closure of the M11 or A414. This in an area, where mobilisation of fire appliances is significantly less than the Wanstead Flats scenario, which has parallels to the fire incidents and property loss in Rainham, Essex in August 2022.
The Conservators believe this factor to be significant in the success of the SANG, as although sites can recover from fire, in the aftermath of such incidents the facility attractiveness drastically declines and fear of safety leads visitors to seek alternate options which could lead to increased visitation to Epping Forest, specifically in areas of SSSI and SAC.
Bye-laws
In part associated with the above, given the proposed scale of the development (1500 dwellings) and the developments location being immediately adjacent to the urban conurbation of Harlow. The Conservators would be keen to understand what (if any) local byelaws or Public Space Protection Orders (PSPO) would be in place to govern use of the SANG. The risk of fire from recreational activities, such as BBQs have been listed above. However, other forms of anti-social behaviour such as ineffective dog control, litter, fly-grazing (which is very prevalent on Harlow Town Open Spaces) etc, all have potential to lessen the attractiveness of the SANG, resulting in the seeking of alternate green/open space options.
Recreational facilities
Whilst the play parks and sports facilities, should be expected as part of a development of such a scale. The provision for recreational walking and cycling facilities does appear to be lacking, especially considering that the SANG land is currently used for agricultural purposes and will take time to develop. The Conservators would suggest that increased multiple circular walks should be included. A good example of this is the Whitehill & Bordon SANG in East Hampshire known as the Hogmoor Inclosure, which has multiple surfaced paths of varied lengths, to accommodate different user needs.
Whilst the SANG provision, may look to accommodate walking (including dog exercise) running and access to some open space. There seems to be little provision for recreational cycling as part of the SANG, which could be accommodated with improved partnership with the Woodland Trust/Harlow District Council for a provision for both the new development and existing Harlow Town Residents.
Focal points within the SANG
From the illustrative diagram displaying the layout of the site, there doesn’t appear to be any focal point (destinations) within the proposed SANG. There is a small wetland creation at the southern extent of the SANG, but given the extensive open aspect of the site, the Conservators believe that increased pond provision within SANG would enhance the appeal and continued success of the SANG.
Air Pollution
The EFDC Local Plan Policy DM22 (Air Quality) and have adopted an Air Pollution Mitigation Strategy (APMS) which sets out the actual measures that the Council will implement during the lifetime of the Plan. These measures seek to limit the increase the increase in traffic volumes through the EFSAC.
The Latton Priory development is not a car free development, and the development proposes an eastern exit onto the B1393 (London Road) which is likely to result in increased traffic volumes going south towards Epping, and specifically Epping Railway Station (Central Line). The Conservators believe that extensive modelling of traffic movements, specifically south on the B1393 would need to be more greatly presented, in order to understand how this prospective increased traffic volume would exacerbate existing traffic movements through the EFSAC.
The Conservators are grateful for the opportunity to comment on this consultation.