Essex County Council, Minerals Planning Consultation, County Hall, Chelmsford, Essex, CM1 1QH
Date: 08/03/2024
Dear Sir / Madam,
Replacement Essex Minerals Local Plan review 2025 to 2040 – Consultation Response
I refer to the above draft plan.
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 (2019, as amended). The site is also a Special Site of Scientific Interest and is protected under the Wildlife and Countryside Act (1981).
The Conservators observe and agree that minerals underpin the construction of
- new homes
- places of work
- transport infrastructure
- essential services such as health, education, and recreational facilities.
The Conservators particular interest in this consultation is that of the proposed outline site of Patch Park Abridge, A63. The Conservators wish to make comment and seek further information on the following matters:
1) Airborne dust and Transport planning within the Epping Forest Special Area of Conservation (SAC) and Site of Special Scientific Interest (SSSI).
2) Impact on the River Roding
3) Future use of the site.
Airborne dust and Transport planning within the Epping Forest Special Area of Conservation (SAC) and Site of Special Scientific Interest (SSSI).
The proposed site lies within 3.2km of both the Epping Forest SAC and SSSI, a fact that is not observed in the Site A63 – report summary. The Conservators would wish to understand how potential airborne dust from the site may impact the Forest.
In respect of the transport provision for the site, the report highlights that the A113 would act as the Main Distributor Road for the site and refers to Appendix. G Transport for full methodology, when this appendix is consulted, it also refers to Appendix. G and provides little detail of the proposed transport routes considered for the site, other than that a new access junction may need to be constructed.
The Conservators wish to indicate at this consultation time, that it is their strongest view that there is a critical need for Essex County Council to ensure that no additional AADT (Annual Average Daily Traffic) occurs as a result of the allocation of this site and furthermore that no aggregate transportation is directed within 200m of the EFSAC. The Conservators believe it is integral part of any planning application made for the site along with an HRA (Habitats Regulation Assessment) and Appropriate Assessment (AA) and an essential s.106 condition for the site if approved by the competent authority.
Impact on the River Roding
The Site A63 document refers to impacts on the river Roding, whilst the site allocation would suggest that this would be an obvious effect, the Conservators would be keen to understand how this potential extraction would affect the downstream of the Roding, notably flooding and sediment transportation.
Future use of the site
The Conservators observe Policy S12 – Mineral Site Restoration and After-Use. We are supportive of the part.2 in ensuring that net biodiversity net gain is achieved following the final restoration. The Conservators would seek more information on what would constitute ‘beneficial’ imported materials for the restoration of the site as part of the final restoration. The Conservators believe that if this site is used as a mineral extraction site, it should post final restoration, provide a place of public recreation benefit in order to reduce recreational impact upon the EFSAC.
The Conservators are grateful for the opportunity to comment on this consultation.