Epping Forest District Local Plan – Submission Version 2017

Supplemental Representations to Site Selection Evidence Base

Dandara Ltd Land to the West of Roydon at Temple Farm

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1.0 Preamble

1.1 These supplemental representations have been prepared in response to an email received from EFDC dated 19th April 2018. The letter acknowledges that the full appendices to the site selection evidence base were not available during the Regulation 19 consultation for the ‘Epping Forest District Local Plan – Submission Version 2017’ (LPSV). Following the Planning Court granting permission for CK Properties Theydon Bois Limited to challenge via judicial review, the Council considers that “… as a result, an opportunity arises to supplement your representations if you would like to do so, to take account of the finalised version of the Site Selection Report and Appendices”.

1.2 Whilst Dandara Ltd welcomes the opportunity to supplement our Regulation 20 representations following the publication of the full site selection evidence base, it remains the case that the LPSV has failed to discharge its statutory obligations under the Town and Country Planning (Local Planning) (England) Regulations 2012. This matter will be considered in detail in association with the upcoming judicial review hearing but we consider it pertinent to set out three fundamental procedural failures not withstanding this additional opportunity to submit representations:

(1) The Regulation 19 LPSV was presented to, and approved for consultation by, Members of EFDC without them having sight of the complete site selection evidence base. When considering whether to approve the LPSV for Regulation 19 consultation, Members were unable to objectively and transparently consider the proposed housing allocations against reasonable alternatives, ‘omission sites’, due to the absence of appendices to the site selection evidence base which are fundamental when making an informed judgement regarding the planning merits of individual sites; (2) Whilst the email circulated by EFDC on 19th April 2018 suggests that those respondents who made reference to the unavailability of the site selection evidence base within their Regulation 20 representations would be provided with an opportunity to supplement these following its publication, this opportunity does not appear to have been extended to all those consulted at Regulation 19 stage. This approach does not provide an opportunity to those who submitted Regulation 20 representations to reconsider their support / opposition to the proposed allocations in light of the availability of the full site selection evidence base and whether the Councils exclusion of sites versus those chosen for allocation was sound; (3) As the site selection evidence base was unavailable for the Regulation 19 consultation period, it must follow that the Council, alongside key evidence base documents such as the SA, did not have the benefit of it when making decisions on site allocations based on ‘reasonable alternatives’. This puts the entire soundness of the Local Plan into question if the full site selection evidence base was not available when officers were recommending and members were making what should be informed and evidenced decisions on site allocations.

1.3 The unavailability of the site selection evidence base during the Regulation 19 consultation period is indicative of the Council’s unashamed objective to submit the Local Plan for examination prior to the, now superseded, 31st March 2018 deadline which was muted as heralding the start of the standard housing methodology for calculating OAHN which would have seen a significant increase in EFDC from the LPSV figure of 514 dpa to 923 dpa. Even

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following the Court granting the JR challenge, Cllr John Philip, the Planning Portfolio Officer reiterated “fortunately, the Government’s deadline extension means the case can be heard without compromising our position” - not focusing on the deficiencies of the evidence base but the potential delay to submission of the Plan. The background to this decision to expedite the preparation of the LPSV is set out in full in the 12th October 2017 report to Cabinet (EB105) including updating the LDS.

1.4 Our representations to the Regulation 19 LPSV raised consistent deficiencies regarding the methodological approach to assessing potential development sites (see Section 4.0). The acknowledged incorrect assessment of land at Temple Farm, Roydon by the Council as part of the 2016/17 site selection process (ref. SR-0303) resulted in a commitment to objectively and transparently reassess the site as part of the ‘tranche 2’ 2018 site selection process (site ref. SR-0303-N).

1.5 Unfortunately, it is evident that the Council’s overriding objective of submitting the LPSV for examination prior to the 31st March 2018 precluded the proper and robust reassessment of ‘tranche 2’ sites under the site selection evidence base and simply predetermined the inclusion of those allocations already contained in the draft Plan. This is explicit in the 12th October 2017 report to Cabinet (EB105) from para. 11 which, despite recognising that “the Council is in the process of assessing 168 new or amended sites, which is far in excess of the quantum of sites originally anticipated …”, nevertheless looks to shorten the Local Plan preparation timetable from an LDS only adopted in March 2017 to achieve the 31st March 2018 submission deadline. The objective of expediting the submission of the Local Plan for examination and having to review significantly more ‘tranche 2’ sites than originally anticipated with the same resource is clearly not compatible and has prejudiced the soundness of the Plan as these supplemental representations will go on to demonstrate.

2.0 Site Selection 2018

2.1 As explained in Section 4.0 of our representations to the LPSV, the incorrect site area for Temple Farm, Roydon was assessed under the site selection 2016/17 process as ref. SR-0303. The Council acknowledged this error and committed to undertaking a ‘without prejudice’ reassessment of the correct site area under ref. SR-0303-N as part of the 2018 site selection ‘tranche 2’ process. It is important to note that this error was significant, with the site selection 2016/17 report considering a site some 40 ha in size with capacity for approximately 1,200 new homes rather than the 200-250 new homes on some 6 ha of developable land promoted by Dandara Ltd through evidence provided to the ‘Epping Forest Developer, Landowner and Promoter Survey 2016’.

2.2 These representations will now focus solely on the methodology employed within the 2018 tranche 2 ‘Site Selection Report’.

Stage 1 and Stage 6.1 A/B Assessment

2.3 Appendix B1.3 of the 2018 ‘Site Selection Report’ (EB805AJ) assesses whether sites put forward for allocation are subject to any major policy constraints. For land at Temple Farm, Roydon (SR-0303-N), it confirms that the site is ‘entirely or partially unconstrained’ having

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regard to the six assessment criteria (stage 1 / stage 6.1A). The site, being ‘tranche 2’, then proceeds to stage 6.1B.

2.4 The ‘Site Selection Methodology’ paper at appendix A of the 2018 ‘Site Selection Report’ (EB805AK) sets out at para. 4.61 four criteria which will be used to determine “… whether a site proposed for residential development accords with the Local Plan strategy and therefore should progress to stage 6.2 …”. Considering land at Temple Farm, Roydon against these four criteria it is concluded in Appendix B1.3 that ‘site is located entirely or partially within a more suitable strategic option and will progress to stage 6.2’.

2.5 This conclusion at stage 6.1B is relevant when these supplemental representations consider the stage 3 / stage 6.3 assessment for site ref. SR-0303-N.

3.0 Stage 2 / Stage 6.2 Assessment

3.1 The ‘Site Selection Methodology’ paper explains at para. 4.63 that the purpose of stage 6.2 is “… to undertake a more detailed quantitative and qualitative assessment of sites to identify the relative suitability of sites for residential or employment development”. Appendix B1.1 of the 2018 ‘Site Selection Report’ (EB805A) confirms that site ref. SR-0303-N proceeds at stage 2 / stage 6.2 for stage 3 / stage 6.3 assessment.

3.2 The stage 2 / stage 6.2 assessment for site ref. SR-0303-N is set out on pg. 110 of appendix B1.4.2, part 3 of the 2018 ‘Site Selection Report’ (EB805Fiii). The proforma for site ref. SR- 0303-N which is reproduced in Appendix 1 of these supplemental representations assesses the site against 32 criteria. There are five possible assessment results associated with each criteria:

(1) Double Positive (++) – Opportunity for development of the site to result in a significant enhancement / benefit; (2) Single Positive (+) – Opportunity for development of the site to result in some enhancement / benefit; (3) Neutral (0) – Likely neutral impact with or without mitigation; (4) Single Negative (-) – Development may result in some harm / detriment that could be reduced / limited alongside mitigation; (5) Double Negative (--) – Development would result in significant harm / detriment that could not be mitigated.

3.3 It is important to note at this stage that the 2018 ‘Site Selection Report’ is specifically assessing sites against evidence provided to EFDC during the ‘Epping Forest Developer, Landowner and Promoter Survey 2016’ and submitted alongside representations to previous iterations of the Local Plan. This is confirmed within the ‘site constraints’ heading for site ref. SR-0303-N which reads “flood constraint on northern part of site … however, proposed site layout provided by promoter accounts for this constraint …”. This is particularly relevant when these supplemental representations go on to consider the rejection of site ref. SR-0303-N during stage 3 / stage 6.3.

3.4 When assessed against the 32 criteria, site ref. SR-0303-N scores a double negative, that is an impact from development that may not be able to be mitigated, against three of the criteria:

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(i) Criteria 4.2 ‘Impact on Agricultural Land’

3.5 Section 4.2 of appendix B1.4.1 of the 2018 ‘Site Selection Report’ (EB805E) explains that “the quality of agricultural land is identified spatially in Natural England’s Regional Agricultural Land Classification Maps … more detailed maps have been prepared on a piecemeal basis; at present, these do not cover Epping Forest District”. The referenced Natural England Regional Agricultural Land Classification Map for the East Region shows land to the west of Roydon, which comprises site ref. SR-0303-N coloured green which equates to Grade 3 ‘good to moderate’ (see Figure 1).

Figure 1: Agricultural Land Classification

3.6 The NPPF defines the best and most versatile agricultural land as “land in grades 1, 2 and 3a of the Agricultural Land Classification” (pg. 50). As recognised within the methodology to the 2018 ‘Site Selection Report’, because no detailed agricultural land classification mapping has been undertaken for EFDC, it is not possible to conclude whether site ref. SR-0303-N comprises Grade 3a or 3b agricultural land. Because only Grade 3a is defined by the NPPF as being the best and most versatile, it is incorrect for criteria 4.2 of appendix B1.4.1 to conclude that “development of the site would involve the loss of the best and most versatile agricultural land”. Because no evidence base exists to sub-divide Grade 3 land into sub-categories (a) and (b) within EFDC, the score given to site ref. SR-0303-N should have been ‘neutral’ rather than ‘double negative’ as it cannot be reasonable demonstrated that the site comprises the best and most versatile agricultural land as defined by the NPPF.

(ii) Criteria 5.1 ‘Landscape Sensitivity’

3.7 The landscape sensitivity of site ref. SR-0303-N will be considered in greater detail under the stage 3 / stage 6.3 assessment below.

(iii) Criteria 6.6 ‘Traffic Impact’

3.8 This criteria awards a double negative on the basis that “moderate peak time congestion expected within the vicinity of the site”. Whilst Section 4.2 of appendix B1.4.1 of the 2018 ‘Site Selection Report’ (EB805E) explains that this conclusion has been reached by ECC’s appointed

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highways consultant Ringway Jacobs using 2015/16 TrafficMaster data, it is considered unevidenced and inconsistent for the following two reasons:

(1) A meeting was held with highway officers at ECC on 9th August 2017 to specifically consider development proposals for site ref. SR-0303-N. This resulted in agreed minutes, signed-off by ECC, which are included at Appendix 2 and concluded that “there were no known highway or junction capacity concerns in Roydon”. No concerns were raised regarding congestion within Roydon during peak times. These minutes were provided to the Council on 18th August 2017 prior to the ‘tranche 2’ assessment work undertaken for the 2018 ‘Site Selection Report’; (2) Site ref. SR-0304 is located on land to the east of High Street, Roydon almost directly opposite site ref. SR-0303-N and is being promoted for a similar number of residential units. Despite the site being located within the centre of Roydon, and locationally being almost identical to SR-0303-N, pg. 111 of appendix B1.4.2 concludes for criteria 6.6 that “area around the site expected to be uncongested at peak time”. As the site is located within the centre of Roydon, such a conclusion is entirely inconsistent and incompatible with that for SR-0303-N and raises significant concerns regarding the robustness of the evidence base, especially when applied at a site specific level.

3.9 Having regard to the site specific meeting held with ECC on 9th August 2017 which did not identify any highway capacity issues in the vicinity of the site, including during peak times being consistent with the proforma entry for site ref. SR-0304, and the inconsistent conclusions drawn for proximate sites within Roydon, it is considered that the score given to site ref. SR-0303-N under criteria 6.6 should have been ‘neutral’ rather than ‘double negative’ as for site ref. SR-0304 immediately to the east.

3.10 Although it is noted from Appendix B1.1 that site ref. SR-0303-N proceeds from stage 2 / stage 6.2 assessment for further testing, it is nevertheless important to note that, putting aside landscape impact, which will be dealt with under stage 3 / stage 6.3, land at Temple Farm, Roydon would not have scored any double negative scores applying the adjustments to the agricultural land (4.2) and traffic impact (6.6) criteria justified above. Furthermore, from a Green Belt impact perspective, criteria 2.1 concludes “… the level of harm caused by release of the land for development would be very low, low or medium”.

4.0 Stage 3 / Stage 6.3 Assessment

4.1 Appendix B1.1 confirms that site ref. SR-0303-N does not proceed at this stage and is excluded from the site allocation process. The justification for the exclusion of the site is provided on pg. 54 of appendix B1.5.2 of the 2018 ‘Site Selection Report’ (EB805I) which reads as follows:

“This site falls within a strategic option which was considered to be less suitable.

The site's suitability was re-considered as part of Stage 6.3 in 2017 since it was identified as potentially being able to contribute to the Council's five year housing land supply. This site scored poorly against several criteria, including landscape sensitivity, and it was considered that it would be harmful to the setting of the Lee Valley Regional Park. Although the site could contribute to the five year housing land supply, it was considered that this benefit did not override the constraints identified and therefore it did not proceed any further”.

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4.2 Pg. 53 of appendix B1.5.2 identifies three strategic options for Roydon comprising ‘intensification’ as a ‘more suitable strategic option’ and ‘eastern expansion’ and ‘western expansion’ as ‘less suitable strategic options’. The ‘western expansion’ strategic option which is of most relevance to site ref. SR-0303-N reads as follows:

“This strategic option is sensitive to change in both landscape and heritage terms, as are the other strategic options identified around Roydon. The Historic Environment Characterisation Study (2015) concluded that the whole area around Roydon is of moderate sensitivity, whilst the Settlement Edge Landscape Sensitivity Study (2010) concluded that all areas around Roydon are highly sensitive to change. However, as a result of its location to the west of Roydon, this strategic option would be the most harmful to the Lee Valley Regional Park relative to the other strategic options in the settlement. The strategic option would conflict with the statutorily defined purpose of the Park - "a place for the occupation of leisure, recreation, sport, games or amusements or any similar activity, for the provision of nature reserves and for the provision and enjoyment of entertainments of any kind" (Section 12(1), Lee Valley Regional Park Act 1966) - risking the incursion of inappropriate development into the Park.

This strategic option is less harmful to the Green Belt. This is evidenced by the Green Belt Review: Stage 2 (2016) which concluded that the loss of parcels 064.7 and 064.8 would have a moderate and low impact upon the Green Belt respectively. The northern part of the strategic option is located within Flood Zones 2 and 3, for the most part the strategic option lies within Flood Zone 1. Additionally, the northern part of the strategic option is located close to Roydon railway station. However, it is considered that the harm identified to the Lee Valley Regional Park, as well as its location away from village centre amenities would, at the settlement level, outweigh any positive factors associated with this strategic option”.

4.3 If site ref. SR-0303-N has failed stage 3 / stage 6.3 partly due to falling within a strategic option which is considered ‘less suitable’ (n.b. in conflict with the stage 6.1B conclusion at Appendix B1.3), it is important to understand those stated aspects of the strategic option which make it unable / unsuitable to accommodate development:

(1) Heritage – Whilst the ‘western expansion’ strategic option is noted as being sensitive to change in heritage terms, the assessment references the ‘Historic Environment Characterisation Study’ (2015) which concludes that “the whole area around Roydon is of moderate sensitivity”. As the evidence base considers that the entirety of Roydon is of moderate sensitivity, and the LPSV proposes housing allocations on Greenfield land surrounding the settlement, it is not considered that heritage impact is a reason for concluding that ‘western expansion’ is less suitable. This is particularly relevant for site ref. SR-0303-N for which criteria 1.8a ‘impact on heritage assets’ of appendix B1.4.2 of the 2018 ‘Site Selection Report’ concludes that “site is located within a Conservation Area or adjacent to a listed building or other heritage asset and effects can be mitigated”; (2) Landscape (General) – As explained above in the context of appendix B1.4.2 of the 2018 ‘Site Selection Report’, criteria 5.1 ‘landscape sensitivity’ explains in the context of site ref. SR-0303- N that “site falls within an area of high landscape sensitivity – characteristics of the landscape are vulnerable to change and unable to absorb development without significant character change”. Appendix B1.4.1 explains that the assessment of ‘landscape sensitivity’ within criteria 5.1 is “… based on the findings of the Council’s Settlement Edge Landscape Sensitivity (SELS) Assessment (2012)”. As recognised within the appendix B1.5.2 strategic summary

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option for ‘western expansion’ reproduced above, because the SELS concludes that all areas around Roydon are highly sensitive to change, and the LPSV proposes housing allocations on Greenfield land surrounding the settlement, it is not considered that landscape impact is a reason for concluding that ‘western expansion’ is less suitable. Landscape impact associated with development of site ref. SR-0303-N specifically will be considered latterly in these supplemental representations alongside impact upon the setting of the Lee Valley Regional Park (LVRP); (3) Amenities – Appendix B1.5.2 considers that the ‘western expansion’ strategic option is considered less suitable due to its “… location away from village centre amenities …”. This conclusion is not only fundamentally incorrect, see Section 3.0 of our representations to the LPSV and the ‘Trip Distribution and Accessibility Technical Note’ included at Appendix 3, but also conflicts with the appendix B1.4.2 assessment proforma for site ref. SR-0303-N which ascribes positive values to a range of criteria including distance to rail/tube station (criteria 3.1), distance to employment locations (criteria 3.3), distance to local amenities (criteria 3.4) and distance to nearest infant/primary school (criteria 3.5). The assessment within the ‘western expansion’ option regarding access to amenities is fundamentally flawed and inconsistent with other parts of the evidence base.

4.4 It is evident from the above assessment that the ‘western expansion’ strategic option for Roydon cannot be considered ‘less suitable’ due to heritage and general landscape sensitivity because the supporting EFDC LPSV evidence base does not identify land to the west of the settlement as being any more sensitive than to the north, east and south. As the LPSV proposes to allocate Greenfield land surrounding Roydon to accommodate new homes, heritage and general landscape sensitivity cannot therefore be considered a finite constraint to justify the ‘less suitable’ categorisation of land to the west of the settlement and the exclusion of site ref. SR-0303-N at stage 3/ stage 6.3.

4.5 Because land to the west of Roydon is recognised within the appendix B1.5.2 assessment as being less harmful to the Green Belt, with the ‘Green Belt Review: Stage 2’ (2016) concluding the requisite parcels would have a low to moderate impact upon the Green Belt, coupled with the proximity to Roydon railway station and the results of the appendix B1.4.3 ‘Community Choices Feedback’ (EB805G) which for ROY-C (see figure 2) concludes that “… the area could accommodate and potentially benefit from small pockets of sympathetic development near to existing residential settlements”, the assessment relies solely on detriment to the setting of the LVRP to justify the ‘less suitable’ conclusion and ultimately, rejection of site ref. SR-0303- N.

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Figure 2: Community Choices Parcels

Lee Valley Regional Park

4.6 Appendix B1.5.2 of the 2018 ‘Site Selection Report’, recognising that the sensitivity of landscape to change around Roydon is effectively equal, qualifies the sensitivity of landscape to the west of the settlement by reference to the setting of the LVRP and particularly the perceived conflict between development and Section 12(1) of the LVRP Act 1966. The ‘western expansion’ strategic option was therefore considered ‘less suitable’ due to “… this strategic option would be the most harmful to the LVRP relative to the other options in the settlement”. Likewise, for site ref. SR-0303-N, “… it was considered that it would be harmful to the setting of the LVRP”.

4.7 It is considered that the classification of the ‘western expansion’ of Roydon as ‘less suitable’ coupled with the rejection of site ref. SR-0303-N at stage 3 / stage 6.3 is unevidenced, unjustified and ultimately unsound based on landscape sensitivity and more specifically harm to the setting of the LVRP. This is on the following basis:

(1) Absence of Baseline Assessment

4.8 Appendix B1.5.2 fails to assess the existing contribution of land to the west of Roydon to the setting and Section 12(1) function of the LVRP, assuming that, compared to the baseline condition, development would automatically result in harm. Site ref. SR-0303-N currently accommodates a poultry farm with associated outbuildings which are visually intrusive and harm both the setting and wider function of the LVRP with limited public access. This baseline context is recognised within the adopted Park Development Framework (2010 and 2011) which specifically identified the part of the LVRP which exactly corresponds with site ref. SR-0303-N as ‘landscape enhancement area’ meaning ‘mixture of strong and weaker landscape character requiring enhancement through design / management’. Figure 3 refers, reproduced in full in appendix 4.

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Figure 3: Park Development Framework Extract

4.9 The LVRPA’s own adopted Park Development Framework (PDF) therefore identifies the eastern extent of the Park adjacent to Roydon, which equates to land promoted for development under ref. SR-0303-N as comprising weaker landscape character which requires enhancement through intervention. The draft PDF Area 7 ‘landscape and heritage’ map likewise shows the eastern part of Temple Farm as a ‘harsh visually detracting edge / investment area’. For the 2018 ‘Site Selection Report’ to be robust, it must therefore assess the baseline character of land surrounding Roydon and its contribution to the setting of the LVRP. It is not sound to simply assume that all land within the setting of the LVRP positively contributes to the Section 12(1) objectives and therefore any development would be harmful. The exact opposite is true in the case of Temple Farm where the existing agricultural use is harmful to the visual setting and physical function of the LVRP and as recognised within the PDF itself, sensitive development presents an opportunity to enhance the role of the land to better achieve the objectives of Section 12(1).

(2) Absence of Site Specific Assessment

4.10 As explained in the context of appendix B1.4.2 of the 2018 ‘Site Selection Report’, consideration has been given to some site specific information provided to the Council for site ref. SR-0303-N under the ‘Epping Forest Developer, Landowner and Promoter Survey 2016’ and representations to the LPSV, particularly in respect of flood risk. However, there is no indication either within the appendix B1.4.2 assessment proforma or appendix B1.5.2 that Masterplan work submitted to the Council for site ref. SR-0303-N, which includes a layout informed by the extensive Green Belt and landscape assessment work included at Appendix 5, has likewise been taken into consideration. If the 2018 ‘Site Selection Report’ has failed to consider the baseline character of the land or how sensitive, landscape-led development could be introduced as part of wider enhancement proposals, the conclusions regarding harm to the setting of the LVRP are neither robust, justified nor sound.

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4.11 This approach is inconsistent with proposed allocations within the LPSV, taking Jessel Green as an example, where extensive Masterplan work has been produced and assessed as part of the site selection process to mitigate, in that case, significant issues regarding the loss of public open space.

(3) Landscape Impact

4.12 As explained in detail within Section 5.0 of our representations to the LPSV, the site specific proposals for the introduction of between 200-250 new homes on site ref. SR-0303-N at Temple Farm, Roydon have been carefully informed by site specific Green Belt and landscape assessment work undertaken by specialist landscape consultancy Define and included at Appendix 5. This assessment work proposes development on a parcel of land which closely integrates with the existing settlement, currently accommodates intrusive poultry sheds, is visually contained by topography / mature vegetation and is distinct from the more open valley sides to the west moving within the LVRP towards the River Stort. This distinct character of SR-0303-N is recognised within the Council’s own SELS which, at para. 8.1.2, notes that whilst “… the western edge of the village comprises a large arable field (Roydon Park) which cloaks a hill, sloping downwards to the west towards the Lee Valley … a series of smaller-scale arable fields which are lined with mature hedgerows are situated at the settlement edge”.

4.13 There is no evidence that the 2018 ‘Site Selection Report’ has considered site specific Masterplanning and associated Green Belt and landscape assessment work (n.b. unlike extant draft allocations such as Jessel Green) due, we suspect, to the publicised objective of submitting the Plan for examination prior to 31st March 2018. Whilst the SELS is a helpful evidence base document which looks at larger, strategic parcels of land surrounding settlements, it is less helpful when moving on to consider specific sites and particularly those whose character significantly differs from the wider parcel. The limitation of this ‘macro- scale’ assessment approach is detrimental to otherwise inherently sustainable sites such as Temple Farm, Roydon where the urban fringe character abruptly changes into rolling countryside with significant topographic and vegetation changes beyond the initial urban fringe.

4.14 We did look to obtain clarification from EFDC on whether site specific evidence was taken into account regarding landscape impact under the 2018 ‘Site Selection Report’ without a satisfactory answer being provided. This correspondence is included at Appendix 6.

(4) LVRP Enhancement

4.15 Just as the existing baseline condition of the site has not been considered within the 2018 ‘Site Selection Report’ expanded upon in point (1) above, likewise there is no consideration of how development may enhance the accessibility, usability and recreation / leisure value of the LVRP in accordance with its Section 12(1) remit. The information submitted to the Council under the ‘Epping Forest Developer, Landowner and Promoter Survey 2016’ and representations to the LPSV demonstrate the significant benefits to the LVRP associated with delivering a circa 22 ha new ‘country park’ which would provide a new gateway into the LVRP

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from Roydon and its mainline station. The opportunities associated with the development of site ref. SR-0303-N are explained in detail in paras. 5.15-5.19 of our LPSV representations including how enhancing the accessibility, usability, enjoyment and value of the LVRP fully accords with the Section 12(1) remit and has failed to be considered within the ‘Site Selection Report’ evidence base. This is particularly disappointing given the explicit recognition within the LVRPA’s own PDF that site ref. SR-0303-N comprises weaker landscape character components which require enhancement through design or management, alongside the objectives of the emerging PDF proposals for Area 7 that Roydon station becomes a new gateway into the park facilitated by improvements to the identified ‘harsh visually detracting edge / investment area’ surrounding the settlement by Temple Farm. No consideration has been given to how development, with specific reference to the Masterplan proposals, could assist in achieving these objectives.

(5) Settlement Edge

4.16 Whilst site ref. SR-0303-N is rejected partly due to falling within the less suitable ‘western expansion’ option, it is unclear why SR-0303-N is not considered under the ‘most suitable strategic option’ referred to as ‘intensification’ which “encompasses small areas of Green Belt to the south, east and west of Roydon” (appendix B1.5.2). Sites such as SR-0304, SR-0117 and SR-0976 are no materially different to SR-0303-N, directly adjoining the settlement boundary on Green Belt land up to a legible, defensible boundary. As site ref. SR-0303-N immediately adjoins the settlement boundary, and extends to a single field boundary in depth up to a legible defensible boundary, it is unclear why it is not considered under the ‘intensification’ option as ‘most suitable’. Even if the 2018 ‘Site Selection Report’ considered parcel SR-0303- N was too large to be considered ‘intensification’, for methodological consistency, the site should have been sub-divided as is the case for site ref. SR-0304 which proceeded at stage 3 / stage 6.3 for further testing.

Figure 4: Illustrative Masterplan

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5.0 Conclusion

5.1 These supplemental representations have been prepared following the failure of the Council to provide full appendices to the 2018 ‘Site Selection Report’ during the Regulation 19 consultation to the LPSV. They demonstrate that despite site ref. SR-0303 being incorrectly assessed during the original 2016/17 ‘Site Selection Report’, and the stated commitment of the Council to undertake a ‘without prejudice’ tranche 2 reassessment, they have failed to properly consider site ref. SR-0303-N having regard to information provided during the ‘Epping Forest Developer, Landowner and Promoter Survey 2016’ and representations to the LPSV.

5.2 They demonstrate that site ref. SR-0303-N passes the stage 1 / stage 6.1, stage 6.1B and stage 2 / stage 6.2 sieve. It is however excluded at stage 3 / stage 6.3 principally because the site itself, and the wider ‘western expansion’ strategic option, is considered sensitive from a landscape perspective and detrimental to the setting of the LVRP. These supplemental representations have shown that this conclusion is fundamentally flawed and has failed to consider the baseline character of the site which the LVRPA PDF recognises as requiring enhancement through design and management due to elements of weaker landscape character and an existing harsh, visually detracting settlement edge. Furthermore, it has failed to consider site specific Masterplanning work informed by independent Green Belt and landscape assessment which makes a clear distinction between the part of Temple Farm proposed to accommodate development which integrates with the settlement edge and is physically and visually self-enclosed and the more open parts of the site which contribute to the setting of the LVRP. This approach is inconsistent with the explicit consideration given the Masterplanning associated with extant allocations within the LPSV.

5.3 The information provided to the Council associated with the ‘Epping Forest Developer, Landowner and Promoter Survey 2016’ and alongside representations to the LPSV demonstrates how the western part of Temple Farm could be dedicated as a new ‘country park’ which would improve the accessibility, usability and recreational / leisure value of the LVRP in full accordance with its Section 12(1) remit. Acknowledging the existing condition of site ref. SR-0303-N having regard to the LVRPA PDF, the Council should have explicitly considered the benefits of development to improving the setting of this part of the LVRP.

5.4 Instead, the 2018 ‘Site Selection Report’ has failed to assess the existing contribution of site ref. SR-0303-N to the setting of the LVRP and has assumed any development would automatically harm the setting. The LPSV has excluded an inherently sustainable site from consideration by failing to properly assess the available evidence base due, we suspect, to the overriding objective of submitting the Plan for examination by 31st March 2018 rather than producing a sound Plan which is positively prepared, justified and effective.

5.5 We would respectfully ask the Inspector to advise the Council to revisit their 2018 ‘Site Selection Report’ to ensure that all site specific evidence has been considered and no sites have been excluded due to an inconsistent, unevidenced and unjustified assessment process which has failed to consider all available evidence due to the conscious expedition of the Plan to examination.

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List of Appendices:

• Appendix 1 - Site Selection SR-0303-N Proforma • Appendix 2 - Agreed ECC Highways Meeting Note • Appendix 3 - Trip Distribution and Accessibility Note • Appendix 4 - Park Development Framework Extract • Appendix 5 - Independent Green Belt and Landscape Assessment • Appendix 6 - Email Correspondence with EFDC

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Appendix 1

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Appendix 2

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Meeting Note

Meeting Details Project Title: Land at Roydon Date: 09/08/2017 Project No.: 02214 Time: 11:00 Subject: Transport Scoping Meeting Venue: ECC Offices, Chelmsford Matthew Lane (ML) – ECC John Richards (JR) – Dandara Present: Matthew Franklin (MF) – PJA Nick Woolley (NW)- PJA Apologies: -

Matters Arising Actions Development Overview (JR) • Positive meeting with Epping Forest DC, development looked upon favourably; • Looking to secure Green Belt release through Local Plan process;

1 • Development quantum confirmed to be ca. 250 units; • Confirmed that any application would be in outline with all matters reserved apart from access; • Meeting objective to identify any highways issues that may affect allocation and subsequent development of the site. Site Access and Public Rights of Way MF stated that one vehicle access point would be provided, designed in accordance with Development Construction Manual guidance for a Feeder Road type. The proposed

development site has a 5m right of way through the newly constructed development site off

Epping Road that could be used for emergency access.

ML confirmed that the Essex Design Guide is currently being updated, however he didn’t

envisage any changes to the updated road type specifications.

ML continued that one point of access would be acceptable, with any need for an

emergency access would have to be agreed with colleagues.

2 MF Stated that footways toward the station and village centre would be provided, with

details to be confirmed following acquisition of highway boundary data.

ML Pedestrian/cycle connection to the south would be required regardless whether or not

an emergency access is required.

ML stated that ECC would be satisfied for PRoW within the site to be upgraded, provided

that maintenance costs to the council are not increased. It should be ensured that all off-site

connections are viable and can be achieved given third party ownership PJA

Action: Highway boundary information to be obtained to confirm opportunities for future footway connections as plan develops.

Accessibility

MF confirmed that there is a Railway Station, Primary School and Convenience Store all

within 5 minutes walk of site; 3 JR noted that Roydon had the only mainline station in Epping Forest District.

ML questioned whether rail travel would actually offer a realistic opportunity for sustainable

journeys to work, as current bus service provision is poor.

LOCATION The Aquarium TELEPHONE +44 (0) 118 956 0909 WEBSITE philjonesassociates.co.uk King Street EMAIL [email protected] Reading RG1 2AN

Matters Arising Actions MF asserted that major employment sites in Harlow and Central London are easily accessible by train, and that the site is perhaps more accessible by public transport modes as those located on the edges of larger settlements such as Harlow.

Action: Additional assessment of sustainability to be undertaken looking at existing travel patterns for Roydon and workplace destinations that are accessible by public transport. PJA Parking MF confirmed that parking would be provided in accordance with ECC parking standards. ML confirmed that the ECC standards are adopted for Epping Forest. A garage counts as a 4 space if greater than 3m x 7m. ML principle of providing additional parking for the station is unlikely to be favourable as would likely encourage greater car trips to access the station. If supported by EFDC, Network Rail and / or Roydon Parish Council ECC would not however necessarily object. Local Assessments / Modelling ML confirmed there were no local or strategic Transport Assessments or existing modelling that could be used to identify the impact of the development. MF confirmed that traffic surveys had been undertaken at the level crossing and further surveys would be undertaken for the planning application stage. ML confirmed that there were no known highway or junction capacity concerns in Roydon 5 and due to no substantive growth currently being proposed within the emerging Local Plan, there are no known projects towards which S106 contributions from any future development would be directed. PJA

Action: Further traffic surveys to be undertaken to inform a Transport Assessment with junction locations to be determined by the Trip Generation and Distribution Traffic Modelling to Date – Level Crossing MF detailed traffic modelling undertaken by PJA to date. Surveys of the crossing showed queueing in the peak hours, however the queue cleared after every cycle. ML did not express any specific concerns about the development impact on the level 6 crossing or the impact of queues upon the development when the barriers are lowered, as no mitigation at the crossing is feasible. ML stated that the development would require provision of Keep Clear markings at the site entrance. Trip Generation/Distribution MF confirmed that trip generation figures used for previous assessments were based on a

first principles methodology.

ML questioned the validity of the methodology and requested a comparison exercise was

undertaken using TRICS.

MF stated that previous distribution was based on the tidality of traffic flows at the level 7 crossing only.

ML requests that 2011 JtW data was used for any assessments henceforth

Action: First Principles Trip Generation to be validated by comparison to TRICS. Future Trip PJA Distribution to be based on JTW assessment of Roydon.

Future Capacity modelling MF proposed that the site access, railway crossing and High Street/Epping Road junction only would be modelled for a planning application. 8 ML requested that development traffic impact on the corridor into Harlow was reviewed, based on the revised distribution. ML further stated that there may be a requirement to model the Pinnacles roundabout dependent on revised traffic flows.

LOCATION The Aquarium TELEPHONE +44 (0) 118 956 0909 WEBSITE philjonesassociates.co.uk King Street EMAIL [email protected] Reading RG1 2AN

Matters Arising Actions ML stated that there were no committed developments in the area specifically required for cumulative assessment PJA Action: Transport Assessment to quantify development impact on corridor into Harlow in addition to assessments at Site Access, Railway Crossing and High Street / Epping Road junction.

Travel Plan ML confirmed that the threshold for a development to require a full Travel Plan is 250 units. 9

Action: Subject to final development quantum a Full Travel Plan would be prepared in PJA support of any future application Summary • No concerns raised regarding the principle of single point of access from High Street; • Further work required to demonstrate the accessibility of the site; • Pedestrian connections to be maximised subject to land constraints; 10 • Queuing at level crossing does not represent a significant concern. Access to be designed with Keep Clear markings. • Future assessment to compare trip generation to TRICS and trip distribution to be based on JTW data which would then confirm extent of assessment required in Transport Assessment.

Distribution: All attendees

LOCATION The Aquarium TELEPHONE +44 (0) 118 956 0909 WEBSITE philjonesassociates.co.uk King Street EMAIL [email protected] Reading RG1 2AN

Saxon Izatt

From: Matthew Lane, Strategic Development Engineer Sent: 18 August 2017 11:52 To: Nick Woolley Cc: Matt Franklin; John Richards Subject: RE: Land at Roydon - Minutes

Hi Nick

I’m happy with the minutes and don’t have anything to add.

Kind regards

Matt

Matthew Lane Strategic Development Engineer Transportation, Planning and Development

Essex County Council | telephone: 03330 130591 | mobile: 07747 486164 | email: [email protected] Please consider the environment before printing this e‐mail

The Highway Authority is now charging for all pre-planning application advice, full details can be found here – Pre- App Charging

From: Nick Woolley [mailto:[email protected]] Sent: 16 August 2017 14:47 To: Matthew Lane, Strategic Development Engineer Cc: Matthew Franklin; John Richards Subject: Land at Roydon - Minutes

Matt,

Please find attached minutes from our meeting last week. Could you confirm that you’re happy with them as a representation of our discussions and provide any comments.

Kind Regards, Nick

Nick Woolley | Phil Jones Associates 16 The Aquarium, 1-7 King Street Reading, RG1 2AN T. 0118 956 0909

1

The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware.

This email (including any attachments) is intended only for the recipient(s) named above. It may contain confidential or privileged information and should not be read, copied or otherwise used by any other person unless express permission is given. If you are not a named recipient, please contact the sender and delete the email from your system. It is the recipient's responsibility to ensure that appropriate measures are in place to check for software viruses.

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Appendix 3

17 | Page

Technical Note

Project: Land at Roydon

Subject: Trip Distribution and Accessibility

Client: Dandara Version: A Project No: 02214 Author: NW Date: 30/08/2017 Approved: MF 1 Overview

1.1.1 Following a pre-application meeting and subsequent discussions with Essex County Council (ECC) Highways Development Control, Phil Jones Associates (PJA) has been requested to provide further justification for assertions made within initial scoping reports regarding site accessibility and trip distribution.

2 Trip Distribution

2.1 Journeys to Work

2.1.1 Following an initial scoping meeting on 9th August, ECC requested that an additional assessment of sustainability should be undertaken, looking at existing travel patterns for Roydon and workplace destinations that are accessible by public transport.

2.1.2 2011 Journey to Work (JtW) Census data has been used to calculate the likely distribution of residential development trips. Middle Super Output Area (MSOA) Epping Forest 002, within which the development site is located was used to provide an accurate general representation of where people are likely to travel to work from the site.

LOCATION The Aquarium TELEPHONE +44 (0) 118 956 0909 WEBSITE philjonesassociates.co.uk King Street EMAIL [email protected] Reading RG1 2AN

Figure 2-1: Regional Journey to Work Destinations (All Modes)

2.1.3 Figure 2-1 illustrates likely trip end destinations via all modes, both on a regional and local level. and indicates that journeys to work are reasonably self-contained within Epping Forest and Eastern /West Essex. Notwithstanding this, workplace destinations further afield in Central London can be accessed from Roydon Railway Station, in close proximity to the site.

2.1.4 According to 2016 National Travel Survey (NTS) data, rail trips contribute 7% of total journeys to work in the England. Based on 2011 Census JtW data, Roydon compares favourably in this regard, with 13% of commuters in Roydon travelling by train.

2.1.5 By changing trains in Harlow (a 4 minute journey), train services to a number of other key workplace destinations are available, including Stansted Airport, Chelmsford and Brentford.

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Figure 2-2: Local Employment

Ware

Harlow

Hoddesdon

Lower Nazeing

2.1.6 Figure 2-2 furthermore illustrates likely trip end destinations at a local level based on output area data. Consistent with the plans above, key local and regional workplace destinations includ:

2.1.7 With regards to cycling the average trip length in England is 5.6km (National Travel Survey, 2016) which equates to a circa 20-minute cycle distance. Data provided within the NTS is categorised as ‘all other private transport’ only (includes motorcycle and private bus as well as cycles). Cycle and motorcycle trips comprise the same proportion of all trips, and for the purposes of this assessment, it has been assumed that motorcycle and private bus average trip lengths are closer to that of the private car, giving a higher average for this category. By removing these modes, a more realistic figure of 7.4km for rural bicycle journeys has been calculated.

2.1.8 National Cycle Network 1 routes in close proximity to the site, along High Street. A traffic-free route provided for much of the route towards Hoddesdon, with on-carriageway provision to key employment destinations in Harlow.

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2.1.9 GIS analysis of the above census data notes that 33% of existing employment trips by residents of Roydon lie within a 5km distance from the site, which as demonstrated above represents a conservative estimate of how far residents of the site are likely to travel.

2.1.10 Figure 2-2 furthermore illustrates likely trip end destinations at a local level based on output area data. Consistent with the plans above, key local and regional workplace destinations including:

Table 2-1: Top 15 JtW Destinations Ranki Location Employers Access via Sustainable Modes Travel Time1 ng 1 Roydon Plants Galore, UK Salads, Cycling. Low traffic route via Low 12 Minutes Roydon Primary School Hill Road 2 Harlow The Pinnacles, Harlow Cycling. NCN 1 via Harlow Road 13 Minutes Business Park (North) Public Transport. 381 Bus 19 Minutes (leave site at 08:34) departing at 08:44 only. 3 City of London Various Public Transport. Half hourly direct Ca. 1 hour service to London Liverpool St, Central line. 4 Hoddesdon Hoddesdon Town Centre, Cycling. NCN 1 off road path 16 Minutes Belcon Industrial Estate 5 Hoddesdon Rye House Power Station, Cycling. As above 11 Minutes Sainsbury’s Distribution 6 Harlow Harlow Town Centre Cycling. NCN 1 via Harlow Road 18 Minutes Public Transport. Half hourly service to Harlow Town, 2 bus into Harlow centre 7 Harlow Templefields, Tesco Public Transport. Half hourly 25 Minutes service to Harlow Town, 20 minute walk. 8 Harlow Princes Gate Public Transport. Half hourly 23 Minutes service to Harlow Town, 15 minute walk. 9 Hoddesdon Sheredes School, St Cross Public Transport Half hourly 22 Minutes School, Hoddesdon Health service to , 15 minute Centre walk 10 Epping Tesco, Marks and Spencer Public Transport. Two hourly 29 minutes service to Epping (07:06 only) Public Transport Ca. 1 hour Train to Harlow Town, two buses (Arrival between 08:00 and 09:00) 11 Broxbourne/Lo Hillgrove Business Park Public Transport Half hourly 30 Minutes wer Nazeing service to Broxbourne, 25 minute walk

1 Google Maps – Arrival time of between 08:00 and 09:00 unless otherwise stated

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Ranki Location Employers Access via Sustainable Modes Travel Time1 ng 12 Harlow Sainsbury’s, Princess Public Transport. Half hourly 26 Minutes Alexandra Hospital service to Harlow Town, 14 bus. 13 Waltham Cross Stirling Business Park Public Transport. Half hourly 27 Minutes service to Waltham Cross, 11- minute walk. 14 Hoddesdon John Warner School Cycling. NCN 1 off road path 14 minutes

15 Epping Q-Deck Public Transport. Two hourly 29 minutes service to Epping (07:06 only) Public Transport Ca. 1 hour Train to Harlow Town, two buses (Arrival between 08:00 and 09:00)

2.1.11 In section 4, paragraph 29 of the NPPF, the Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas.

2.1.12 It is demonstrated that key employment destinations are already well catered for by a network of national and local cycle routes. It is clear that in accordance with NPPF above, development would be sited where access to public transport modes is optimised, regardless of personal choice thereafter.

2.2 Potential Journeys to Work

2.2.1 The analysis presented above is based on the existing travel patterns of residents in Roydon. Additional GIS analysis has been undertaken to understand where potential residents of the site could commute to within an hour of the site (via public transport only). Figure 2-3 illustrates the centroids of Lower Super Output Areas accessible within 1 hour of public transport only23:

2Departure at 8:00 assumed 3 Calculated using journey time information from Google Maps, and includes walking distances

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Figure 2-3: One Hour Commuting Time via Public Transport

2.2.2 The GIS analysis reveals that 1,483,988 jobs4 are available within a one-hour commuting time of the site. Notwithstanding the current pattern of employment trips within Roydon, potential residents of the site benefit from good access to employment via public transport. Currently 13% of journeys to work are undertaken by public transport, but given the number of jobs available within a one hour commuting time there is potential for this proportion to increase, particularly as a result of an effective Travel Plan at the proposed development.

2.3 ‘Other’ Journeys

2.3.1 In this instance ‘other’ journeys refer to non-commuting journeys to school, recreation, health, and retail.

2.3.2 Guidance provided by the Institution of Highways and Transportation (IHT) in their publication ‘Guidelines for Providing for Journeys on Foot’ (2000) suggests that in terms of walking to school and recreational journeys; walk distances of up to 2,000 metres can be considered as a preferred

4 WP101EW - Population (Workplace population)

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maximum with ‘desirable’ and ‘acceptable’ distances being 500 and 1,000 metres respectively. It should however be noted that journeys of a longer length are often undertaken.

2.3.3 For other non-commuter journeys, the guidance suggests that walk distances of up to 1,200 metres can be considered as a preferred maximum, with the ‘desirable’ and ‘acceptable’ distances being 400 and 800 metres respectively. Again, it should be noted that journeys of a longer length are often undertaken.

2.3.4 Figure 2-4 indicates the location of local amenities and attractions relative to the site.

Figure 2-4: Local Amenities

2.3.5 Figure 2-4 shows that the railway station, a primary school, and a convenience store are all located within 5 minutes walk of the site. Secondary education, employment and healthcare provision are located less than 5km in Harlow, which as discussed as easily accessible by bike.

2.3.6 As discussed, a bus route with services every two hours serves Roydon, with non-employment trips to key retail and leisure facilities in Epping and Harlow possible.

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2.3.7 Lee Valley Park is also located directly adjacent to the site, with leisure trips possible via a network of off road footpaths.

2.4 Summary

2.4.1 It has been demonstrated that the proposed development site is readily accessible via sustainable modes. Based on existing data trends, 33% of predicted employment trips are located within 5km of the site, with National Cycle Network Route 1 allowing traffic free access to key destinations in Hoddesdon and Harlow.

2.4.2 Roydon Railway Station is located less than 200m to the site access, and provides direct services to London Liverpool Street and Harlow Town. Further key destinations, including Stansted Airport can be accessed via Harlow. The close proximity of the station is a key benefit in relation to journeys to work as it means that almost 1.5m jobs are within a one hour commuting distance of the development.

2.4.3 In the context of Paragraph 29 of the NPPF, which states “the government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas” it is clear than the proposed development site represents a sustainable rural location for development.

3 Route Assignment

3.1.1 This note has so far considered potential employment destinations only, however ECC have also requested clarification regarding vehicular trip distribution and assignment, specifically to inform the scope of any future capacity modelling that be required.

3.1.2 The previous note considered journeys to work only, therefore modal split data by journey purpose has been extracted from TEMPRO for the local area (Epping Forest 002), with the full data for Car Drivers provided in Table 3-1.

Table 3-1: Vehicle Trips by Journey Purpose Journey Destination AM Peak PM Peak Arrival Departure Arrival Departure Work 77% 71% 60% 59% Education 8% 11% 5% 4% Retail/Leisure 15% 18% 34% 37%

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3.1.3 Further clarification was also required regarding trip generation methodologies. The scoping note submitted to ECC was based upon a ‘first principles’ methodology, further details of which can be seen within the appended scoping note.

3.1.4 It was requested that a sensitivity test was undertaken using TRICS, as is based on the following selection parameters:

• Sites in England Only; • Sites with between 50 and 500 dwellings; and • Located in a Suburban Area.

3.1.5 Table 3-2 shows a comparison of the first principle and TRICS trips rates.

Table 3-2: Trip Rate Comparison (Person Trips) AM Peak PM Peak Arrival Departure Two-Way Arrival Departure Two-Way TRICS 0.171 0.633 0.804 0.614 0.337 0.951 First Principles 0.254 0.761 1.014 0.469 0.253 0.721

3.1.6 On the basis that the TRICS rates present a slightly higher combined peak figure, it is proposed to utilise these rates for the remainder of this assessment.

3.1.7 Table 3-2 presents a person trip rate only. As part of the same TRICS analysis, vehicle trip rates have also been extracted.

Table 3-3: Trip Rate Comparison (Vehicle Trips) AM Peak PM Peak Arrival Departure Two-Way Arrival Departure Two-Way TRICS Trip Rate 0.112 0.332 0.444 0.361 0.203 0.564 Trip Generation (280 Dwellings) 31 93 124 101 57 158

3.1.8 The car driver trips above have been applied to the percentages derived within Table 3-1, with a summary of trip generation by journey purpose is detailed in Table 3-4.

Table 3-4: Trip Rate Comparison (Vehicle Trips) Journey Destination AM Peak PM Peak Arrival Departure Two-Way Arrival Departure Two-Way Work 24 66 90 61 34 95 Education 3 10 13 5 2 7 Retail/Leisure 5 17 21 35 21 56 Total 31 93 124 101 57 158

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3.2 Journeys to Work (Vehicular)

3.2.1 2011 Journey to Work Census data has been used to calculate the employment trip distribution. The distribution of vehicular employment trips from Middle Super Output Area (MSOA) (Epping Forest 002) has been used as a proxy for the distribution of vehicle trips from the proposed development.

3.2.2 The number of trips to each MSOA has been uploaded to GIS mapping software and represented as a proportion of the total vehicular trips to work. This data and the resultant trip generation is provided in Table 3-5:

Table 3-5: Route Assignment (Journeys to Work Only) Journey Destination AM Peak PM Peak Percentage Traffic Arrival Departure Two-Way Arrival Departure Two-Way B181 North (Towards 41% 10 27 37 25 14 39 Stanstead St Margarets) B181 South (Towards Lower Nazeing, 36% 9 24 32 22 12 34 Hoddesdon, Epping and Waltham Abbey) Harlow Road (Towards 23% 5 15 20 14 8 21 Harlow) Total 100% 24 66 90 61 34 95

3.3 Journeys to Education

3.3.1 Roydon Primary School is located in close proximity to the site, it is envisaged that all primary school age children will attend this school. In terms of secondary school provision, Roydon Primary School has ties with schools in Harlow, and it is expected that children attending secondary school will travel to Harlow. For the purposes of this assessment, a 50:50 trip split between primary and secondary schools is assumed.

Table 3-6: Route Assignment (Education Only) Journey Destination AM Peak PM Peak Percentage Traffic Arrival Departure Two-Way Arrival Departure Two-Way B181 North (Towards 0% 0 0 0 0 0 0 Stanstead St Margarets) B181 South (Towards Lower Nazeing, 50% 1 5 6 3 1 4 Hoddesdon, Epping and Waltham Abbey) Harlow Road (Towards 50% 1 5 6 3 1 4 Harlow)

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Journey Destination AM Peak PM Peak Percentage Traffic Arrival Departure Two-Way Arrival Departure Two-Way Total 100% 3 10 13 5 2 7

3.4 Journeys to Retail

3.4.1 While convenience retail provision exists within Roydon, it is envisaged that larger retail stores may attract trips for residents of the site. A gravity model for retail trips has been constructed, and is based upon the stores that are located within a catchment area of 7km surrounding the site. According to National Travel Survey statistics, 7km is the average distance travelled for shopping trips in the UK (Table NTS0405).

3.4.2 A weighted distance factor of 2 has been applied to the retail model which results in a greater influence of distance to the site, with less regard to magnitude. I.e. the closer the store to the site the greater the proportion of people who will gravitate to it.

3.4.3 The food retail distribution element is summarised in Table 3-7:

Table 3-7: Route Assignment (Retail Only) Journey Destination AM Peak PM Peak Percentage Traffic Arrival Departure Two-Way Arrival Departure Two-Way B181 North (Towards 44% 2 7 9 15 9 25 Stanstead St Margarets) B181 South (Towards Lower Nazeing, 10% 0 2 2 3 2 6 Hoddesdon, Epping and Waltham Abbey) Harlow Road (Towards 46% 2 8 10 16 10 26 Harlow) Total 100% 5 17 21 35 21 56

3.5 Trip Distribution Summary

This chapter has outlined the methodology for calculating trip distribution for the residential site, split by journey purpose. A summary of the total trip distribution by route is included in Table 3-8.

Table 3-8: Route Assignment (Retail Only) Journey Destination AM Peak PM Peak Arrival Departure Two-Way Arrival Departure Two-Way B181 North (Towards 12 35 47 41 23 64 Stanstead St Margarets)

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Journey Destination AM Peak PM Peak Arrival Departure Two-Way Arrival Departure Two-Way B181 South (Towards Lower Nazeing, 10 31 41 28 15 43 Hoddesdon, Epping and Waltham Abbey) Harlow Road (Towards 9 28 36 32 18 51 Harlow) Total 31 93 124 101 57 158

3.5.1 Following analysis of vehicle journeys by mode, it is concluded that may also be required at the Pinnacle roundabout in Harlow, given the volume of traffic using Harlow Road. It should however be noted that the impact of the development on this roundabout is likely to be considerably lower than developments east of Harlow, and as such any junction improvements required as part of a Section 106 contribution should be proportional.

3.6 Impact within Hertfordshire

3.6.1 Additional preliminary scoping discussions have been under taken with Development Control officers at Hertfordshire County Council (HCC), given that the county boundary is north of Roydon railway crossing. For information purposes, Table 3-9 details the development traffic impact upon roads in Hertfordshire.

Table 3-9: Development Trips within Hertfordshire Journey Destination AM Peak PM Peak Arrival Departure Two-Way Arrival Departure Two-Way B181/Hoddesdon Rd 10 27 37 28 16 44 A1170/A414 8 22 30 23 13 31 A414/A10 5 15 21 14 8 22

3.6.2 Further analysis on the impact of roads within Hertfordshire would be contained within any formal Transport Assessment work should a planning application be forthcoming.

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Appendix 4

18 | Page

5658-01_032_LVRPA_Area7 _Proposals_LandHeritage_Rev1 Wednesday, 28 January 2015 10:08

5658-01_03 2_LVRPA_…

Appendix 5

19 | Page

DANDARA LTD LAND TO THE WEST OF ROYDON AT TEMPLE FARM TECHNICAL NOTE RELATING TO MASTERPLANNING, GREEN BELT AND LANDSCAPE RELATED MATTERS 8 DECEMBER 2016

1. Introduction

1.1. This technical note is in respect of land accessed off Epping Road, Roydon, which forms a small component of land identified within the Epping Forest District Local Plan as site SR-0303.

1.2. This note considers:

• How the land currently being promoted off Epping Road, Roydon compares to the site assessed within the Epping Forest District Local Plan Evidence Base (as parcel SR-0303), and within the Stage 2 Green Belt Study (as parcel 064.8); • The relevant management objectives of the Lee Valley Regional Park; • The relevant findings of the Epping Forest Landscape Sensitivity Study (2010); • The rationale of the proposed conceptual masterplan for the land, and the likely effects of the conceptual masterplan on the Green Belt, the landscape and visual baseline, and the Lee Valley Regional Park; • How Green Belt sites currently being proposed in the draft Epping Forest District Local Plan perform in respect of the purposes of including land in the Green Belt and landscape sensitivity, in comparison to land currently being promoted at Epping Road, Roydon.

1.3. This technical note cross refers to the following plans, contained within Appendix A: Figure 1 – Landscape Related Designations Figure 2 – Zone of Theoretical Visibility Figure 3 – Site Location Plan Figure 4 – Site Photos Figure 5 – Conceptual Masterplan Figure 6 – Lee Valley Regional Park and Local Community Benefits Figure 7 – Promoted Site Comparison Plan 1.4. It also includes at Appendix B: B1 – Extracts of the Green Belt Assessment – Stage 2 Study B2 – Extracts of the Green Belt Assessment – Stage 2 Technical Annex B3 – Roydon extract of the Stage 2 Site Selection Report B4 – Roydon extract of the Stage 3 Site Selection Report B5 – Roydon extract of the Stage 3 Capacity Site Selection Report B6 – River Lee Regional Park Plan Extract – Roydon B7 - River Lee Regional Park Plan Part 2 Text – Roydon B8 – Extract of the 2010 Settlement Edge Landscape Sensitivity Study (SELSS)

2. Epping Forest District Council (EFDC) Evidence Base

2.1. The EFDC Evidence Base includes the Green Belt Assessment Stage 2, which identifies the site as being part of a much wider parcel, identified as 064.8 (see B1). The detailed technical annex to the assessment in regard to this parcel is contained at Appendix B2. It confirms that this wider parcel is 33.9 hectares in size, and that this performs as follows in respect of Green Belt purposes.

1st GB Parcel – No Contribution 2nd GB Parcel – Weak Contribution 3rd GB Parcel – Relatively Strong Contribution 4th GB Parcel – No Contribution 5th GB Parcel – Not Assessed

2.2. This assessment identifies that the summary position of harm resulting from the potential development of this parcel would be high. The technical annex identifies, however, that the north south hedgerow (that defines the western extent of the site being promoted), would reduce this harm to moderate.

2.3. Having considered the assessment in more detail, the main aspect of the wider parcel assessment that would alter by virtue of a smaller parcel is the 3rd Green Belt purpose (relating to assisting in safeguarding the countryside from encroachment). The reduced site, as promoted, would as a minimum reduce the assessed relatively strong contribution to moderate, and it would logically follow that, with the other purposes being at worst ‘weak’ or ‘no contribution’, that the summary of harm should be less than moderate. This is a notable point, as it identifies the promoted site as the joint second performing parcel in Roydon (with 064.1 being the best performing parcel with a ‘low’ summary of harm, but being only 2.14 hectares in size).

2.4. The reduced parcel size as currently promoted would therefore perform to an equivalent or lower level of harm to the Green Belt as sites progressing to Stage

3 and 4 of the Site Selection process, and indeed one part of the GB parcel has been supported in this process (SR-0117), with only (lack of) access to the site stopping its proposed allocation for housing.

2.5. EFDC’s Stage 2 Site Selection Report identifies the promoted site as being part of a much wider parcel (SR-0303), which (at 64.15 hectares) is twice the size of the parcel considered in the Green Belt assessment, and some 8 times larger than the site currently being promoted (which is ~8 hectares, 5.5 of which to be developed – see Figure 5). The parcel being assessed in the Site Selection Report is wholly unrepresentative of the land being promoted for development by Dandara Ltd, to a greater degree than found within the Green Belt Assessment (which recognised the different effect a smaller site would have in that regard). It has been acknowledged by EFDC that despite receiving all representation material on time, they failed to pass this material on for assessment.

2.6. The assessment is, as a result, not fit for purpose, as it quite rightly concludes that development of this very large parcel (if developed as a whole) would have an adverse impact on Ancient Trees, Green Belt, Agricultural Land and Landscape Sensitivity (see B3). Indeed, the reason provided for this site not proceeding to Stage 3 is that it forms part of a strategic option and would be most sensitive in landscape terms and would be harmful to the setting of the Lee Valley Regional Park (B5). The site as promoted is not only one eighth smaller than this assessment parcel, but directly abuts the urban area, sits adjacent (and provides access to) the preferred site SR0117, and does not attract the harmful landscape and visual consequences, harm to Ancient Trees or Green Belt that would result from development of the much larger parcel. The site as promoted does not project westward from the settlement’s existing western boundary (the settlement would extend no further westwards than its current most westerly extent at Hansells Mead), and at its highest point (54m AOD) is some 20 metres lower than the highest point site assessed in the wider parcel.

2.7. The only conclusion that can be made from the scale of the different parcels assessed in the EFDC evidence base is that it is wholly unrepresentative of the site being promoted, and, as recognised in the Green Belt Assessment Stage 2, a smaller site would have quite dramatically reduced effects that should be considered afresh in the process.

3. Lee Valley Regional Park (LVRP) Management Objectives

3.1. Due to the claimed harm to the setting of the LVRP, it is worth considering what the LVRP identifies as its objectives for this part of the LVRP. Part 2 of the Park

Plan, at Section 2, considers the Roydon to Broxbourne section of the Park (B6), as illustrated at B7.

3.2. This Plan understandably focuses on water related activities and improvements, but it also sets out high level proposals for the valley sides, as set out at B6 at 2.1 (a-d). This specifically promotes low intensity countryside activities and informal countryside recreation to be encouraged, new visitor facilities to be provided to support this use, linear and circular routes for pedestrians, cyclists and horse riders, and the protection of the rural landscape character.

3.3. The relevance of the proposed masterplan in regard to the LVRP proposals is set out at item 5 below.

4. Epping Forest District Council Landscape Sensitivity Study (2010)

4.1. This study significantly pre-dates the Green Belt Assessment – Stage 2 and Site Selection Report, and inevitably defers to these studies where any overlap exists (specifically the Green Belt Assessment). The land as promoted sits in a much larger parcel (see B8 – site 1), which is similar to the wider parcel considered in the Green Belt Assessment (and is therefore far larger than the land as promoted). Three other parcels are identified for Roydon, and parcel 1 is in the lowest category for landscape sensitivity (moderate), and at the same level as all parcels for visual sensitivity (high). This study does not, therefore, suggest that the land as promoted is in a more sensitive location on the settlement edge (simply that all edges have high sensitivity).

4.2. The same observation can be found when comparing these findings with the land currently being promoted, which is substantially smaller in scale, avoids much higher land to the west, and also avoids affecting existing woodland and ancient trees. As such, the landscape and visual sensitivity of the proposed development on a much smaller tract of land should be less than high sensitivity.

5. Concept for land being Promoted

5.1. The concept for land currently being promoted is set out at Figures 5 and 6. The former illustrates the suggested disposition of development, open space and movement routes, and focuses on the following key principles:

1. To provide a cohesive and complementary relationship with the existing settlement. The development is contained by the existing western edge of the settlement (being set back from it by around 100 metres) and provides an

effective connection to Epping Road to the south and High Street to the north, which also provides access to parcel SR-0117;

2. It aims to create generous east west green movement corridors to connect the wider countryside to the settlement more effectively, and promote active recreational use of this land, consistent with the objectives of the Lee Valley Regional Park Plan;

3. A more formal urban form is proposed to frame the central street, with a looser, informal and lower density approach to the majority of the site (to its edges) to allow a comfortable assimilation into the landscape;

4. Development not extending beyond the existing north-south hedgerow (which corresponds with the ‘moderate’ Green Belt conclusion in regard to this smaller land parcel), and;

5. To provide an area of informal public open space to the north to relate to the existing floodplain.

5.2. The conceptual masterplan identifies around 6 hectares of net developable area, which would equate to delivering between 200-250 dwellings.

5.3. Figure 6 separately sets out our proposed approach for land to the west of the proposed development land, with the following key principles which positively relate to the Lee Valley Regional Park proposals for this part of the LVRP:

1. Promote a large amount of public parkland to the west, which can be used for recreation purposes, and possibly traditional agriculture, with green corridors linking the existing settlement and proposed development to this facility;

2. Create new recreational footpath routes to create variety, join together existing routes, and create circuits for local residents to utilise, thereby promoting recreation, health and wellbeing;

3. Extend native woodland copses to the south and west of this parcel, and manage this woodland for ecological and landscape benefits, and;

4. Promote options to create community benefits within the open space provided, including a visitor facility, toilets / showers, overspill car parking for the village railway station, and an enhanced neighbourhood play facility.

5.4. In summary, the development concept is a positive response to the site. It directly addresses the LVRP proposals by creating improved access and community /

visitor facilities. It promotes parkland and traditional agriculture on land that currently has urban fringe uses. The reduced extent of development when compared to the land assessed in the Green Belt Assessment and Site Selection Report, combined with the sensitive approach identified above, ensures that the concerns raised in regard to landscape sensitivity are greatly over estimated. The harm to the LVRP’s setting does not exist, quite the opposite, the scheme delivers on a number of key proposals.

6. Other Green Belt Sites supported by EFDC

6.1. Epping Forest District Council sets out at Appendix B1.6.5 of its Site Selection Report the Results of identifying Sites for Allocation. This report identifies those sites identified per settlement at Stage 3 and 4 of the Site Selection Report, providing the Council’s conclusion as to the deliverability of the preferred sites and concluding that sites without insurmountable constraints are proposed for allocation.

6.2. When considering the sites proposed for allocation in terms of those that are green field and of a substantial contribution (i.e over 50 dwellings), Table 1 below identifies a number of sites that provide a reasonable comparison to the land promoted off Epping Road, Roydon.

6.3. Comparison with land promoted at Roydon by Dandara Ltd must consider the conclusions in respect of harm to the Green Belt and the landscape and visual sensitivity of the land parcels in which the specific sites are located. This being at worst a moderate impact for the site being promoted.

6.4. Table 1 (over the page) compares the sites identified above in respect of the Green Belt harm identified by the 2016 Green Belt Assessment – Stage 2, and the Landscape Sensitivity as identified in the 2010 Settlement Edge and Landscape Sensitivity Study for each parcel in which the proposed EFDC housing allocation are located.

Table 2 – EFDC Proposed Housing Allocations and GB Harm / Landscape Sensitivity

SS Parcel GB Parcel GB Assessment - SELSS SELSS Settlement Ref Ref summary harm Parcel Ref Sensitivity

Chipping Ongar SR-0390 24.4 HIGH 6 High Epping SR-0132Ci 69.3 VERY HIGH 1 Moderate 70.1 VERY LOW 1 Moderate SR -0208 44.1 VERY HIGH n/a

SR-0153 46.1 HIGH 3 High SR-0069/33 44.2 VERY HIGH 4 Low

SR-0069 44.2 VERY HIGH 4 Low SR-0071 47.1 HIGH 3 High

Fyfield SR-0049 16.3 VERY HIGH 3 High Lower Nazeing SR-0473 67.5 VERY HIGH 3 Moderate SR-0011 67.5 VERY HIGH 3 Moderate SR-0300 67.5 VERY HIGH 3 Moderate

SR-0473 67.5 VERY HIGH 3 Moderate SR-0300 (east) 67.4 VERY HIGH 3 Moderate

North Weald Bassett SR-0003 10.2 MODERATE 2 Moderate SR-0417 10.2 MODERATE 2 Moderate

SR-0158A 10.2 MODERATE 2 Moderate

SR-0036 10.1 LOW 3 Moderate

SR-0195B 10.1 LOW 3 Moderate

Sheering SR-0073 5.2 VERY HIGH n/a

Theydon Bois SR-0026C 41.4 VERY HIGH 2 Moderate SR-0026B 41.4 VERY HIGH 2 Moderate

1 2 Proposal 64.8 MODERATE 1 Moderate

6.5. Table 2 highlights that of the 22 proposed allocations identified as being reasonable to compare against land promoted by Dandara Ltd at Roydon (in blue text), 16 of the sites perform worse in terms of Green Belt harm (High harm or greater – in red text).

1 Reduced from ‘High’ to ‘Moderate’ for the wider parcel, as set out in the detailed annex to the Green Belt Assessment – Stage 2 2 Reduced from ‘High’ for the much wider land parcel to ‘Moderate’ to align with the findings of the Green Belt Assessment – Stage 2

6.6. In respect of landscape sensitivity, the majority of the sites (14) have equal sensitivity to the land as promoted (moderate sensitivity), with 4 sites of the 22 being of a worse performance (in red text) with only 2 sites being of a low sensitivity (green text).

6.7. When considering Green Belt harm and landscape sensitivity together, only 3 sites perform better than land promoted by Dandara, with 16 of the promotes sites performing worse (and 3 being of the same performance).

6.8. In summary, the great majority of the sites promoted for allocation in the Epping Forest District Council Site Selection Study perform worse than the land as promoted by Dandara Ltd in regard to Green Belt harm and landscape sensitivity terms.

7. Conclusions

7.1. The land being promoted to the west of Roydon by Dandara Ltd is not accurately represented in the Green Belt Assessment – Stage 2 or the Site Selection Report, simply because the land parcel it sits within is significantly larger, extends well beyond the existing settlement edge, and has a very different countryside character, which rises to 20 metres higher than the highest part of the land as promoted. The Stage 2 report recognises the reduced harm arising from the sub- land parcel in which the promoted land is located, which reduces the overall harm from high to moderate.

7.2. Similarly, the inaccuracy of the larger size assessment parcel has affected the accuracy of the Site Selection Report, which identifies concerns relating to landscape sensitivity, Green Belt, Ancient Trees and Agricultural land.

7.3. The same inaccuracy is found with regard to the Settlement Edge and Landscape Sensitivity Study, which also assesses a far wider area. Whilst the parcel size issue could be levelled at many sites, the problem with this inaccuracy becomes tangible for sites such as land west of Roydon, where the urban fringe character abruptly changes into rolling countryside with significant topographic and vegetation changes beyond the initial urban fringe.

7.4. Turning to the Lee Valley Regional Park, Part 2 of the Park Plan, at Section 2, considers the Roydon to Broxbourne section of the Park (B6), as illustrated at B7, which sets out high level proposals for the valley sides, as set out at B6 at 2.1 (a- d). This specifically promotes low intensity countryside activities and informal countryside recreation to be encouraged, new visitor facilities to be provided to support this use, linear and circular routes for pedestrians, cyclists and horse

riders, and the protection of the rural landscape character. All of these objectives can be delivered by the currently proposed scheme (see Figure 5 and 6).

7.5. The masterplan concept as promoted not only positively addresses the key proposals as found within the Lee Valley Regional Park, but also provides a cohesive western edge to the settlement, whilst unlocking the development parcel SR-0117, development of which is found acceptable, but is otherwise landlocked. The site also provides substantial community and LVRP benefits, including:

1. Promote a large amount of public parkland to the west, which can be used for recreation purposes, and possibly traditional agriculture, which green corridors linking the existing settlement and proposed development to this facility;

2. Create a series of new recreational routes to create variety, join together existing routes, and create circuits for local residents to utilise, thereby promoting recreation, health and wellbeing;

3. Extend native woodland copses to the south and west of this parcel, and manage these woodland for ecological benefits, and;

4. Promote options to create community benefits within the open space provided, including a visitor facility, toilets / showers, overspill car parking for the village railway station, and an enhanced neighbourhood play facility.

7.6. Finally, when considering Green Belt harm and landscape sensitivity together, only 3 sites perform better than land promoted by Dandara, with 16 of the promotes sites performing worse (and 3 being of the same performance).

7.7. This inevitably leads to no other conclusion than if this land was assessed accurately and transparently it would be allocated for housing development, thereby delivering benefits to the local community, the LVRP whilst also releasing the adjacent site for development (SR-0117).

APPENDIX A – FIGURES

Figure 1 – Landscape Related Designations Figure 2 – Zone of Theoretical Visibility Figure 3 – Site Location Plan Figure 4 – Site Photos Figure 5 – Conceptual Masterplan Figure 6 – Lee Valley Regional Park and Local Community Benefits Figure 7 – Promoted Site Comparison Plan LEGEND

Site boundary

Green Belt

SSSI (Site of Specific Scientific Importance)

Registered Parks and Gardens

N

SCALE 1:25,000 100100 300300

0m0m 200200 500500 10001000

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1 Figure Roydon Site 1:25,000 Scale LEGEND

Site boundary

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2 Figure Roydon Site 1:25,000 Scale LEGEND

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0m 40 100 200

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3 Figure Roydon Site 1:4,000 Scale Photo Location 1

Site Photos

Photo Location 2 4 Figure Roydon Site - Scale Photo Location 3

Site Photos

Photo Location 4 4 Figure Roydon Site - Scale Photo Location 5

Site Photos

Photo Location 6 4 Figure Roydon Site - Scale Photo Location 7

Site Photos

4 Figure Roydon Site - Scale 30

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30 28 34 38 LEGEND 30 30 30 38 30 30 30 30 30 32 Site boundary 32

28 38 36 40 32 30

30 30 32 New homes; 6ha/~200-250 40 30 30 28 32 38 32 dwellings 34 32 32 32 34 30 30 34 Parkland; (formal and informal) ~5ha 40 28 36 28 32 30 42 30 36 34 38

30 42 30 36 40 Formal built edge 34

28 34 38 Lower density built edge to respond to 28 42 30 42 30 parkland and green edges 30 36 38 44 30 28 32 38 40 44 34 32 Primary road; ~1ha 28 38 44 36 40 36 44 30 46 38 42 40 Primary road with an informal parkland 46

28 44 34 38 character 46

30 48 48 46 42 46 40 40 48 28 Approximate EA floodplain 50 32 36 42 50 40 44 48 38 48 48 42 40 34 Existing Public Right Of Way 52 46

44 48 50 50 52 28 42 50 Proposed footpath to link existing 50 30 36 42 54 50 44 public footpaths 46 52 28 32 44 52 52 38 40 52 54 34 54 Neighbourhood Play Area 54 54 36 44 SR-0117 44 52 46 54 38 54 42 46 56 56 56 St Peter’s Church 56 44 46 58 54 56 48

48 58 46 42 46 40 48 58 50 50 40 44 60 56 56 48 48 48

52 58 58 46 58

44 48 50 50 60 60 58

52 62 60 50

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52 60 54 54 62 56 56 56 56 62 62 64 58 54 62 56

58 Conceptual Masterplan

58 62 64 N

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62 60 SCALE 1:4,000 20 60 62

60 60 0m 40 100 200 58 64 60 5 Figure

60 62 Roydon Project

62 62 64 62 1:4,000 Scale

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30 30 B 30 30 32

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32 30 30 32 D32 32 32 32 34 30 34

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28 34 38 LEGEND A 30 30 38 30

Site boundary 32 28 38 36 40 30

Informal public access 40 28 34 38 New recreational routes, connecting 30

40 existing PRoWs and providing ‘low Green corridors 28 32 36 intensity countryside activities’ Increased Green corridors to structure 42 movement from Roydon (and new 38 42 40 dev’t) to the countryside in logical Potential community assets 34 locations that are highly accessible C 28 42

Existing Public Right Of Way 30 36 42 44 28 32 38 40 44 B Proposed footpath to link existing 34 44 public footpaths 36 44 46 38 42 New native woodland 46 44 46

D 48 48 46 42 46 40 New recreational routes 48 50 50 40 44 48 48 48

Childrens play area 52 46

44 48 50 50 52 50

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54 A 50 46 52

52 52 52 54

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56 56 56 56 58 54 56

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60 60 58 64 New native woodland to enhance 60 60 existing woodland in landscape and 62 ecology terms 62 62 64 Lee Valley Park/Community Benefits 62 Potential Community Assets: 62 64 “Farmland and woodland on the A Potential vistor facility with parking N to provide access to the LVRP. valley side to be protected”, through the creation of informal public access B Potential facility to support waterside recreation (such as to natural parkland with limited toilets/ shower facilities); grazing SCALE 1:4,000 C Potential overspill public car park 20 60 to serve the train station; 0m 40 100 200 D Potential Neighbourhood Play 6 Figure Facility to serve the wider area. Roydon Project 1:4,000 Scale 30

30 30 32 30

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30 30

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30 30 32

32 36 34 28 28 30 30 36 38 LEGENDLEGEND

30 36

34 34

30 SR-0303 Developed area - 10.3 ha 30 38 38 40 36

30 32 36 28 38 28 SR-0303 - 39.8 ha

40

Developed 40 38 40 34 area 30 44 36 SR-0117 - 1.2 ha 36 42 38 28 32 40

38 42

28 46 38 34 40

42 42 46 42 44 36 42 30 44 32 40

40 44 44 34 38 44 SR-011744 28 36 40 46 46 38 42 46 42 40 48 46 48 42 44 46 42 50 44 42 48 44 48 46 42 46 40 48 46 52 50 50 SR-0303 50 48 50 48

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72 72 60 60 64 72 70 SCALE 1:5,000 68 60 25 75

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60 72 62 74 60 Roydon Project 58 54 60 66 52 58 60 1:5,000 Scale 56 76

50 54 64 76 62 56 48 76

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52 70 50 46

APPENDIX B – DOCUMENT EXTRACTS

B1 – Extracts of the Green Belt Assessment – Stage 2 Study B2 – Extracts of the Green Belt Assessment – Stage 2 Technical Annex B3 – Roydon extract of the Stage 2 Site Selection Report B4 – Roydon extract of the Stage 3 Site Selection Report B5 – Roydon extract of the Stage 3 Capacity Site Selection Report B6 – River Lee Regional Park Plan Extract – Roydon B7 - River Lee Regional Park Plan Part 2 Text – Roydon B8 – Extract of the 2010 Settlement Edge Landscape Sensitivity Study (SELSS)

Name Settlement Purpose 1 Purpose 2 Purpose 3 Purpose 4 Summary of Rating Rating Rating Rating Harm

054.5 Loughton and No Moderate Relatively No High Debden Contribution Strong Contribution

054.6 Loughton and No Relatively Moderate No High Debden Contribution Strong Contribution

061.1 Lower Nazeing Weak Relatively Moderate No Moderate Weak Contribution

061.2 Lower Nazeing Weak Relatively Strong No Very High Weak Contribution

066.3 Lower Nazeing No Weak Moderate No Moderate Contribution Contribution

066.4 Lower Nazeing No Relatively Strong No Very High Contribution Weak Contribution

066.5 Lower Nazeing Weak Relatively Moderate No Moderate Weak Contribution

067.3 Lower Nazeing No No Relatively No High Contribution Contribution Strong Contribution

067.4 Lower Nazeing No No Strong No Very High Contribution Contribution Contribution

067.5 Lower Nazeing No No Strong No Very High Contribution Contribution Contribution

002.1 Lower No No Relatively Relatively High Sheering Contribution Contribution Strong Strong

002.2 Lower No Relatively Relatively Relatively High Sheering Contribution Weak Strong Weak

006.1 Matching No No Strong No Very High Contribution Contribution Contribution

015.2 Moreton No No Strong No Very High Contribution Contribution Contribution

008.1 North Weald No No Moderate No Moderate Bassett Contribution Contribution Contribution

008.2 North Weald No Moderate Strong No Very High Bassett Contribution Contribution

010.1 North Weald No No Relatively No Low Bassett Contribution Contribution Weak Contribution

010.2 North Weald No Moderate Moderate No Moderate Bassett Contribution Contribution

010.3 North Weald No Moderate Relatively No High Bassett Contribution Strong Contribution

010.4 North Weald No Moderate Relatively No High Bassett Contribution Strong Contribution

010.5 North Weald No Weak Moderate No Moderate Bassett Contribution Contribution

011.1 North Weald No Weak Moderate No Moderate Bassett Contribution Contribution

011.2 North Weald No Relatively Relatively No High Bassett Contribution Weak Strong Contribution

011.3 North Weald No Relatively Strong No Very High Bassett Contribution Weak Contribution

064.1 Roydon No Weak Relatively No Low Contribution Weak Contribution

064.2 Roydon Relatively Moderate Moderate No Moderate Weak Contribution

Epping Forest District Green Belt Assessment: 29 August 2016 Stage 2 Name Settlement Purpose 1 Purpose 2 Purpose 3 Purpose 4 Summary of Rating Rating Rating Rating Harm

064.4 Roydon No Relatively Relatively No High Contribution Weak Strong Contribution

064.6 Roydon No No Moderate No Moderate Contribution Contribution Contribution

064.7 Roydon Relatively Moderate Strong No Very High Weak Contribution

064.8 Roydon No Weak Relatively No High Contribution Strong Contribution

059.1 Sewardstone Strong Moderate Moderate No Very High Contribution

059.2 Sewardstone Strong Strong Strong No Very High Contribution

005.1 Sheering No No Relatively No High Contribution Contribution Strong Contribution

005.2 Sheering No No Strong No Very High Contribution Contribution Contribution

033.1 Stapleford Relatively No Relatively No High Abbotts Strong Contribution Strong Contribution

041.1 Theydon Bois No Relatively Relatively No High Contribution Weak Strong Contribution

041.3 Theydon Bois No Relatively Strong No Very High Contribution Strong Contribution

041.4 Theydon Bois No Moderate Strong No Very High Contribution Contribution

042.1 Theydon Bois No Strong Strong No Very High Contribution Contribution

043.1 Theydon Bois No Moderate Strong No Very High Contribution Contribution

043.2 Theydon Bois No Moderate Relatively No High Contribution Strong Contribution

043.3 Theydon Bois No Relatively Moderate No High Contribution Strong Contribution

054.10 Theydon Bois No Weak Relatively No Low Contribution Weak Contribution

054.7 Theydon Bois No No Weak No Very Low Contribution Contribution Contribution

054.8 Theydon Bois No No Weak No Very Low Contribution Contribution Contribution

054.9 Theydon Bois No Moderate Moderate No Moderate Contribution Contribution

049.2 Thornwood No No Relatively No Low Contribution Contribution Weak Contribution

050.2 Thornwood Weak Moderate Relatively No High Strong Contribution

050.3 Thornwood No Moderate Moderate No Moderate Contribution Contribution

070.5 Thornwood No Relatively Relatively No Low Contribution Weak Weak Contribution

058.1 Waltham Weak Relatively Moderate Weak Moderate Abbey Weak

059.3 Waltham Weak Weak Weak Weak Very Low Abbey

Epping Forest District Green Belt Assessment: 30 August 2016 Stage 2 Settlement: Roydon Settlement Type: Small Village Stage 2 Assessment

LUC - January 2016 Settlement: Roydon Settlement Type: Small Village Stage 2 Assessment

Parcel 064.8 Parcel Size (Ha) - 33.90 Summary of Assessment - Parcel's Contribution to the Purposes of Green Belt 1st Green Belt Purpose No Contribution 2nd Green Belt Purpose Weak 3rd Green Belt Purpose Relatively Strong 4th Green Belt Purpose No Contribution 5th Green Belt Purpose Not Assessed

Summary of Assessment Resultant harm to the Green Belt purposes if parcel released from the Green Belt: High

Purpose 1. Check the unrestricted sprawl of large built-up No Contribution areas (Large built-up areas are: London, Harlow, Cheshunt and Hodddesdon) The parcel lies relatively close to Hoddesdon but is separated from it by the valley of the River Stort, close to its confluence with the Lee Valley, which was identified at Stage 1 of the Green Belt Review as an area of environmental constraint which would preclude future housing development. Any development within this parcel would therefore relate to Roydon rather than Hoddesden, and so would not be perceived as sprawl emanating from the latter. Land to the east of Roydon makes a strong contribution to preventing sprawl from Harlow. The higher rating given to Stage One parcel DSR-064 reflects that parcel's inclusion of land adjacent to the large built- up area of Harlow. Purpose 2. Prevent neighbouring towns from merging Weak

(Towns are: London, Harlow, Cheshunt, Hodddesdon, Epping, Waltham Abbey, Loughton / Debden, Chigwell, Buckhurst Hill, Chipping Ongar, North Weald Bassett, Theydon Bois, Roydon and Lower Nazeing) Development would not represent any risk of coalescence with Hoddesden, due to the environmental constraints on development in the valley, and existing development at Roydon Mill limits the extent to which further development to the south of this would be seen as closing the gap. Purpose 3. Assist in safeguarding the countryside from Relatively Strong encroachment The farmland in this parcel is not as expansive or as undulating as the arable farmland on the western side of the hill, and is framed on three sides by development, but it is still a very open rural landscape, with long views across the valley to open countryside and wooded hills in east Hertfordshire. The only buildings in the parcel are those of Temple Farm, close to the inset settlement edge. The west-facing settlement edge is exposed to the south of the farm but stronger to the north, and a large house with outbuildings and an orchard separate the parcel from the inset settlement to the south. There is no landform change to provide additional distinction between the parcel and the adjacent settlement. The parcel's outer edges (to the north and west) are well defined but offer little visual containment in this valley side setting. Several north-south hedgerows subdivide the area, and whilst these offer no visual screening from the north they offer scope as potential boundaries to a more limited intrusion into the countryside. The area between the settlement edge and the first of these hedgerows can be considered to make a more 'moderate' contribution to Purpose 3. Purpose 4. To preserve the setting and special character of No Contribution historic towns (Historic towns are: Chipping Ongar, Waltham Abbey, Epping and Sawbridgeworth) There is no relationship between the parcel and any historic town. Purpose 5. To assist in urban regeneration, by encouraging the Not Assessed recycling of derelict and other urban land Not assessed at individual parcel level, as explained in Methodology section of report. Consideration of alternative parcel boundaries The north-south hedgerow nearest the settlement edge could provide an alternative parcel boundary, containing an area which is considered to make a 'moderate' contribution to Purpose 3. Potential anomalies identified for consideration by EFDC None identified.

LUC - January 2016 Site Suitability Assessment Site Reference: SR-0052A Parish: Roydon Settlement: Size (ha): 61.45 Address: Land at East End Farm, Harlow

Primary use: Housing SLAA notes: Residential led urban extension to Harlow on existing agricultural fields

SLAA yield: Enhanced landscaping and access to the countryside. Not Client SLAA source Based on promoter material. Epping Forest District Council for baseline Job Title yield: Epping Forest District Local Plan

SLAA site None Drawing Status contraints: Issue Drawing No Issue SR-0052A P1 Site selection None adjustment:

© Contains OS data © Crown copyright and database right (2016) Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, Community The Council did not consult on a growth location which covers or is GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © OpenStreetMap contributors, and the GIS User Community feedback: near to this site. Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community Dwellings: 0

Criteria Score Qualitative Assessment

Effects of allocating the site for the proposed use do not undermine conservation objectives (alone or in 1.1 Impact on Internationally Protected Sites 0 combination with other sites).

Site falls within an Impact Risk Zone and due to the nature and scale of the development proposed it is likely to be Due to the development type (over 10 rural residential dwellings), development of the site is likely to pose a risk and 1.2 Impact on Nationally Protected sites (-) possible to mitigate the effects of the proposed development. consultation with Natural England is required. However, it is likely that mitigation to reduce the risk would be possible.

Site is not located within or adjacent to Ancient Woodland. 1.3a Impact on Ancient Woodland 0

Site contains a higher density of Ancient and/or Veteran trees, or are configured in such a way that direct loss or There are 41 Ancient trees directly affected by the site. The trees are dispersed and concentrated on the western 1.3b Impact on Ancient/Veteran Trees outside of (--) harm is likely. boundary, and development of the site may affect a portion of the trees. The density of the trees is such that direct Ancient Woodland harm is likely. Site is unlikely to impact on Epping Forest Buffer Land. 1.4 Impact on Epping Forest Buffer Land 0

Features and species in the site may not be retained in their entirety but effects can be mitigated. The site encompasses the majority of a Deciduous Woodland and Wet Woodland habitats, and is adjacent to a Semi 1.5 Impact on BAP Priority Species or Habitats (-) Improved Grassland habitat. The site is likely to directly and indirectly affect the habitats, but these effects can be mitigated. Features and species in the site may not be retained in their entirety but effects can be mitigated. A small part of the site encompasses approximately half of the Worlds Ends LWS and may directly affect this LWS. The 1.6 Impact on Local Wildlife Sites (-) site is adjacent to Roydon Brickfields North and within the 250m buffer for Roydon Mead LWS, however is unlikely to affect these LWS. Site within Flood Zone 1. Some 95% of the site is in Flood Zone 1. Higher Flood Risk Zones 2, 3a and 3b, covering 5%, are located on the 1.7 Flood risk (++) northern site boundary. These areas can be avoided and the flood risk mitigated through site layout.

Proposed site located within a Conservation Area or adjacent to a Listed Building or other heritage asset and 1.8a Impact on heritage assets (-) effects can be mitigated.

There is a medium likelihood that further archaeological assets may be discovered on the site, but potential is 1.8b Impact on archaeology 0 unknown as a result of previous lack of investigation.

Site lies outside of areas identified as being at risk of poor air quality. 1.9 Impact of air quality 0

Site is within Green Belt, where the level of harm caused by release of the land for development would be high or The majority of the site is within very high/high sensitivity Green Belt parcels which contribute strongly to preventing 2.1 Level of harm to Green Belt (--) very high. the sprawl of Harlow and its coalescence with Roydon. If the site was released it may harm the purposes of the wider Green Belt. Site is more than 4000m from the nearest rail or tube station. 3.1 Distance to the nearest rail/tube station (-)

Site between 400m and 1000m of a bus stop. 3.2 Distance to nearest bus stop 0

Site is more than 1600m and less than 2400m of an employment site/location. 3.3 Distance to employment locations 0

Site is between 1000m and 4000m from nearest town, large village or small village. 3.4 Distance to local amenities 0

Site is between 1000m and 4000m from the nearest infant/primary school. 3.5 Distance to nearest infant/primary school 0

Site is more than 4000m from the nearest secondary school. 3.4 Distance to local amenities (-)

Site is between 1000m and 4000m from the nearest GP surgery. 3.7 Distance to nearest GP surgery 0

Not applicable. 3.8 Access to Strategic Road Network

Majority of the site is greenfield land adjacent to a settlement. 100% greenfield site, adjacent to an existing settlement (Harlow). 4.1 Brownfield and Greenfield Land (-)

Development would involve the loss of the best and most versatile agricultural land (grades 1-3). 4.2 Impact on agricultural land (--)

Development unlikely to involve the loss of public open space. No public open space is located in the site area. Development will not involve the loss of public open space. 4.3 Capacity to improve access to open space 0

The site falls within an area of high landscape sensitivity - vulnerable to change and unable to absorb 5.1 Landscape sensitivity (--) development without significant character change.

Development is unlikely to have an effect on settlement character. Developer proposals include enhancement of landscape and publically accessible open space, with no built 5.2 Settlement character sensitivity 0 development. This is unlikely to impact on settlement character.

Topographical constraints exist in the site but potential for mitigation. 6.1 Topography constraints (-)

Gas or oil pipelines do not pose any constraint to the site. 6.2a Distance to gas and oil pipelines 0

Power lines do not pose a constraint to the site. 6.2b Distance to power lines 0

The intensity of site development would not be constrained by the presence of protected trees either on or 6.3 Impact on Tree Preservation Order (TPO) 0 adjacent to the site.

Suitable access to site already exists. 6.4 Access to site (+)

Potential contamination on site, which could be mitigated. Potential contamination over small part of site (Farm). Potential adverse impact that could be mitigated. 6.5 Contamination constraints (-)

Site below the size threshold where it would be expected to affect congestion (e.g. employment site or housing 6.6 Traffic impact site with capacity of <25 dwellings).

© Arup SR-0304

SR-0117

SR-0169

SR-0035

SR-0890

SR-0197

Drawing No. Report on Content Legend Site Selection EFDC-S34-0012-Rev1 Residential sites for testing at Stages 3/4 in Roydon Stage 3/4 Sites Date: September 2016

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community Scale: 1:6,000 @A3 ¯ Site Deliverability Assessment Indicative Site Capacity Assessment

Site Reference: SR-0035 Site boundary amendment: No amendment made to site boundary. Settlement: Roydon Site constraints affecting extent of developable area Address: Land at Epping Road, Roydon Site area (ha): 0.19

Notes: On-site major policy constraints: None

Land type: Medium performing Green Belt adjacent to a settlement Area of site subject to major policy 0 constraints (ha):

Primary use: Housing On-site non-major policy constraints:

Area of site subject to non-major policy 0 constraints (ha): Unconstrained site area (ha): 0.19 Establishing indicative baseline density

Site located in: Large Village Site setting is: Other Site is near a commuter hub: No Indicative baseline density (dph): 39 Indicative baseline yield (units): 7

Refining the indicative site density

Identified density constraints: Conservation Area

Constraints density adjustment: 0% (dph): 39 Justification for adjustment: Impact on Conservation Area likely to be mitigated without reduction in density. No capacity adjustment made.

Client Epping Forest District Council Local setting: Preapp received for six dwellings which is deemed acceptable. Capacity reduced to match pre-app submission. ! Job Title Epping Forest District Local Plan

Drawing Status Local setting density adjustment: -20% (dph): 31.2 Issue Incorporate mixed use development: Site proposed for solely residential use. Drawing No Issue SR-0035 P1

Mixed use density adjustment: 0% (dph): 31.2

Gross to net adjustment: 0% (dph): 31.2 © Contains OS data © Crown copyright and database right (2016) Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © Existing on-site development or OpenStreetMap contributors, and the GIS User Community 0 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community commitments (units):

Availability and Achievability Assessment Indicative net site capacity (units): 6

Criteria Score Qualitative Assessment

Site is in single ownership The Council's SLAA indicates that the site is in single ownership. 1.1 Ownership (+)

There are no existing uses on-site or existing uses could cease in less than two years 1.2 Existing uses (+)

Site is not subject to any known restrictions The Council's SLAA suggests that there no known on-site restrictions on the site. 1.3 On-site restrictions (+)

Site expected to be available between 2016 and 2020 1.4 Site availability (+)

Site is not being actively marketed The landowner has advised that they are willing to sell the land for development, at a time when development is a 2.1 Site marketability (-) prospect. Seeking an allocation in the Local Plan represents the first step to development becoming a prospect.

No viability issues identified 2.2 Site viability (+)

There are no known on-site constraints which would impact upon deliverability There are no known on-site constraints which could impact upon deliverability. The site has existing connections to 2.3 On-site and physical infrasturcture constraints (+) utilities including water, main sewerage, electricity, and to highways infrastructure.

Site is located in a school planning area with a current or forecast deficit and where schools have limited ability to 2.4a Primary schools (Planning area) (-) expand

Site is located within 1km of a primary school with a current or forecast capacity deficit 2.4b Primary schools 0

Site is located in a school planning area with a current or forecast deficit but schools have potential to expand 2.5a Secondary schools (Planning area) 0

Site is located more than 1km from a secondary school 2.5b Secondary schools (-)

Site is located within 400m of existing publicly accessible open space, or there are proposals for new on-site open 2.6 Access to open space (+) space provision as part of the development.

Site is located more than 1km of a health facility (GP) 2.7 Health (-)

None of the site is located within a minerals safeguarding area 2.8 Impact on mineral deposits (+)

There are no identified current deficiencies in the quantum of open space within the settlement. No open space is 3.1 Cumulative loss of open space in settlement (+) lost as a result of the proposed allocations in the settlement

The proposed allocations in the settlement would lead to a shortage of current primary school places in the 3.2 Cumulative impact on primary school 0 Schools Planning Area. There is limited scope to further expand school provision due to site constraints. (Planning area)

The proposed allocations in the settlement would lead to a shortage of current secondary school places in the 3.3 Cumulative impact on secondary schools 0 Schools Planning Area. There is potential to accommodate growth by either expanding schools or identifying a (Planning area) new site. The proposed site allocations provide opportunities to enhance green infrastructure 3.4 Cumulative impact on the green infrastructure (+)

Settlement is served by a Sewage Treatment Works (STW) which has known spare capacity or planned additional 3.5 Cumulative impact on sewage treatment work (+) capacity capacity

The proposed allocations in this settlement do not have a material impact on the current or expected forecast peak 3.6 Cumulative impact on Central Line capacity (+) use of the Central Line stations within Epping Forest District

© Arup Site Deliverability Assessment Indicative Site Capacity Assessment

Site Reference: SR-0117 Site boundary amendment: No amendment made to site boundary. Settlement: Roydon Site constraints affecting extent of developable area Address: The paddock to the rear of Barn House, Farm Close, Roydon, Essex, CM19 5LW Site area (ha): 1.31

Notes: Open land. On-site major policy constraints: None

Land type: Medium performing Green Belt adjacent to a settlement Area of site subject to major policy 0 constraints (ha):

Primary use: Housing On-site non-major policy constraints:

Area of site subject to non-major policy 0 constraints (ha): Unconstrained site area (ha): 1.31 Establishing indicative baseline density

Site located in: Large Village Site setting is: Other Site is near a commuter hub: Yes Indicative baseline density (dph): 58.5 Indicative baseline yield (units): 77

Refining the indicative site density

Identified density constraints: Conservation Area, Access

Constraints density adjustment: -10% (dph): 52.65 Justification for adjustment: Conservation Area located nearby, and a reduction in density would likely be required to mitigate impact on its setting. Capacity adjusted to reflect this.

Client Epping Forest District Council Local setting: No adjustment made for local setting. ! Job Title Epping Forest District Local Plan

Drawing Status Local setting density adjustment: 0% (dph): 52.65 Issue Incorporate mixed use development: Site proposed for solely residential use. Drawing No Issue SR-0117 P1

Mixed use density adjustment: 0% (dph): 52.65

Gross to net adjustment: -10% (dph): 47.38 © Contains OS data © Crown copyright and database right (2016) Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © Existing on-site development or OpenStreetMap contributors, and the GIS User Community 0 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community commitments (units):

Availability and Achievability Assessment Indicative net site capacity (units): 62

Criteria Score Qualitative Assessment

Site is in single ownership 1.1 Ownership (+)

There are no existing uses on-site or existing uses could cease in less than two years 1.2 Existing uses (+)

Site subject to restrictions and there is limited prospect of the restriction being overcome The site is part of a wider area of land identified as a potential area for development. The development of the site is 1.3 On-site restrictions (-) reliant on the development of this wider area, for example, in relation to access.

Site expected to be available between 2016 and 2020 1.4 Site availability (+)

Site is not being actively marketed 2.1 Site marketability (-)

No viability issues identified 2.2 Site viability (+)

There are no known on-site constraints which would impact upon deliverability There are no known on-site constraints which would impact upon deliverability. 2.3 On-site and physical infrasturcture constraints (+)

Site is located in a school planning area with a current or forecast deficit and where schools have limited ability to 2.4a Primary schools (Planning area) (-) expand

Site is located within 1km of a primary school with a current or forecast capacity deficit 2.4b Primary schools 0

Site is located in a school planning area with a current or forecast deficit but schools have potential to expand 2.5a Secondary schools (Planning area) 0

Site is located more than 1km from a secondary school 2.5b Secondary schools (-)

Site is located within 400m of existing publicly accessible open space, or there are proposals for new on-site open 2.6 Access to open space (+) space provision as part of the development.

Site is located more than 1km of a health facility (GP) 2.7 Health (-)

None of the site is located within a minerals safeguarding area 2.8 Impact on mineral deposits (+)

The site has not been included in the assessment as it is not proposed for allocation 3.1 Cumulative loss of open space in settlement 0

The site has not been included in the assessment as it is not proposed for allocation 3.2 Cumulative impact on primary school 0 (Planning area)

The site has not been included in the assessment as it is not proposed for allocation 3.3 Cumulative impact on secondary schools 0 (Planning area)

The site has not been included in the assessment as it is not proposed for allocation 3.4 Cumulative impact on the green infrastructure 0

The site has not been included in the assessment as it is not proposed for allocation 3.5 Cumulative impact on sewage treatment work 0 capacity

The site has not been included in the assessment as it is not proposed for allocation 3.6 Cumulative impact on Central Line capacity 0

© Arup Site Deliverability Assessment Indicative Site Capacity Assessment

Site Reference: SR-0169 Site boundary amendment: No amendment made to site boundary. Settlement: Roydon Site constraints affecting extent of developable area Address: The Old Coal Yard, off 32 High Street, Roydon Site area (ha): 0.53

Notes: On-site major policy constraints: None

Land type: Medium performing Green Belt adjacent to a settlement Area of site subject to major policy 0 constraints (ha):

Primary use: Housing On-site non-major policy constraints:

Area of site subject to non-major policy 0 constraints (ha): Unconstrained site area (ha): 0.53 Establishing indicative baseline density

Site located in: Large Village Site setting is: Other Site is near a commuter hub: Yes Indicative baseline density (dph): 58.5 Indicative baseline yield (units): 31

Refining the indicative site density

Identified density constraints: Conservation Area, Locally Listed Building

Constraints density adjustment: -75% (dph): 14.63 Justification for adjustment: Conservation Area likely to be significantly affected by development here, and a capacity reduction has been made.

Client Epping Forest District Council Local setting: No adjustment made for local setting. ! Job Title Epping Forest District Local Plan

Drawing Status Local setting density adjustment: 0% (dph): 14.63 Issue Incorporate mixed use development: Site proposed for solely residential use. Drawing No Issue SR-0169 P1

Mixed use density adjustment: 0% (dph): 14.63

Gross to net adjustment: 0% (dph): 14.63 © Contains OS data © Crown copyright and database right (2016) Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © Existing on-site development or OpenStreetMap contributors, and the GIS User Community 0 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community commitments (units):

Availability and Achievability Assessment Indicative net site capacity (units): 8

Criteria Score Qualitative Assessment

Site is in single ownership 1.1 Ownership (+)

There are no existing uses on-site or existing uses could cease in less than two years 1.2 Existing uses (+)

Site is not subject to any known restrictions 1.3 On-site restrictions (+)

Site expected to be available between 2016 and 2020 1.4 Site availability (+)

Site is not being actively marketed The position on the site is unknown. It is therefore assumed that the site is not being actively marketed. 2.1 Site marketability (-)

No viability issues identified A scheme has been drawn and costed for the site and no viability issues have been identified. 2.2 Site viability (+)

Identified on-site constraints may impact upon deliverability. There may be some constraints to utilities connections and necessary highways infrastructure which could impact on 2.3 On-site and physical infrasturcture constraints (-) the delivery of the site. No mitigation or design solutions have been identified to limit impacts.

Site is located in a school planning area with a current or forecast deficit and where schools have limited ability to 2.4a Primary schools (Planning area) (-) expand

Site is located within 1km of a primary school with a current or forecast capacity deficit 2.4b Primary schools 0

Site is located in a school planning area with a current or forecast deficit but schools have potential to expand 2.5a Secondary schools (Planning area) 0

Site is located more than 1km from a secondary school 2.5b Secondary schools (-)

Site is located within 400m of existing publicly accessible open space, or there are proposals for new on-site open 2.6 Access to open space (+) space provision as part of the development.

Site is located more than 1km of a health facility (GP) 2.7 Health (-)

None of the site is located within a minerals safeguarding area 2.8 Impact on mineral deposits (+)

There are no identified current deficiencies in the quantum of open space within the settlement. No open space is 3.1 Cumulative loss of open space in settlement (+) lost as a result of the proposed allocations in the settlement

The proposed allocations in the settlement would lead to a shortage of current primary school places in the 3.2 Cumulative impact on primary school 0 Schools Planning Area. There is limited scope to further expand school provision due to site constraints. (Planning area)

The proposed allocations in the settlement would lead to a shortage of current secondary school places in the 3.3 Cumulative impact on secondary schools 0 Schools Planning Area. There is potential to accommodate growth by either expanding schools or identifying a (Planning area) new site. The proposed site allocations provide opportunities to enhance green infrastructure 3.4 Cumulative impact on the green infrastructure (+)

Settlement is served by a Sewage Treatment Works (STW) which has known spare capacity or planned additional 3.5 Cumulative impact on sewage treatment work (+) capacity capacity

The proposed allocations in this settlement do not have a material impact on the current or expected forecast peak 3.6 Cumulative impact on Central Line capacity (+) use of the Central Line stations within Epping Forest District

© Arup Site Deliverability Assessment Indicative Site Capacity Assessment

Site Reference: SR-0197 Site boundary amendment: No amendment made to site boundary. Settlement: Roydon Site constraints affecting extent of developable area Address: Land adjacent to Kingsmead, Epping Road, Roydon, Essex Site area (ha): 0.5

Notes: Lawn, part of large domestic garden On-site major policy constraints: None

Land type: Medium performing Green Belt adjacent to a settlement Area of site subject to major policy 0 constraints (ha):

Primary use: Housing On-site non-major policy constraints:

Area of site subject to non-major policy 0 constraints (ha): Unconstrained site area (ha): 0.5 Establishing indicative baseline density

Site located in: Large Village Site setting is: Other Site is near a commuter hub: No Indicative baseline density (dph): 39 Indicative baseline yield (units): 19

Refining the indicative site density

Identified density constraints: Ancient/Veteran Trees outside of Ancient Woodland, TPOs

Constraints density adjustment: -5% (dph): 37.05 Justification for adjustment: Ancient/Veteran tree located on site likely to require buffer that could reduce capacity marginally, and density reduced accordingly. TPOs located off-site and not likely to affect density.

Client Epping Forest District Council Local setting: Lower density setting and character of surrounding development likely to require reduction in density. Density reduced accordingly. Job Title ! Epping Forest District Local Plan

Drawing Status Local setting density adjustment: -45% (dph): 20.38 Issue Incorporate mixed use development: Site proposed for solely residential use. Drawing No Issue SR-0197 P1

Mixed use density adjustment: 0% (dph): 20.38

Gross to net adjustment: 0% (dph): 20.38 © Contains OS data © Crown copyright and database right (2016) Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © Existing on-site development or OpenStreetMap contributors, and the GIS User Community 0 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community commitments (units):

Availability and Achievability Assessment Indicative net site capacity (units): 10

Criteria Score Qualitative Assessment

Site is in single ownership 1.1 Ownership (+)

There are no existing uses on-site or existing uses could cease in less than two years 1.2 Existing uses (+)

Site is not subject to any known restrictions Although there is uncertainty over whether development would be reliant on the development of other land, there are 1.3 On-site restrictions (+) no known restrictions that would prevent the site coming forward.

Site expected to be available between 2016 and 2020 1.4 Site availability (+)

Site is not being actively marketed As the position on the site is unknown following the survey, it is assumed that the site is not being actively marketed. 2.1 Site marketability (-)

No viability issues identified 2.2 Site viability (+)

Identified on-site constraints may impact upon deliverability. There may be some constraints to accessing the site which could impact on the delivery of the site. No mitigation or 2.3 On-site and physical infrasturcture constraints (-) design solutions have been identified to limit impacts.

Site is located in a school planning area with a current or forecast deficit and where schools have limited ability to 2.4a Primary schools (Planning area) (-) expand

Site is located within 1km of a primary school with a current or forecast capacity deficit 2.4b Primary schools 0

Site is located in a school planning area with a current or forecast deficit but schools have potential to expand 2.5a Secondary schools (Planning area) 0

Site is located more than 1km from a secondary school 2.5b Secondary schools (-)

Site is located within 400m of existing publicly accessible open space, or there are proposals for new on-site open 2.6 Access to open space (+) space provision as part of the development.

Site is located more than 1km of a health facility (GP) 2.7 Health (-)

None of the site is located within a minerals safeguarding area 2.8 Impact on mineral deposits (+)

There are no identified current deficiencies in the quantum of open space within the settlement. No open space is 3.1 Cumulative loss of open space in settlement (+) lost as a result of the proposed allocations in the settlement

The proposed allocations in the settlement would lead to a shortage of current primary school places in the 3.2 Cumulative impact on primary school 0 Schools Planning Area. There is limited scope to further expand school provision due to site constraints. (Planning area)

The proposed allocations in the settlement would lead to a shortage of current secondary school places in the 3.3 Cumulative impact on secondary schools 0 Schools Planning Area. There is potential to accommodate growth by either expanding schools or identifying a (Planning area) new site. The proposed site allocations provide opportunities to enhance green infrastructure 3.4 Cumulative impact on the green infrastructure (+)

Settlement is served by a Sewage Treatment Works (STW) which has known spare capacity or planned additional 3.5 Cumulative impact on sewage treatment work (+) capacity capacity

The proposed allocations in this settlement do not have a material impact on the current or expected forecast peak 3.6 Cumulative impact on Central Line capacity (+) use of the Central Line stations within Epping Forest District

© Arup Site Deliverability Assessment Indicative Site Capacity Assessment

Site Reference: SR-0304 Site boundary amendment: No amendment made to site boundary. Settlement: Roydon Site constraints affecting extent of developable area Address: Roydon, North East Area Site area (ha): 1.44

Notes: Broad Area North East of Roydon On-site major policy constraints: Flood Zone 3b affects northern and eastern boundaries of the site.

Land type: Medium performing Green Belt adjacent to a settlement Area of site subject to major policy 0.48 constraints (ha):

Primary use: Housing On-site non-major policy constraints:

Area of site subject to non-major policy 0 constraints (ha): Unconstrained site area (ha): 8.64 Establishing indicative baseline density

Site located in: Large Village Site setting is: Other Site is near a commuter hub: No Indicative baseline density (dph): 39 Indicative baseline yield (units): 337

Refining the indicative site density

Identified density constraints: Nationally Protected Sites, Conservation Area, Listed Building

Constraints density adjustment: -50% (dph): 19.5 Justification for adjustment: Site's distance to Nationally Protected Sites means that mitigation is not likely to constrain density. Impact to Conservation Area and Listed Buildings likely to require mitigation through a reduction in density.

Client Epping Forest District Council Local setting: Development should be limited to the area up the existing public right of way, which would 'round-off' the settlement. This equates to ! Job Title approximately one sixth of the site. Epping Forest District Local Plan

Drawing Status Local setting density adjustment: -84% (dph): 3.12 Issue Incorporate mixed use development: Site proposed for solely residential use. Drawing No Issue SR-0304 P1

Mixed use density adjustment: 0% (dph): 3.12

Gross to net adjustment: -10% (dph): 2.81 © Contains OS data © Crown copyright and database right (2016) Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © Existing on-site development or OpenStreetMap contributors, and the GIS User Community 0 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community commitments (units):

Availability and Achievability Assessment Indicative net site capacity (units): 24

Criteria Score Qualitative Assessment

Site ownership is unknown or is in multiple ownership and the other owners are either unknown, oppose the An enquiry from the land registry returned multiple titles and no information for a large portion of the site in the north. 1.1 Ownership (-) development or are promoting another conflicting scheme

Existing uses on-site where the use could cease in more than 10 years or the timescale for on-site uses ceasing is An enquiry from the land registry returned no information on ownership for the main portion of the site and there is no 1.2 Existing uses (-) unknown known timescale for existing on-site uses to cease.

Site is not subject to any known restrictions 1.3 On-site restrictions (+)

Site not expected to be available until at least 2026 or site availability is unknown The availability of the site is unknown. 1.4 Site availability (-)

Site is not being actively marketed An enquiry from the land registry returned no information on ownership for the main portion of the site and the site has 2.1 Site marketability (-) not previously been put forward for development.

No viability issues identified 2.2 Site viability (+)

There are no known on-site constraints which would impact upon deliverability No data is held on on-site constraints. 2.3 On-site and physical infrasturcture constraints (+)

Site is located in a school planning area with a current or forecast deficit and where schools have limited ability to 2.4a Primary schools (Planning area) (-) expand

Site is located within 1km of a primary school with a current or forecast capacity deficit 2.4b Primary schools 0

Site is located in a school planning area with a current or forecast deficit but schools have potential to expand 2.5a Secondary schools (Planning area) 0

Site is located more than 1km from a secondary school 2.5b Secondary schools (-)

Site is located within 400m of existing publicly accessible open space, or there are proposals for new on-site open 2.6 Access to open space (+) space provision as part of the development.

Site is located more than 1km of a health facility (GP) 2.7 Health (-)

None of the site is located within a minerals safeguarding area 2.8 Impact on mineral deposits (+)

The site has not been included in the assessment as it is not proposed for allocation 3.1 Cumulative loss of open space in settlement 0

The site has not been included in the assessment as it is not proposed for allocation 3.2 Cumulative impact on primary school 0 (Planning area)

The site has not been included in the assessment as it is not proposed for allocation 3.3 Cumulative impact on secondary schools 0 (Planning area)

The site has not been included in the assessment as it is not proposed for allocation 3.4 Cumulative impact on the green infrastructure 0

The site has not been included in the assessment as it is not proposed for allocation 3.5 Cumulative impact on sewage treatment work 0 capacity

The site has not been included in the assessment as it is not proposed for allocation 3.6 Cumulative impact on Central Line capacity 0

© Arup Site Deliverability Assessment Indicative Site Capacity Assessment

Site Reference: SR-0890 Site boundary amendment: No amendment made to site boundary. Settlement: Roydon Site constraints affecting extent of developable area Address: Land at Epping Road, Roydon, Harlow, Essex Site area (ha): 6.33

Notes: One residential dwelling with outbuildings and garden and agricultural field to the rear On-site major policy constraints: None

Land type: Medium performing Green Belt adjacent to a settlement Area of site subject to major policy 0 constraints (ha):

Primary use: Housing On-site non-major policy constraints:

Area of site subject to non-major policy 0 constraints (ha): Unconstrained site area (ha): 6.33 Establishing indicative baseline density

Site located in: Large Village Site setting is: Other Site is near a commuter hub: No Indicative baseline density (dph): 39 Indicative baseline yield (units): 247

Refining the indicative site density

Identified density constraints: Nationally Protected Sites, TPOs, Conservation Area

Constraints density adjustment: 0% (dph): 39 Justification for adjustment: TPOs located on site boundaries, however mitigation likely to be accommodate without reduction in density required. Impact on setting of Conservation Area and Nationally Protected Sites not likely to constrain

Client capacity. No capacity adjustment made. Epping Forest District Council Local setting: Development should be limited to the property fronting Epping Road. This equates to 6% of the site area. Job Title ! Epping Forest District Local Plan

Drawing Status Local setting density adjustment: -94% (dph): 2.34 Issue Incorporate mixed use development: Site proposed for solely residential use. Drawing No Issue SR-0890 P1

Mixed use density adjustment: 0% (dph): 2.34

Gross to net adjustment: 0% (dph): 2.34 © Contains OS data © Crown copyright and database right (2016) Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © Existing on-site development or OpenStreetMap contributors, and the GIS User Community 0 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community commitments (units):

Availability and Achievability Assessment Indicative net site capacity (units): 15

Criteria Score Qualitative Assessment

Site is in single ownership 1.1 Ownership (+)

There are no existing uses on-site or existing uses could cease in less than two years 1.2 Existing uses (+)

Site is subject to restrictions but agreement in place or being negotiated to overcome them, or not judged to be a A public footpath runs through the site, but it is judged that this would not constrain development. 1.3 On-site restrictions 0 constraint

Site expected to be available between 2016 and 2020 1.4 Site availability (+)

Site is under option to a developer The site is under option to a housebuilder. 2.1 Site marketability (+)

No viability issues identified Based on the assumption from initial overviews that major infrastructure would not be required, and based on provision 2.2 Site viability (+) of housing in line with the Council's policy, the site is judged to be viable.

On-site constraints have been identified but mitigation or design solutions mean that there would be no impact The site has an identified need for connection to utilities, highways infrastructure, and telecoms, which may impact on 2.3 On-site and physical infrasturcture constraints 0 upon deliverability. deliverability. Connections have been identified close to the site to mitigate against these constraints.

Site is located in a school planning area with a current or forecast deficit and where schools have limited ability to 2.4a Primary schools (Planning area) (-) expand

Site is located within 1km of a primary school with a current or forecast capacity deficit 2.4b Primary schools 0

Site is located in a school planning area with a current or forecast deficit but schools have potential to expand 2.5a Secondary schools (Planning area) 0

Site is located more than 1km from a secondary school 2.5b Secondary schools (-)

Site is located within 400m of existing publicly accessible open space, or there are proposals for new on-site open Existing masterplans propose new public open space provision on-site as part of the development. 2.6 Access to open space (+) space provision as part of the development.

Site is located more than 1km of a health facility (GP) 2.7 Health (-)

None of the site is located within a minerals safeguarding area 2.8 Impact on mineral deposits (+)

There are no identified current deficiencies in the quantum of open space within the settlement. No open space is 3.1 Cumulative loss of open space in settlement (+) lost as a result of the proposed allocations in the settlement

The proposed allocations in the settlement would lead to a shortage of current primary school places in the 3.2 Cumulative impact on primary school 0 Schools Planning Area. There is limited scope to further expand school provision due to site constraints. (Planning area)

The proposed allocations in the settlement would lead to a shortage of current secondary school places in the 3.3 Cumulative impact on secondary schools 0 Schools Planning Area. There is potential to accommodate growth by either expanding schools or identifying a (Planning area) new site. The proposed site allocations provide opportunities to enhance green infrastructure 3.4 Cumulative impact on the green infrastructure (+)

Settlement is served by a Sewage Treatment Works (STW) which has known spare capacity or planned additional 3.5 Cumulative impact on sewage treatment work (+) capacity capacity

The proposed allocations in this settlement do not have a material impact on the current or expected forecast peak 3.6 Cumulative impact on Central Line capacity (+) use of the Central Line stations within Epping Forest District

© Arup SR-0304

SR-0303

SR-0117 SR-0423

SR-0169

SR-0035

SR-0675

SR-0306

SR-0890

SR-0197

Report on Drawing No. Content Legend Site Selection EFDC-S3-0015-Rev1 Results of Stage 3 Assessment for Residential Sites in Roydon Strategic Options Stage 3 Sites Site proceeds for Date: September 2016 further testing More suitable Suitable Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and strategic option Site does not the GIS User Community Not Suitable proceed for further Scale: 1:6,000 @A3 Less suitable testing ¯ strategic option Appendix B1.5.2 Results of Stage 3 Assessment for Residential Sites in Roydon

Strategic Option Settlement Option Suitability Justification for Option Suitability

This option provides opportunities to maximise existing urban brownfield land and develop on lower performing Intensification Roydon More suitable strategic option Green Belt sites immediately adjacent to the settlement.

Eastern expansion Roydon Less suitable strategic option This option would be the most harmful to the Green Belt, risking the coalescence of Roydon and Harlow.

This option is the most sensitive location in landscape terms and would be harmful to the setting of the Lee Valley Western expansion Roydon Less suitable strategic option Regional Park.

Site Rank

Site Size Capacity Site Ref. Address Settlement Site Suitability Justification for Site Suitability Site Category Site to Proceed to Stage 3/4 (Ha) (Units) Land Location Flood Risk Flood Agricultural Agricultural

SR-0035 Land at Epping Road, Roydon Roydon 0.19 7 Suitable The site scores poorly against several criteria, including landscape harm, but it was felt that 1 5 3 5 The site should proceed for further testing. it may be possible to overcome these constraints. Noting potential impact on Lee Valley Park and local parking constraints, the site should be considered. This site should continue to be considered.

SR-0117 The paddock to the rear of Roydon 1.31 39 Suitable The site scores poorly against several criteria, including landscape harm and contamination, 1 5 3 5 The site should proceed for further testing. Barn House, Farm Close, but it was felt that it may be possible to overcome these constraints. Noting potential impact Roydon, Essex, CM19 5LW on Lee Valley Park, the site should be considered further.

SR-0169 The Old Coal Yard, off 32 Roydon 0.53 16 Suitable This site is in a sustainable location at the edge of Roydon. Although the site scores less 1 5 3 5 The site should proceed for further testing. High Street, Roydon well against a number of criteria, it was felt that it may be possible to overcome constraints, including contamination, heritage and harm to the Green Belt. This site should continue to be considered.

SR-0197 Land adjacent to Kingsmead, Roydon 0.50 5 Suitable This site scores well across the majority of criteria and is in a sustainable location at the 1 5 3 5 The site should proceed for further testing. Epping Road, Roydon, Essex edge of Roydon. Though it is Green Belt, it was felt that it may be possible to mitigate impacts through landscaping. It should therefore be considered further.

SR-0303 Roydon, West Area Roydon 39.97 1200 Not suitable This site is part of a strategic option which was judged to be a less favourable growth N/A The site should not proceed for further testing. direction. This option would be most sensitive in landscape terms and would be harmful to the setting of the Lee Valley Regional Park.

SR-0304 Roydon, North-east Area Roydon 9.12 273 Suitable The eastern part of the site scores poorly in terms of landscape and Green Belt harm, with 1 5 3 5 The site should proceed for further testing. potential for coalescence between Roydon and Harlow. The western part of the site is less constrained and should be considered further, noting the reduced capacity.

SR-0306 Roydon, south-east Area Roydon 14.05 422 Not suitable This site is part of a strategic option which was judged to be a less favourable growth N/A The site should not proceed for further testing. direction. This option would be most sensitive in Green Belt terms, risking the coalescence of Roydon and Harlow.

SR-0423 Land East of Little Brook Roydon 0.88 27 Not suitable This site is part of a strategic option which was judged to be a less favourable growth N/A The site should not proceed for further testing. Road, Roydon direction. This option would be most sensitive in Green Belt terms, risking the coalescence of Roydon and Harlow.

SR-0675 Parkfields Garages, Nos. 4- Roydon 0.24 4 Not suitable Following further assessment by the Council, it was judged that this site would not support N/A The site should not proceed for further testing. 19, Roydon the minimum development threshold for allocation in the Local Plan (6 units) and should not be considered further. SR-0890 Land at Epping Road, Road, Epping at Land SR-0890 SiteRef. Roydon, Harlow, Essex Roydon,Harlow, Address Roydon Settlement .360 6.33 Site Size (Ha) Capacity Capacity (Units) Suitable SiteSuitability proposed. This site should continue to be considered. be to continue siteshould This proposed. than density mayit that development higher isnoted It accommodate overcome. be may constraint harm landscape identified the that felt wasit and most criteria against well Roydon.scores It of edge the at moderatelylocation a in sustainable siteis located This JustificationSiteSuitabilityfor

5 3 5 1 Flood Risk SiteRank

Location

Agricultural Land SiteCategory The site should proceed for further testing. further for proceed siteshould The Site to Proceed to Stage 3/4Stageto Proceed Siteto SECTION TWO ROYDON TO BROXBOURNE

Setting the Scene complementing Rye Marsh to the north. Admiral’s Walk Lake and its surrounding meadows support a notable bat population. Many Proposals for the future use of Section Two have been drawn up in smaller rivers and streams are already valuable for their natural a Park-wide context so that the best use is made of the resources form and water quality. and so that a range and hierarchy of leisure activities can be achieved across the whole Regional Park. This Section is one of the The Netherhall monument and Broxbourne Mill are points of historic greatest areas of opportunity remaining in the Regional Park due to interest. the imminent completion of mineral extraction and the resultant creation of new areas of land and water. Extensive areas of gravel extraction, dissection by numerous roads, tracks and the railway, the occurrence of several linear built Section Two is characterised by a complex and varied pattern of land developments and extensive glasshouses both within and outside uses which gives it a fragmented feel. The vacant and operational the Regional Park boundary have a detrimental impact. Many of the gravel workings will provide a future land bank to help achieve the glasshouses are in a poor state of repair and are surrounded by purpose of the Regional Park. Significant areas of housing are patches of rough ground. This all results in a negative effect on the already established and will remain. Technically, the Keysers Estate character of the Regional Park as a whole. However, these sites and Avenue Road to Eldon Road are not part of the Regional Park provide future opportunities for the appropriate development of the although they have an impact on the Park (and vice versa). Regional Park.

Key Resources and Special Features Opportunities for Visitor Enjoyment

The exposed, rolling farmland setting to the east creates an open, The particular strengths of Section Two are the existing popular rural context. The valley slopes are set back except at Roydon Park, recreational areas at Broxbourne, and Roydon Mill; the a prominent and unique wooded hill. Clay Hill and Clayton Hill both successful water sports operation at Nazeing; the boating on the form distinctive features along the eastern edge, and there are Navigation utilising existing moorings and club facilities and the notable views into the Regional Park from the railway which skirts extensive angling facilities. the western edge of this Section. The water resources already contribute to a hierarchy for water Where the landscape is more mature, the main nature conservation sports opportunities within the Regional Park. Water sports value lies in the grasslands, hedgerows and woodlands. The water development opportunities could be further improved with greater bodies provide feeding and roosting sites for wildfowl investment and management. Broxbourne Sailing Club offers tuition

Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 47 Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 48

and club facilities at Nazeing Meads North Lagoon, and at Central The area is well served by train and minor roads. The Lagoon, the only club based junior sailing tuition facility in the area. forms a continuous unifying north-south route and the Three Although national trends indicate that the windsurfing market is Forests Way traverses the Park. A comprehensive network of declining, courses remain popular. Roydon Mill Lake is one of only footpaths, bridle paths and cycle routes is not as yet in place and two sites in the Regional Park available for water-skiing. Whilst local access points are often difficult to find. general canoeing activities can be accommodated along the Lee Navigation, the white water canoe facility at Dobbs Weir is of The active use of the water is an attractive feature for other regional importance. Broxbourne Rowing Club is based on the countryside visitors. Land around the lakes awaiting restoration will Navigation where training for competitions is carried out. enable the Regional Park to meet a wider range of visitors’ needs.

This Section is already popular with visitors for water recreation. At the fisheries, there has been considerable investment in stocking as The Proposals well as in infrastructure. The provision of higher quality facilities would increase the popularity even further. The Lee Valley Leisure The Proposals for Section Two aim to contribute to the development Pool has been refurbished for recreational swimming and fitness of a hierarchy for water sports throughout the Regional Park. In activities. Both the Lee and Stort Navigations pass through the addition, attractive riverside and wetland parkland will be created Section. The Lee Valley Boat Centre offers a variety of recreational from derelict land for both day and short break visitors. This Section boating activities. The Broxbourne Cruising Club has its base and will contrast with the sections to the North and South by featuring moorings on the Navigation on active use of the resources. Informal recreation with refuges for water birds will provide a balance in the adjacent sections. In addition to water recreation, the existing leisure facilities are for informal recreation. The Roydon Mill Leisure Park provides static caravans, a touring caravan and camp site, a variety of leisure activities as well as the lake for water-skiing and casual water recreation. The caravan site at Dobbs Weir also provides static and touring caravan pitches and has space for tents. The Goats at Carthagena, is a static site only. There are four holiday chalets at Broxbourne. The public houses are very popular all year and offer food and drink. Visitors to this Section of the Regional Park can therefore find accommodation and can add their support to the full services offered in Roydon Village and Broxbourne. SECTION TWO PROPOSALS

Ref Proposal Explanation

2 Area providing for a wide range of recreational and Park Plan Part One policies provide guidance on the implementation of proposals sporting activities based on and around the water in this Section, in particular: L1.1-L4.4, LS1.2-LS1.6, LS2.1, LS2.2, LS4.1, NC3.1, resources of the Lee and Stort Navigations and the lakes. W1.1, W2.1, W2.3, WR2.1-WR2.3, WR3.1-WR3.10, IR2.1-IR2.3, IR2.12, FR3.1- FR3.3, T1.1, T2.3, T3.1, T5.3.

In addition to the Strategic Proposals LVRP1-4 and Park- The primary focus of this area is to achieve a broader range of wide Proposals, specific Section-wide proposals to activities than is currently available in the Regional Park through a contribute towards the achievement of the Vision for the partnership of private landowners and the Park Authority. The Regional Park are: under used land and water resources provide opportunities for a An emphasis to be placed on water and water-side sport countryside tourism (2.1), watersports development (2.2) and and recreation, countryside sports and supporting visitor intensive countryside recreation (2.3) accessed principally from services being developed on vacant and under used land Roydon (2.1) and Broxbourne (2.4). The future strength of this and water. area lies in its water and the opportunities to enjoy water and the b A route across the Valley for the London Orbital Bridleroute water-side environment for both informal and formal recreational to be identified, safeguarded and implemented. activities (Proposal WMS). The inter-relationship of the lakes at c Areas of visually attractive landscape character to be Glen Faba and at Nazeing Meads can be recognised through their protected and conserved. The remaining gravel workings to management and future use. Major opportunities lie in bringing be restored and associated plant and machines to be the vacant and under used land and water into use over the removed. coming years. A coordinated approach to the restoration of d Opportunities to enhance nature conservation to be given mineral sites can spread the best practice achieved in Section One. priority on designated lakes, on natural rivers and streams and in the management of grasslands, hedgerows and Residents in adjacent communities are concerned that any future woodlands. development of the area should not lead to noise disturbance or e Biodiversity targets to be achieved through the protection traffic generation. The Park Authority also shares concerns about of existing habitats, the creation of higher quality habitats the impact of traffic on the enjoyment and safety of visitors and on the Rivers Stort and Lynch and areas of new wetland on the regeneration of the Regional Park. Although numbers of habitat and of floodplain grassland to be created. heavy vehicles used by the minerals companies should decline over f The Greenwich Meridian to be celebrated throughout site the next few years, these are being replaced by traffic generated 2.3 and a feature to be made of its intersection with the Lee by importers of horticultural and food products. Proposals seek to

Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 49 Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 50

Ref Proposal Explanation Valley Walk at Carthagena Lock and at the entrance to the address this issue. Nazeing Meads area (site 2.2) as part of Proposal M. g Broxbourne and Roydon Stations to be developed and The railway opens up a public window on the Regional Park and, promoted as main entrances to the Regional Park and therefore, the opportunity should be taken to create a high quality timetables to be adjusted to match visitor requirements in landscape which will project the Park’s image. The accessibility by terms of daily service and frequency as part of the Lee train of this Section is one of its primary assets and will play an Valley Line Proposal LVL. important role in the provision of sustainable leisure (Proposal h Traffic calming and measures to improve pedestrian and LVL). However, the provision of a regular and daily train service is a cyclist safety to be implemented at Dobbs Weir Road and at necessity to the Park’s regeneration. Nazeing Road. Landscape improvements to be made on these two important cross valley links. Landowners and industrial/horticultural occupiers - whether in or i New development in areas of established housing to adjacent to the Regional Park, can be encouraged to make a contribute to the achievement of the Regional Park through positive contribution to achieving the Vision for the Regional Park improvements to landscaping and the quality of built through increased maintenance of their land and the provision of development appropriate to the overall proposal area which landscape buffers (Proposal LS). they lie within or are adjacent to. j A positive landscape quality to be achieved through the The mix of land uses, remnant horticultural glasshouses and retention of open views to the rural valley sides, the penetration of urban and suburban elements into this Section rationalisation of signage, the maintenance of boundary weakens its potentially more rural character. The resulting fencing, verge maintenance along roads and the railway, experience is of a landscape of only moderate quality despite the the removal or improvement of derelict glasshouses, and more attractive spaces along the Navigation. Views from the higher quality design of buildings (existing and proposed). higher ground around Roydon are spoilt by the pylons, glasshouses k The overall image and purpose of the Regional Park to be and unattractive uses which are not compatible with the purposes protected from intensification of commercial and industrial of the Regional Park. This area has enormous scope for uses. Measures to mitigate adverse impacts on visitors and improvement of landscape quality and an enhanced identity. The the environment to be implemented. restoration of land will improve the image of the locality and should also benefit businesses in the area.

The Health and Safety Executive advise that constraints are imposed by the presence of the notifiable installation at Hoddesdon Holder Station and by the gas pipeline which crosses the Valley. Ref Proposal Explanation WC2 Waterway Corridor

In addition to Park-wide Proposal WC: The Waterway Corridor is already an asset for Section Two in visual a The attractiveness of the focal points at Carthagena, Dobbs terms. Proposals therefore concentrate on protecting the Weir and Fieldes Weir Locks to be protected and environment and bringing the Corridor into greater recreational information/signage to be provided to encourage visitors to use. The quality of the Corridor will contribute to the overall explore the area. experience of the national cycle network. b The recreational use of the Navigation to be improved including canoe facilities, launching/porterage points at The Lee Navigation and Flood Relief Channel have the ability to existing locks, visitor moorings, modernisation of club provide additional facilities for canoeists. Detailed surveys will facilities and the development of water recreation activities. provide guidance on stretches of navigation suitable for water c The importance of the “cut off” to Otters and recreation; banks which are accessible and those which should be Water Voles to be enhanced through habitat management managed for wildlife; and how to overcome potential dangers of and creation. Disturbance to be mitigated through the utilising part of the flood defence system for recreation. establishment of wildlife refuges and the installation of dedicated fishing platforms. Additional visitor services are required at the Dobbs Weir gateway d Areas of new wetland habitat to be created. to the Regional Park where traffic congestion is an issue. e The peaceful character of the Stort Navigation to be Alternative means of access should be explored and improvements protected. made to current car parking arrangements. The implementation f A route for part of the national cycle network to be of the landscape buffer on the periphery of the industrial area is identified and safeguarded in the Stort Valley. vital to improving the image of the gateway. g A new safe crossing of the road to be provided at Dobbs Weir and improved links to be made between the towing The junction of the Lee and Stort Navigations can also be improved path and other paths. through landscaping, signage and links beyond to create an h The North East Hoddesdon industrial area and any other attractive entrance to the Park. potentially intrusive land use to be integrated with the Waterway Corridor by a landscaped buffer and well designed buildings.

Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 51 Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 52

Ref Proposal Explanation

PW2 Lee Valley Pathway Corridor The route of the Lee Valley Pathway is shown as an indicative route on the Proposals Map in this Section.

In addition to Park-wide Proposal PW: Timescales, land ownership and safety issues will need to be a An attractive and feasible route to be identified, resolved in identifying the route of the Lee Valley Pathway. safeguarded and implemented. Currently, the proposed route requires a technical solution to crossing the railway and a safe crossing point on Dobbs Weir Road. The large scale land restoration outlined in other proposals is to create the attractive corridor for the route.

2.1 Area of increased activity for a range of countryside recreational activities in conjunction with enhancement of nature conservation and protection of the rural landscape quality. In addition to the Section-wide Proposal: This area has a strong rural character dominated by the Across the area: agricultural use and mixed vegetation on the eastern valley both a Low intensity countryside activities and informal within and beyond the Regional Park boundary where further countryside recreation to be encouraged on the open skyline tree and woodland planting would be of benefit. Low Hill farmland and open space on the valley side. The high quality Road, a protected lane, contributes to the historic and landscape rural landscape to be protected and where built value of the Regional Park boundary. The rural valley sides form a development currently impacts on the eastern boundary, a strong enclosure of this area. Any changes in land use and buffer zone to be created. management will have an impact on the achievement of this b New visitor facilities to be provided to support the use of proposal and affect the quality of the environment within the Park. land for leisure and recreation and to allow investment to modernise existing facilities. Uses should be complementary Roydon has potential as a gateway to the Regional Park for those to Roydon Village and openness should be maintained. arriving by train, foot, cycle, boat and horse. At this point the Park c Both linear and circular routes to be created for is connected to communities and other recreational areas via the pedestrians, cyclists and horse riders through agreements Stort Navigation and the Three Forests Way. Roydon Parish Church between landowners. and a range of interesting buildings in the village and at Roydon d The rural landscape character of farmland and woodland on Mill contribute to the sense of arrival at the gateway. the sloping valley side to be protected. Ref Proposal Explanation e Agricultural good practice and nature conservation to be Glen Faba lakes have the potential to meet water recreation promoted. objectives for non motorised activities. An intensive fishery is already a successful facility. Further development appropriate to At specific locations: the floodplain, in conjunction with the rest of site 2.1, would f At Roydon Mill Leisure Park: enable all the lakes to meet their potential. The Glen Faba lakes ➢ Improvements to visitor accommodation and leisure also have nature conservation value as a feeding site for wintering facilities to be encouraged. water birds, notably Gadwall, Tufted Duck and Pochard. Guidance ➢ The visual quality of the site to be enhanced further on meeting both nature conservation and water recreation targets and its setting, openness and rural qualities to be can be provided in an integrated leisure and land management protected. plan for site 2.1. The continuing programme of gravel extraction ➢ Facilities associated with the lake’s use as a Leisure provides a further opportunity for restoration to increase wetland Priority Site to be improved through investment to and grassland habitats. develop recreational and water sports use together with protection of its freshwater ecology. A balance will need to be achieved over future years to retain a ➢ This key entrance to the Regional Park to be viable use of the farmland whilst protecting its high quality promoted alongside the attraction and interest of landscape and nature conservation value and compatibility with its Roydon Village. location within the Park. All development should achieve the g At the Glen Faba Lakes: highest standards of design. There is the potential to provide ➢ Based on enjoyment of the waterside environment, equestrian activities not available elsewhere in the Regional Park future development and management to be as within Section Two. In partnership with landowners, the highways Integrated Use Sites to balance water and informal authority and the Parish Council, existing bridle paths which recreation with the needs of wildlife, notably wildfowl. currently do not connect except through Roydon Village could be ➢ Built facilities to service visitors and to enable the inter-linked off road. This could potentially form part of the best use of the water resource to be developed. London Orbital Bridleroute. ➢ Facilities for anglers to be improved. h From Dobbs Weir Road: ➢ The open views northwards to be protected and measures taken to prevent further intrusive elements and to reduce the impact of existing non-Park uses and developments. ➢ The distinctive landmark of Netherhall tower to be protected and views of it created.

Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 53 Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 54

Ref Proposal Explanation 2.2 Area where emphasis will be on enjoyment of water sports and informal recreation in a waterside environment.

In addition to the Section-wide Proposal: Nazeing Meads lagoons are used for a variety of water sports and a Nazeing Meads North Lagoon to be designated a Leisure for angling. The nature of shared use on small water bodies is that Priority Site. The appearance of recreational facilities the highest standards cannot be achieved for each individual associated with the lake to be improved and facilities to be activity. The potential nature conservation value can also be modernised to meet visitor expectations and to provide for depressed. Overall, consideration of the large water bodies in staff managing and maintaining the site. Section Two suggests each activity could have dedicated use of b Nazeing Meads Central and South Lagoons to be designated specific lakes and this in turn would have beneficial consequences and managed as Integrated Use Sites where recreation, for wildlife. Sailing could possibly be achieved to a higher standard including a centre of excellence for angling, and nature over the Regional Park as a whole. This is a long-term proposal conservation take equal priority. and therefore requires each water body and its surrounding land c Management plans to be implemented to protect current to be safeguarded whilst also maintaining the flood storage nature conservation value whilst catering for the needs of capacity of the lagoons. The smaller lakes can be developed to visitors. In the winter, a “hard weather refuge” to be their potential with centralised and shared support facilities protected on the lagoons. serving the whole of this proposal area. d The smaller lakes of Brackens Pool, the Water Hole and Wrightons Lake to be safeguarded as Leisure Priority Sites. The quality of recreational activities is reliant on the quality of e Provision for specialist outdoor recreation to be supporting facilities. There will be a need for buildings and accommodated. structures to support the designation of the lagoons and lakes for f The main entrance into the area to be created on Nazeing a high standard fishery and to achieve standards of excellence in New Road. Built development, car parking and landscape water sports. enhancement to be provided for visitor interpretation and services. Links with Broxbourne Station to be strengthened. The Park Authority was established to achieve land restoration g A corridor of parkland to continue to be created between where previous mechanisms had failed and this challenge remains the Navigation and the Lagoons to enable the valley to be on site 2.2. However, the extent of contamination requires large- opened up to visitors. Accessibility through the area by foot scale investment and large quantities of clean capping materials. and bicycle to be achieved. This Proposal may take many years to achieve. Although full public h The open character of the valley floor to be protected from access may not be safely provided, sites such as St Paul’s Field development to the rear of properties in Nursery Road and contribute to the openness of the Valley and have developed their Ref Proposal Explanation at Sedge Green Nurseries. Over the long-term, non-Park own ecological value and therefore contribute to the character of compatible intrusive uses to be removed or their adverse the Regional Park in other ways. impact mitigated including through the use of the Authority’s land purchasing powers if necessary. Avenue It has been a long term aim of the Park Authority to purchase all planting and block woodland planting to help provide a land between the Navigation and the Lagoons (known as greater visual structure to the landscape. Carthagena). Land which does not serve visitors to the area causes i A programme of phased remediation to be undertaken to fragmentation, disrupts routes through the Park, and has a tackle dereliction and contamination throughout Proposal detrimental environmental impact on the image and purpose of area 2.2 to enable public use of the open space and leisure the Regional Park. Clearance and consolidation has already had a facilities to be provided. This would include the removal (or beneficial impact on the Park which the remaining occupiers are replacement) of derelict glasshouses and large scale now enjoying. It is intended to maintain the impetus to complete decontamination either side of Nursery Road and on St this project. Paul’s Field. j The Flood Relief Channel to be improved to meet visual and There are established industrial and residential sites lying in the biodiversity objectives. midst of this Proposal area. They are included because of their k The impact on the Regional Park of industrial sites, impact on the achievement of this proposal. The policies in Part structures and buildings to be improved through measures One of the Plan indicate how their impact can be reduced through that contribute to a reduction in noise, traffic generation, the design, height and mass of buildings and the encouragement visual effect and intrusion. Higher quality development to of changes of use for leisure and recreation. be sought and particular attention to be paid to the boundaries with open space. It is intended that, in the long It is desirable from the national viewpoint that there should be a term, all such sites should be brought into leisure and flourishing horticultural industry. However, the development of a recreational use where this would be compatible with the regional recreational resource is not assisted by areas of derelict function of this Section. glasshouses or by intensification which results in more permanent l At Carthagena, the Authority will continue to purchase land structures and which uses building materials which adversely affect and buildings to assemble an integrated recreational open the openness of the Green Belt. Studies towards achieving a space. realistic future should involve all relevant parties. Where land is no longer required for the horticultural industry, it should be incorporated into the open countryside according to the original intentions of Parliament when drawing the Regional Park boundary.

Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 55 Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 56

Ref Proposal Explanation Changes in use or other developments which have a detrimental impact on the image and purpose of the Regional Park or which conflict with leisure users will be resisted by the Park Authority. The eventual redevelopment of industrial sites for leisure or recreation, which could generate an equivalent level of replacement employment, is likely to be welcomed.

2.3 Area of opportunity for intensive countryside and informal recreation activities with a focus on the Lee Navigation. In addition to the Section-wide Proposal: This area is a key opportunity site. It has the attraction of the a A comprehensive development scheme to be achieved for proximity of Broxbourne station and the secure boundaries formed the whole area to ensure the site is restored and integrated by the railway and the navigation and other waterways. The area into the Regional Park. has the capacity to support large numbers of visitors arriving by b The Spitalbrook site to be developed for leisure and train. A substantial part of this site (known as Spitalbrook) is recreation set well within an extensive parkland setting. vacant and not fully restored following gravel extraction. Restoration of the site to be completed through large scale Significant investment is needed to bring it into use compatible investment in the quality of the landscape. Facilities at the with its high profile location within the Regional Park. Restoration northern end of the area to contribute to the popularity of is likely to be completed as part of the redevelopment of the site Dobbs Weir and the Waterway Corridor. An extensive buffer for leisure and recreation. Temporary leisure uses may be zone in the north of the area to be planted to define the appropriate until permanent development is completed. A boundary of the Regional Park and mitigate adverse effects comprehensive solution for the whole area should be brought of adjoining uses on visitor enjoyment. forward for agreement between the Park Authority, the c All lakes within Site 2.3 to be managed as Integrated Use landowners, the local authorities and other interested parties. Part Sites realising their potential for recreation and nature One policies provide guidance of identifying the most appropriate conservation. leisure uses. d Admiral’s Walk Lake to be managed as an Integrated Use Site for angling and nature conservation. Its surrounding Admiral’s Walk Lake and its margins are the most important site floodplain grassland to be protected, access improved and for bats in the Regional Park. The Water Management Strategy landscape quality enhanced and effectively managed. recommends the lake be managed as a fishery. There is limited e Further investment in visitor accommodation relating to potential for other water activities if biodiversity targets are to be the Broxbourne Gateway to be developed. met. The adjacent meadow-land provides invertebrate habitat for Ref Proposal Explanation f Between the two gateways of Broxbourne and Dobbs Weir, the bats. (Beyond the Regional Park boundary). Footpath links nature conservation to be encouraged through wetland provide for circular walks between the New River and the habitat creation and improvements. The River Lynch to be Navigation. Development to the north outside the Park should re-instated to a natural river channel. respect the qualities of the area with appropriate siting of new g Road improvements to bring the area into use to provide buildings and landscape. There is a longstanding proposal to for pedestrians and cyclists with safe links at Broxbourne ensure a 60ft landscape buffer on the periphery of the adjacent Gateway and at Dobbs Weir. North East Hoddesdon Industrial Area.

2.4 Broxbourne Gateway to Nazeing Meads and to the River Lee Country Park

In addition to the Section-wide Proposal: Broxbourne is a key destination for the public. In the area there a Landscape to be improved and views of Broxbourne Parish are several public, private and voluntary recreational facilities each Church and the New River to be protected. run independently and without consideration for each other. b Visitor facilities and opportunities to enjoy the waterside to Uniquely, Broxbourne is a location in the Regional Park where the be centred on the Navigation and the Lee Valley Leisure general public can explore the Navigation by boat. The area would Pool. benefit from a master plan to harness the opportunities to refocus c Use of the Navigation to be promoted for boating and on the water resource and to integrate activities. rowing. d Visitors to be encouraged to explore the country parks There is a need to reduce the impact of traffic on the countryside. beyond the Gateway by foot and cycle through use of train Broxbourne’s proximity to a major railway station gives it or park and ride schemes. considerable advantage over other areas of the Park. The Gateway Proposal is designed to offer visitors an attractive alternative to car transport. The visitor capacity of Sections Two and Three can be increased if car dependency is reduced.

Lee Valley Regional Park Plan Part Two: Proposals SECTION TWO 57

PDF created with pdfFactory Pro trial version www.pdffactory.com There is one small area of urban greenspace character on the southern edge of the settlement edge which contributes toward the local landscape character within the eastern fringe of the settlement;

There are two medium sized patches of sensitive woodland within the fringes of the village which contribute to local landscape character;

There are many veteran trees located within the landscape of the village which are sensitive landscape and historic features;

An interconnected network of public footpaths creates sensitive recreational routes within the fringes of the village. These provide access for pedestrians and cyclists throughout the area and connect the settlement to the surrounding landscape; and The wide floodplain of the River Stort borders the northern edge of the village, whilst the wide floodplain of the River Lee is situated in relatively close proximity to the western edge of the village.

Sensitivity of Landscape Setting Areas

8.5.2 Taking into account the above, the sensitivity of each Landscape Setting Area is evaluated as follows, based on the criteria set out in section 1.5.3:

Landscape Landscape Character Sensitivity Visual Sensitivity Overall Setting Sensitivity Area to change Representation Number of Overall Intervisibility Visual Overall of typical sensitive Landscape Prominence Visual character natural, Character Sensitivity cultural Sensitivity and historic features

1 High 2 High 3 High 4 High

8.6 Key Opportunities for Growth

8.6.1 Drawing on the above analysis, those Landscape Setting Areas identified as high or moderate overall sensitivity are considered desirable to safeguard in landscape terms and are considered to have a significant role in contributing to the structure, character and setting of the settlement. Landscape Setting Areas that have been identified as low sensitivity may be suitable for development in landscape terms and are considered to have a less significant role in

March 2012 68 Epping Forest District Settlement Edge Landscape Sensitivity Study 11110602 LSS Final Report_V2_11-01-10.doc Chris Blandford Associates

PDF created with pdfFactory Pro trial version www.pdffactory.com contributing to the structure, character and setting of the settlement. Further assessment work would, however, be needed to examine site-specific landscape and visual sensitivities.

8.7 Contribution to Green Belt

8.7.1 In line with methodology set out within Section 1.5.27, an evaluation of the contribution that the landscape setting of Roydon makes to the purposes of including land within the Green Belt (PPG2: Paragraph 1.5) is set out within the table below:

March 2012 69 Epping Forest District Settlement Edge Landscape Sensitivity Study 11110602 LSS Final Report_V2_11-01-10.doc Chris Blandford Associates

PDF created with pdfFactory Pro trial version www.pdffactory.com

Appendix 6

20 | Page

Saxon Izatt

From: John Richards Sent: 16 April 2018 15:31 To: 'Alison Blom-Cooper' Cc: 'LDFconsult'; 'David Coleman' Subject: RE: Land at Temple Farm, Roydon

Importance: High

Hi Alison,

Sorry to chase on this but could you come on my email of 27th March please.

Thanks.

John Richards Director, Planning MRTPI

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Direct: 01442 838135 • Mobile: 07525 593381

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From: John Richards Sent: 03 April 2018 15:07 To: 'Alison Blom‐Cooper' Cc: 'LDFconsult' ; 'David Coleman' Subject: RE: Land at Temple Farm, Roydon

Hi Alison,

Could you come back to me on this please.

Thanks.

John Richards Associate Director, Planning MRTPI

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1 Direct: 01442 838135 • Mobile:

HQ: 01442 838130 • E-mail: [email protected] • Web: www.dandara.com Dandara Hemel Hempstead, KD Tower, Cotterells, Hemel Hempstead, Hertfordshire, HP1 1FW

From: John Richards Sent: 27 March 2018 11:11 To: 'Alison Blom‐Cooper' Cc: LDFconsult ; David Coleman Subject: RE: Land at Temple Farm, Roydon

Thanks Alison.

I’ve also seen this which we referred to in our independent Green Belt and Landscape Assessment which accompanied our Reg. 19 representations at Appendix 4.

Our criticism was that your District‐wide assessment work was based on large parcels which could not be directly applied to specific sites without further finer grain assessment. This is explained at para. 7.3 of our report:

“The same inaccuracy is found with regard to the Settlement Edge and Landscape Sensitivity Study, which also assesses a far wider area. Whilst the parcel size issue could be levelled at many sites, the problem with this inaccuracy becomes tangible for sites such as land west of Roydon, where the urban fringe character abruptly changes into rolling countryside with significant topographic and vegetation changes beyond the initial urban fringe”.

This is echoed in your own SELS at para. 8.1.2 which makes the distinction between more open, river valley landscape moving towards the Lee Valley and the smaller‐scale fields adjacent to the settlement edge.

Our expectation from our meeting with David was that the evidence we submitted as part of the Developer, Landowner and Promoter Survey and alongside our representations to the Local Plan, including Masterplanning informed by landscape assessment work, would be taken into account within the updated 2017 Site Selection Report.

Whilst this seems to be the case for issues such as flood risk, you seem to be telling me that from a landscape perspective, the Report has simply referred to dated, Borough‐wide landscape reports rather than site specific work provided by respondents.

Can you just confirm that this is the case.

Thank you.

John Richards Associate Director, Planning MRTPI

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From: Alison Blom‐Cooper [mailto:[email protected]] Sent: 26 March 2018 17:21 To: John Richards Cc: LDFconsult ; David Coleman Subject: RE: Land at Temple Farm, Roydon

This is set out in the methodology for site selection – see link below and in particular section 5.1 on Page B208 http://www.efdclocalplan.org/wp‐content/uploads/2018/03/EB805E‐Appendix‐B1.4.1‐Detailed‐Methodology‐for‐ Stages‐2‐and‐6.2‐Assessment.pdf

The key piece of evidence was the Council’s Settlement Edge Landscape Sensitivity Study (SELS) from 2010. See link to report below http://www.efdclocalplan.org/wp‐content/uploads/2018/03/EB712‐Settlement‐Edge‐Landscape‐Sensitivity‐Study‐ C2010.pdf

Hopefully you now have what you need.

Alison Blom-Cooper

Interim Assistant Director | Planning Policy | 01992 564066 Epping Forest District Council | Civic Offices | 323 High Street | Epping | Essex | CM16 4BZ

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From: John Richards [mailto:[email protected]] Sent: 26 March 2018 16:52 To: Alison Blom-Cooper Cc: LDFconsult; David Coleman Subject: RE: Land at Temple Farm, Roydon

In that case can you explain how the landscape sensitivity was assessed?

Sorry to press.

Thanks.

John Richards Associate Director, Planning MRTPI

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From: Alison Blom‐Cooper [mailto:[email protected]] Sent: 26 March 2018 16:47 To: John Richards Cc: LDFconsult ; David Coleman Subject: RE: Land at Temple Farm, Roydon

Hi – the only assessment is that set out in the Stage 2 proforma which is on the website.

Alison Blom-Cooper

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From: John Richards [mailto:[email protected]] Sent: 26 March 2018 16:26 To: Alison Blom-Cooper Cc: LDFconsult; David Coleman Subject: RE: Land at Temple Farm, Roydon

Dear Alison,

Thank you for your quick response which is appreciated.

I’ve had sight of both of those assessments which are helpful and effectively conclude that the site should not be progressed for latter testing due to landscape sensitivity and a form of development that would be harmful to the LVRP.

The site was reassessed by the Council with a much reduced red line area as informed by Masterplanning which took great care to limit development to a single field parcel to minimise landscape impact and to significantly improve the setting of the LVRP by donating a large area of the site as public open space / new habitat / recreational area etc. I know this Masterplan has been taken into account as part of the updated Site Selection evidence base as the proforma, as an example, reads “proposed site layout provided by promoter accounts for this constraint and the affected areas are not proposed for development (open space)” in respect of flood risk.

What I cannot find is the landscape assessment work that has informed the landscape and LVRP setting conclusions contained on the proforma.

If you could assist.

Kind regards,

John Richards Associate Director, Planning MRTPI

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From: Alison Blom‐Cooper [mailto:[email protected]] Sent: 26 March 2018 10:27 To: John Richards Cc: LDFconsult ; David Coleman Subject: RE: Land at Temple Farm, Roydon

Dear Mr Richards,

David Coleman is currently away on leave so I am replying on his behalf.

As the Overview table you have copied into your email below shows, the site fell out of the site selection process at Stage 6.3: Identifying Sites for Further Testing. Therefore it was not subject to a more detailed capacity assessment or the deliverability assessment.

The Stage 2 suitability assessment of this site SR‐0303‐N against each of the suitability criteria is found on page B573 of Appendix B1.4.2 Results of Stage 2 and 6.2 Assessment. Please follow the link below to download the document. http://www.efdclocalplan.org/wp‐content/uploads/2018/03/EB805Fiii‐Appendix‐B1.4.2‐Results‐of‐Stage‐2‐and‐ Stage‐6.2‐Assessment‐Part‐3.pdf

Stage 6.3 provides the conclusion on site suitability and the justification for both the site SR‐0303‐N and the eastern expansion Strategic Option. The detailed write‐up for Roydon is found at pages B767 to B769 of Appendix B1.5.2 Identifying Sites for Further Testing. Please follow the link below to download the document. http://www.efdclocalplan.org/wp‐content/uploads/2018/03/EB805I‐Appendix‐B1.5.2‐Results‐of‐identifying‐sites‐ for‐Further‐Testing.pdf

Hope this helps.

Best

Alison

Alison Blom-Cooper

Interim Assistant Director | Planning Policy | 01992 564066 Epping Forest District Council | Civic Offices | 323 High Street | Epping | Essex | CM16 4BZ

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From: LDFconsult Sent: 23 March 2018 11:48 To: Alison Blom-Cooper Cc: David Coleman Subject: FW: Land at Temple Farm, Roydon Importance: High

From: John Richards [mailto:[email protected]] Sent: 23 March 2018 11:35 To: David Coleman Cc: LDFconsult; Rachel Allwood Subject: RE: Land at Temple Farm, Roydon Importance: High

Morning David,

I note that the appendices to the Site Selection Report have now been published.

Notwithstanding the JR challenge pending, I would be grateful if you could assist me on a couple of points for Temple Farm being ref. SR‐0303‐N. I understand from the summary table (below) that it was excluded at Stage 3 / 6.3 on landscape grounds including the setting of the LVRP. However, unless I’m looking at the wrong report, I can’t find it referenced in ‘B1.6.4 Results of Stage 3/6.3 Capacity and Stage 4/6.4 Deliverability Assessments’. Could you please confirm for me where I can find the landscape reassessment work undertaken for site SR‐0303‐N.

Thank you in advance.

John Richards Associate Director, Planning MRTPI

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6 From: David Coleman [mailto:[email protected]] Sent: 15 January 2018 18:11 To: John Richards Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

John

The evidence base provides justification as to why the Local Plan provides the most appropriate strategy when considered against reasonable alternatives. A detailed explanation and justification for why individual sites, including land at Temple Farm, have not been included in the Local Plan is not set out within the evidence base. National planning policy and the regulations do not require the Council to publish this information, but as outlined below, the Council will be publishing further information on discounted sites prior to Submission in the interests of transparency and best practice.

In addition, please note the following four further points:  Firstly, the statutory requirement is "publication" not consultation;  Secondly, the purpose of publication is to allow Regulation 20 representations to be made about the Local Plan Submission Version — not the version of a plan land owners/promoters would prefer;  Thirdly, Regulation 20 representations primarily should address soundness, legal compliance and the duty to co‐operate — the three matters to be considered by the inspector appointed to examine the Local Plan under section 20 of the 2004 Act; and  Finally, your concerns relate to soundness only (as per your email below from 10 January) — the reasons why the site has been discounted do not go to soundness.

I trust that this is clear, and taken together with my earlier responses, I trust that this fully and comprehensively answers your questions.

Kind regards David

From: John Richards [mailto:[email protected]] Sent: Monday, January 15, 2018 16:17 To: David Coleman Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

David,

I’m sorry to press on this point but I’m going to ask a very simple question – reviewing the evidence base to the Local Plan currently available can I or can I not determine why land at Temple Farm has been excluded from consideration as a potential strategic site. If so, can you please let me know where?

At the present time, as I understand it, I simply cannot determine why the Council has excluded the site from consideration which I think is a fairly fundamental aspect of your statutory obligation to consult.

Kind regards,

John Richards Associate Director, Planning MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 15 January 2018 14:30 To: John Richards Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Dear John

Apologies for the slight delay in responding to you.

Addressing each of your comments concerning soundness in turn:

I. Whilst we understand the difficulties you have identified arising from the unavailability of some of the appendices to the Site Selection Report, we do not agree that their unavailability at this stage makes it impossible to submit informed representations to the Plan. The information currently available concerning the sites allocated in the Local Plan Submission Version is sufficient to allow any disappointed party promoting non‐allocated sites to make representations as to the comparative merits of allocating the promoted site.

II. As the Site Selection Report makes clear, we are in the process of finalising the detailed write‐up of the appendices. For the avoidance of doubt, the Council does not concede that the said additional site assessment work has not been completed. The delay in the publication of the appendices is due to the time it takes to generate the pro forma for each site, including the mapping for each site, all of which must be checked for accuracy before publication. The Council specifically denies that we have not completed our assessment of all sites, or that the Local Plan Submission Version cannot be considered 'justified' within the meaning of soundness as defined within paragraph 182 of the Framework.

III. It is no secret that a key driver for the publication of the Local Plan Submission Version is to ensure that the Council can submit the document to the Secretary of State for Independent Examination before 31 March 2018. As you know, that is a product of the Secretary of State's indicated change in policy regarding the standardised methodology for objectively assessed need for housing in September 2017. Whilst the decision to amend the Council's Local Development Scheme has truncated the period available to prepare the Local Plan Submission Version, we specifically deny that the decision has compromised the Council's ability to objectively assess new and amended sites. Moreover, in all the circumstances, the Council considers the suite of evidence base documents available to be adequate and sufficient to enable those wishing to make Regulation 20 representations to do so.

For these reasons and those set out in our previous correspondence, the Council will not accede to your request to publish the additional site selection work this week, nor extend the Regulation 19 publication period by a minimum of two weeks, or otherwise.

The remaining appendices to the Site Selection Report will be made available to the Council prior to the Submission of the Local Plan. Unfortunately, given the very limited time available to prepare the submission documents, extending the Regulation 19 publication period will not be possible.

We accept that this situation is not ideal but we do not consider that you, or any other interested party, cannot make valid or meaningful Regulation 20 representations, or that you, or any other interested party will be prejudiced in the conduct of the independent examination of the Local Plan. 8

For the avoidance of doubt, the Council will work with the Planning Inspector appointed to examine the Local Plan Submission Version to ensure disappointed promoters of the non‐allocated sites are afforded a proper opportunity to make such representations as the Inspector considers reasonable in the circumstances.

Kind regards David

David Coleman

Planning Policy Manager | Planning Policy | 01992 564517 Epping Forest District Council | Civic Offices | 323 High Street | Epping | Essex | CM16 4BZ

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From: John Richards [mailto:[email protected]] Sent: Friday, January 12, 2018 09:08 To: LDFconsult Cc: David Coleman Subject: RE: Land at Temple Farm, Roydon Importance: High

Dear Sir / Madam,

Please can you come back to me on this.

The simple point is that we need to know why site ref. SR‐0303‐N has not be chosen for allocation ahead of those set out in your current draft Plan. As the site specific assessment work presumably informed your revised Plan, this should be easily available.

There is just over two weeks until the end of the consultation and would reiterate the point made in my final paragraph below.

Kind regards,

John Richards Associate Director, Planning MRTPI

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9 From: John Richards Sent: 10 January 2018 14:58 To: LDFconsult Cc: David Coleman Subject: RE: Land at Temple Farm, Roydon Importance: High

Dear Sir / Madam,

Thank you for your response.

In your first paragraph you clearly state “all of the evidence used by the Council to formulate the Plan is available from the Council’s website”.

You then go on in your second paragraph to concede that the site assessment evidence base for those new and amended sites which were considered by the Council between 18th May 2016 and 31st March 2017, including Temple Farm ref. SR‐0303‐N, is not currently available, with “the Council currently finalising the detailed write‐up of the site selection appendices to the Report on Site Selection (2017)”. Given that the site was originally incorrectly assessed by the Council, with an apology provided by the Council in recognition of this dated 14th November 2016 (see attached), it is incredibly frustrating and disappointing that the Local Plan is being consulted upon without a full site selection evidence base.

There are a number of clear soundness issues here:

(i) Whilst one is able to understand the site selection methodology and general approach, it is currently impossible to understand why the Council has rejected or chosen individual sites for development because the detailed site selection proforma is not available. This makes it impossible to submit informed representations to the Plan which assess the soundness of selecting certain sites for development over others applying the methodology set out in your Report on Site Selection; (ii) If you are finalising the detailed write‐up of the appendices and they are not to be available this month, are you conceding that this additional site assessment work has not been completed? This certainly appears to be the case and suggests that your Plan cannot possibly be considered ‘justified’ as you have not completed your assessment of all sites and therefore your proposed spatial strategy and allocations cannot be considered the most appropriate when considered against the alternatives – put simply, you have published your Plan without completing your assessment of all alternatives; (iii) As you have conceded in your 12th October 2017 Report to Cabinet, a key driver for the publication of your Submission Version Local Plan is to ensure you can submit the document to the SoS for examination before 31st March 2018. We are concerned that by amending your previously published LDS to specifically meet this deadline, you have compromised not only the ability to objectively assess new and amended sites, but are not even in a position to be able to publish a full suite of evidence base documents, required to understand the process of site selection, and critical to the community’s and land owners ability to prepare fully considered representations.

I am formally requesting that either the Council publishes the site selection evidence base this week or extends the consultation period by a minimum of two weeks from the date that this evidence base is available. Otherwise you are fundamentally prejudicing and restricting the ability of respondents to understand the Council’s rationale, thought process and methodology underpinning the selection of sites for allocation and the rejection of others.

I look forward to your response.

John Richards Associate Director, Planning MRTPI

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From: LDFconsult [mailto:[email protected]] Sent: 10 January 2018 14:09 To: John Richards Cc: David Coleman Subject: RE: Land at Temple Farm, Roydon

Dear John

Thank you for your email. All of the evidence used by the Council to formulate the Plan is available from the Council’s website. As you will appreciate, the evidence base supporting the Local Plan is and will continue to evolve. I would therefore urge you to submit your representation(s) to the Council during the Publication period based upon the information available, explaining why you consider / do not consider the Local Plan to be sound and / or legally compliant. Your representations will then be considered through the Independent Examination.

All relevant available documents can be found on the Council’s website under the Technical Information page. This includes the two updated site selection methodologies (2017) used to identify residential, employment and traveller sites and the Report on Site Selection (2016) with appendices. The 2016 Report on Site Selection sets out the assessment of all sites promoted to the Council up to 17 May 2016. The Report on Site Selection (2017), which is available to view on the Council’s website, provides an overview of the additional assessment undertaken by the Council in 2017. Any new or amended sites promoted to the Council between 18 May 2016 and 31 March 2017 have also been assessed – this includes your site SR‐0303‐N. The site selection process has now been concluded and the outcomes of this work reflected in the Submission Version of the Local Plan. The Council is currently finalising the detailed write‐up of the site selection appendices to the Report on Site Selection (2017). The Council will make the write‐up of these available as soon as possible but this is unlikely to be before the end of the Publication period. Clearly the write‐up will not change the Submission Version of the Local Plan.

I would suggest referring to the full Sustainability Appraisal which provides further details and justification for the approach taken in the Submission Version of the Plan: http://www.efdclocalplan.org/wp‐content/uploads/2017/12/Sustainability‐and‐Equalities‐Impact‐Appraisal‐ AECOM‐December‐2017‐EB204.pdf

As you are aware the Site Selection report can be found at: http://www.efdclocalplan.org/wp‐content/uploads/2017/12/20171212_Report‐on‐Site‐Selection_Issue‐EB802B.pdf

Kind regards

Planning Policy Officer

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From: John Richards [mailto:[email protected]] Sent: Friday, January 5, 2018 15:36 To: David Coleman Cc: William Marr-Heenan; Nigel Richardson; Nick Smithson Subject: RE: Land at Temple Farm, Roydon Importance: High

David,

Please can you come back to me on this please as time is of the essence.

Hopefully you agree that it is vital for consultees to understand the rationale and justification behind the Council’s site selection process especially when one of your stated aims of the current draft was to reassess sites which had either not been subject to assessment previously or had undergone material changes to the extent of land being promoted.

Could you come back as a priority please, even if just an update as to your enquiries on the matter.

Thank you in advance.

John Richards Associate Director, Planning MRTPI

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From: John Richards Sent: 02 January 2018 16:15 To: 'David Coleman' Cc: William Marr‐Heenan ; Nigel Richardson ; Nick Smithson Subject: RE: Land at Temple Farm, Roydon Importance: High

David,

I am starting to go through the evidence base for the Submission Version Local Plan and particularly Appendix B of the Arup 2017 Site Selection Report which reassessed land at Temple Farm, Roydon. I can’t seem to find Appendix B which is obviously critical to our representations to understand why the Council has not chosen to allocate the site given the representations we made to the previous iteration of the Local Plan including the identification of previous deficiencies regarding assessment.

Could you point me in the right direction please.

12 Thanks.

John Richards Associate Director, Planning MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 21 November 2017 09:48 To: John Richards Cc: William Marr‐Heenan ; Nigel Richardson ; Nick Smithson Subject: RE: Land at Temple Farm, Roydon

Good morning John

The attached letter provides the latest position. The Publication Local Plan will be reported to Council on 14th December. No dates have yet been set for further developer forum meetings.

Kind regards David

From: John Richards [mailto:[email protected]] Sent: Monday, November 20, 2017 14:09 To: David Coleman Cc: William Marr-Heenan; Nigel Richardson; Nick Smithson Subject: RE: Land at Temple Farm, Roydon

David,

I hope you are well and sorry to keep pestering you on this.

I just wondered if you had any further updates on progress with the Local Plan and particularly whether invitations to developer forum meetings have been issued. If they have, and this does not include ourselves, we would appreciate knowing on a without prejudice basis.

Thank you in advance.

John Richards Associate Director, Planning MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 06 September 2017 10:30 To: John Richards Cc: LDFconsult ; William Marr‐Heenan ; Nigel Richardson ; Nick Smithson Subject: RE: Land at Temple Farm, Roydon

Morning John

Site selection work is taking place and will be continuing over the next few months. Further updates on timescales will be provided to Cabinet on 12th October.

No formal decisions on any changes to the Plan will be taken prior to Council approving the Reg 19 Pre‐Submission Plan – currently anticipated to be early next year. However, if through our work it becomes apparent that a particular site is likely to be favourably considered, we would obviously look to extend an invitation to the landowner / promoter at the earliest possible opportunity.

Sorry that I cannot be more definitive at this point in time.

Kind regards David

From: John Richards [mailto:[email protected]] Sent: Tuesday, September 5, 2017 17:09 To: David Coleman Cc: LDFconsult; William Marr-Heenan; Nigel Richardson Subject: RE: Land at Temple Farm, Roydon

David,

Sorry to chase but if you could come back on my emails of 18th and 30th August it would be greatly appreciated.

Thank you in advance.

John Richards Associate Director, Planning MRTPI

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From: John Richards Sent: 30 August 2017 14:36 To: 'David Coleman' Cc: LDFconsult ; William Marr‐Heenan ; Nigel Richardson Subject: RE: Land at Temple Farm, Roydon

David,

I hope you are well.

Following on from my email of 18th August to James, I was just wondering whether you had any update on the site selection timescales for the Local Plan and particularly when you anticipate confirming which sites will benefit from invitations to the developer forum meetings.

Thank you in advance.

John Richards Associate Director, Planning MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 08 May 2017 08:57 To: John Richards Cc: LDFconsult ; William Marr‐Heenan ; Nigel Richardson Subject: RE: Land at Temple Farm, Roydon

Good morning John

Just to confirm that I have received your email and copy of your pre‐app submission in the post. We are busily preparing for the site selection work, the start of which has been delayed slightly be several factors, and the sheer scale of the task of reviewing over 3,000 consultation responses and progressing the other work stream associated with the production of the Local Plan.

I will pass on your pre‐application submission to my colleagues undertaking the site selection process so that these can be considered as appropriate. Your pre‐application submission will of course be overseen by my colleagues in development management, but myself and colleagues in the Council will be involved as required and appropriate in considering and reviewing the submission.

Kind regards David

15 From: John Richards [mailto:[email protected]] Sent: Thursday, May 4, 2017 13:43 To: David Coleman Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon Importance: High

David,

I am just following up on the email I sent you on the 18th April.

As alluded to, we submitted a request for pre‐application advice for land at Temple Farm earlier this week.

Given that we are promoting the development through the Local Plan, with the purpose of pre‐application advice being to ensure that all parts of the Council’s planning department is aware of exactly what is being proposed and the impact this would have upon the various opportunities and challenges associated with the site, including its current Green Belt status, we thought it would be useful if you could attend the meeting from a policy perspective.

I have sent you a WeTransfer link which comprises the pre‐application submission in full and have attached the supporting covering letter and illustrative Masterplan to this email for your information.

I will look forward to hearing from you regarding my earlier query regarding the Local Plan site reassessment process.

Kind regards,

John Richards Associate Director, Planning MRTPI

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From: John Richards Sent: 18 April 2017 16:11 To: 'David Coleman' Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Hi David,

I hope you are well.

I just wondered whether you had any update on the site reassessment work you mentioned would commence during March / April 2017? Any update in respect of process or timescales would be appreciated.

16 I also wanted to let you know that we are intending to submit this week a formal pre‐application advice request for land at Temple Farm, Roydon to ensure that any emerging development proposal is informed from both a planning policy and development management perspective. I will copy you into this pre‐application advice request.

Happy to discuss.

John Richards Associate Director, Planning MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 15 February 2017 17:16 To: John Richards Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Hi John

At present we are still reviewing and analysing all of the responses received. Further work on site selection, including reassessing sites where boundaries need to be altered, will commence in March / April. The further work on site selection will then take several months.

An update report on progress is being provided to cabinet on 9th march.

Kind regards David

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From: John Richards Date: Wednesday, 15 Feb 2017, 1:45 pm To: David Coleman Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Hi David,

I just wondered whether you had any further information on timescales associated with reviewing the representations made to the draft Local Plan and especially the reassessment of land at Temple Farm in response to the incorrect site area being considered.

Any update would be appreciated. John Richards Associate Director, Planning MRTPI

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From: John Richards Sent: 18 January 2017 13:34 To: 'David Coleman' Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Thanks David and noted.

John Richards Senior Planning Manager, MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 16 January 2017 12:44 To: John Richards Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Dear John

Yes that is correct. If the sites proposed for allocation change, then the attendance to the developer forum will change accordingly.

Kind regards David

From: John Richards [mailto:[email protected]] Sent: Friday, January 13, 2017 09:51 To: David Coleman Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Thanks David and understood.

Presumably these Forums are without prejudice to a thorough review of representations received and further site selection work, which for Temple Farm is the first time the site would have been properly assessed. Is the intention then to run additional Forums for potential new / additional allocations within the next iteration of the draft Local Plan? John Richards Senior Planning Manager, MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 12 January 2017 17:32 To: John Richards Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Thanks John. Apologies, but Developer Forum meetings are only including sites proposed for allocation in the Draft Local Plan, which is why you have not received an invitation. However, we will keep in touch with any developments over time, and be in touch if we need to discuss aspects of your site further – particularly as the site selection work progresses.

Kind regards David

From: John Richards [mailto:[email protected]] Sent: Thursday, January 12, 2017 17:21 To: David Coleman Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

Hi David,

Thanks for the response.

Unfortunately we haven’t received an invite to the 24th February Forum so if you could send on the invite and ensure that we are included on the relevant mailing list that would be greatly appreciated.

Obviously if you need any additional information on the site in advance or following, do let us know.

Kind regards, John Richards Senior Planning Manager, MRTPI

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From: David Coleman [mailto:[email protected]] Sent: 12 January 2017 17:16 To: John Richards Cc: LDFconsult Subject: RE: Land at Temple Farm, Roydon

John

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Thank you for your email, and happy new year to you too.

We are not able to hold individual meetings with site promoters at the current time, but rather are encouraging ongoing dialogue through the Developer Forum. Hopefully you have received an invitation to our next meeting on 24th February? Please let me know if not and I will investigate.

That being said, we will be in touch if we do need to meet with you individually to clarify any issues, or discuss any aspects of your site and emerging proposals to inform our plan preparation process.

Kind regards David

David Coleman

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From: John Richards [mailto:[email protected]] Sent: Tuesday, January 10, 2017 15:14 To: David Coleman Cc: LDFconsult Subject: Land at Temple Farm, Roydon

David,

I hope you are well and happy new year.

Following our meeting on 21st November 2016 to discuss the status of land at Temple Farm to the west of Roydon in respect of the emerging Epping Forest DC Local Plan, we were hoping that policy officers would be willing to meet with us and our Masterplanning team to discuss the potential of the site in more detail. You will have received our representations to the emerging Local Plan on 9th December 2016, including Masterplan which is attached.

As well as delivering much needed new homes, we would appreciate the opportunity to talk you through our Green Belt and landscape assessment work which has led to the creation of our Masterplan with the ability to deliver 200‐ 250 new homes with no material harm to Green Belt purposes or landscape impact. This has resulted in the development of a scheme which not only has minimal impact from a Green Belt and landscape perspective, but would proportionally integrate with the existing settlement pattern of Roydon in an inherently sustainable location in close proximity to the village centre and the District’s only mainline railway station. We would also like to discuss the future use, and potential gifting, of a large part of the site to the west which could act as a new gateway into the Lee Valley Park for this part of the District.

I hope that the Council can see the benefit of meeting to discuss the site in more detail and I would be grateful if you could suggest a couple of dates when yourself and policy colleagues may be available.

Kind regards,

John Richards,

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