LAND AT 1-3, COMMON, EPPING

November 2020 On behalf of The Chisenhale-Marsh Estates Company

CONTENTS

1.0 Introduction 1 Overview 1 Application Supporting Documents 1 Structure of this Statement 2

2.0 The Application Site 3 Site and Surrounding Area 3 Planning History 3

3.0 Pre-Application Engagement 5

4.0 The Proposed Development 7 Layout and Scale 7 Appearance and Materials 7 Landscaping and Biodiversity 7

5.0 Planning Policy Assessment 8 The Development Plan 8 National Planning Policy Framework 26

6.0 Application Assessment and Conclusions 30 Principle of Development 30 Design 31 Amenity 31 Heritage 32 Ecology, Trees and Landscaping 32 Access and Connectivity 33 Waste and Recycling Facilities 34 Contaminated Land 34 Flood Risk and Water 35 Sustainability 36 Summary and Conclusions 37

Appendices

Appendix 1: District Council Pre-Application Response dated 20 April 2020 38

Planning Statement

1.0 INTRODUCTION

Overview

1.01 This Planning Statement has been prepared by Carter Jonas LLP on behalf of The Chisenhale-Marsh Estates Company to support a full application for planning permission for the development described below at 1-3 Coopersale Common, Epping:

“Proposed demolition of the existing buildings and the redevelopment of the site to provide six new dwellings, associated gardens and infrastructure”

1.02 The purpose of this Planning Statement is to provide a description of the proposals and an assessment of these against relevant planning policy and other material considerations in order to demonstrate that the application proposals represent sustainable development which should be approved without delay.

Application Supporting Documents

1.03 In addition to this Planning Statement the application submission comprises the following information which is discussed throughout this Statement:

• Completed application forms and certificates • Application plans and drawings including: o Site Location Plan, FYU 8_01A o As Existing Block Plan, FYU 8 E_02C o Floor Plans Survey (Existing), J0006820-20-01 o External Elevations (Existing), J0006820-20-02 o Location and Block Plan (Proposed), FYU 8 P3_01A o Site Plan, FYU 8 P3_02C o Floor Plans, FYU 8 P3_03A o Context Elevations, FYU 8 P3_04B o Context Image, FYU 8 P3_05B o Elevations, FYU 8 P3_06A o Elevations, FYU 8 P3_09 o Sketch Images 1, FYI 8 P3_07B o Sketch Images 2, FYU 8 P3_08B o Landscaping Plan, CSA/4999/100 • Design and Access Statement • Preliminary Ecological Appraisal • Ecological Walkover Survey Report • Bat Survey Report • Reptile Report • Biodiversity Offset Calculations • Donor Site Plan • Phase 1 Desk Study and Preliminary Risk Assessment • Tree Survey, Arboricultural Method Statement & Tree Protection Plan • Heritage Assessment • Condition Survey Report • Flood Risk Assessment

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Structure of this Statement

1.04 For ease of reference this Statement is structed as follows:

• Section 2: The Application Site – provides a description of the site, surrounding area and any relevant planning history. • Section 3: Pre-Application Engagement – sets out the pre-application discussions that have taken place with the local authority prior to the submission of the application. • Section 4: The Proposed Development – provides a description of the proposed development. • Section 5: Planning Policy Context – sets out the planning policy and other material considerations against which the application proposals should be considered. • Section 6: Application Assessment and Conclusions – provides an assessment of the proposals against the requirements of planning policy and other material considerations; assesses the proposals against the dimensions of sustainable development; and draws conclusions regarding the acceptability of the proposals.

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2.0 THE APPLICATION SITE

Site and Surrounding Area

2.01 The site is located to the north of Garnon Mead on the northern edge of village of Coopersale, situated approximately 1km to the east of the Market Town of Epping. The village is within the administrative boundary of Council and within the Parish of Epping.

2.02 The site features a two-storey dwelling that has been sub-divided into two, together with, associated outbuildings, areas of car parking and garden land. The building is vacant.

2.03 The immediate context surrounding the site to the south and west is residential in nature and consists of dwellings predominantly two storey and terraced although there are also a number of semi-detached dwellings. Epping Forest is situated beyond the eastern and northern boundaries of the site; this forms a designated Site of Special Interest (SSSI). The metropolitan Green Belt wraps around the eastern part of the site. The site forms the boundary of the urban area/ village.

2.04 The village of Coopersale hosts a small number of services and facilities including a Cricket Club, Primary School, number of shops and convenience stores, a Church and Social Institute Hall. It is also located in close proximity to Epping, which is accessible by pedestrian footpath links close to the subject site, that is approximately 20 minutes by foot or 5 minutes by bicycle. Epping offers numerous services, facilities, and employment opportunities. The site is highly sustainable in terms of its location and accessibility by public transport to wider locations, including regular bus service to and from Epping, and Roydon and direct access into London via Epping underground station.

2.05 Other notable land uses/ constraints within the vicinity include the Epping-Ongar light railway line, located approximately 10m from the northern boundary of the site. The M11 motorway is located 0.5km to the east and the North Weald Airfield, located approximately 1km to the north east.

2.06 There are no designated heritage assets on the site or within the near vicinity.

2.07 The site is located in Flood Zone 1, with a very low risk of river flooding.

Planning History

2.08 An application for the proposed development for three dwellings on the eastern part of the site that falls outside of the Green Belt was submitted to Epping Forest District Council in November 2019 (reference: EPF/3196/18).

2.09 Officers raised concerns regarding the separation distance between the proposed dwellings and the existing dwellings that were to be retained. Officers were concerned this would result in poor amenity being achieved for future occupiers, particularly with regard to overlooking. As a result, the application proposal was amended in accordance with advice received from officers to proposed one new dwelling along with the retention of the existing dwellings on site.

2.10 The amended application had been signed off with a recommendation for approval on 10 June 2018. However, a Decision Notice has not been issued to date as a result of the need for the Council and Natural to agree mitigation measures to prevent air pollution primarily generated by vehicles damaging the

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health of the trees and heathland habitats within Epping Forest. To date the Decision Notice associated with application reference EPF/3196/18 remains outstanding.

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3.0 PRE-APPLICATION ENGAGEMENT

3.01 A request for pre-application advice was submitted to Epping Forest District Council (EFDC) on 17 December 2019. A pre-application response was received from the Council dated 20 April 2020. A copy of this response can be seen at Appendix 1, but key points are summarised below:

Design

– The Councils historic records show the existing property being on site prior to the latter half of the 19th Century, any proposal which seeks to demolish these homes will need to submit a heritage statement. – Furthermore, when considered the application, the design officer has made the following comments: • The submitted plans are extended boxes and sketch views, therefore would require scaled elevations and a street scene plan to determine acceptability more accurately. • The form and massing of the scheme needs to take cues from the local context. • The proposed buildings are too close to root protection areas of on site and nearby trees. This feature needs to be revised. • The entrance of the site defined by the view of the car park and is dominated by hard standing.

Parking provision

– Policy CP9 of the adopted Local Plan seeks to minimise the need for travel and promote opportunities for sustainable transport modes. The Council consider the provision of 14 car parking is considered excessive. It is therefore recommended that the number of parking spaces be reduced to one per dwelling. The proximity to the SSSI

– The council were concerned the is proposal would result in a net increase in vehicle movements, and therefore a significant effect on air quality as it relates to the Epping Forest SAC cannot be screened out at this point in time. It would also be likely to lead to increased visitor pressure on the SAC given its location within the 3km Zone of Influence.

Natural England’s opinion on the acceptability of the proposal

– “Both Natural England and the Conservators of Epping Forest (the Conservators) strongly challenged the robustness of the HRA in terms of its methodology and conclusions. Given the uniqueness of the Forest, its high-risk status and the professed engagement between these key representors and the Council, the dispute at this stage seems most unfortunate. Nevertheless, I cannot conclude beyond reasonable scientific doubt (as the parties all agree that I must) that the Plan will not adversely affect the integrity of the SAC until steps have been taken towards resolving it”.

Other Considerations

– To consider the impact on trees the council considers that a Tree Survey and Tree Protection Plan should accompany the application.

– Given the site is on previously developed land, the council advises that a contamination Phase 1, Phase 2 and as necessary a Detailed Remediation Scheme.

Conclusions

– The Local Planning Authority concluded that the proposal would not adversely affect the integrity of the Epping Forest Special Area of Conservation, therefore, would support the principle of the proposed development.

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The Amended Scheme

3.02 The proposed development has taken on board all of the advice received from pre-application engagement outlined above. The application is accompanied by a Heritage Assessment, Preliminary Risk Assessment, and suite of Ecological Reports to support the application. These will be discussed further in the report.

3.03 Furthermore, the majority of the trees and vegetation along this boundary will be retained as it forms a significant green boundary to the built-up form of the village. A proposed landscaping scheme will provide new trees and vegetation on the site.

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4.0 THE PROPOSED DEVELOPMENT

4.01 The description of development to which this application relates is as follows:

‘Proposed demolition of the existing buildings and redevelopment of the site to provide six new dwellings associated gardens and infrastructure’.

4.02 A full description of the development proposals is provided below.

Layout and Scale

4.03 The existing buildings on site would be demolished and replaced with six new houses to the western part of the site outside of the Green Belt. The proposed dwellings will be two storeys in height arranged in two blocks, one of four and other two, separated by parking and landscaping. To the front of the proposed dwellings all properties would be provided with one car parking space. To the rear, all of the proposed dwellings would be provided with good sized private gardens. The site has accessible pedestrian and vehicular access to the site via Garnon Mead.

4.04 The proposals have also been designed in order to ensure that there is no unacceptable adverse impact on the amenity of the future occupants. This is achieved by ensuring a separation distance of 20m between the two western properties and four eastern properties. The intervening distance between the proposed properties minimises the potential for adverse impacts in terms of loss of daylight or sunlight.

Appearance and Materials

4.05 The design of the proposed dwellings is to have strong housing front gables and long eaves to the side. The oversailing first floors provide covered entrances and add visual interest to the front elevation.

4.06 The proposed development has been carefully designed reflecting a modern reinterpretation of traditional aesthetic using a simple palette of materials found in the surrounding area.

Landscaping and Biodiversity

4.07 Well-designed hard and soft landscaping will be provided to the front and rear of the proposed dwellings.

4.08 The development will retain the majority of existing trees on site and sought to retain as much of the buffer of vegetation along the southern boundary.

4.09 The overgrown scrub and hedge on the western boundary to the railway embankment will be replaced with a new indigenous hedge to offer visual protection.

4.10 The proposed landscaping will provide a well-suited range of species which are appropriate to the location on the edge of Epping Forest, which will help incorporate the development into its surrounding as well as preserve and enhance existing ecology.

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5.0 PLANNING POLICY ASSESSMENT

5.01 This section identifies the main elements of national and local planning policy and guidance that are relevant to the application proposals. It is not intended to be an exhaustive study for reasons of brevity and proportionality. An assessment of the proposals against these policies and guidance is contained in the subsequent section of this Statement.

The Development Plan

5.02 The Development Plan for Epping Forest comprises the following and each document is considered in turn below:

• Combined Policies of the Epping Forest District Local Plan (1998) and Alterations (2006) • Emerging Epping Forest District Local Plan Submission Version (2017)

Combined Policies of the Epping Forest District Local Plan (1998) and Alterations (2006)

Policy CP1 – Achieving Sustainable Development Objectives

Planning powers and actions will be used to:

(i) avoid, or at least minimise, impacts of development upon the environment, particularly in ways likely to affect future generations. Where negative impacts cannot be avoided, compensatory measures will be required to offset such impacts, taking into account that social and economic activities depend upon the maintenance of a stable and healthy environment for their continuance; (ii) secure the provision of sufficient types and amounts of housing accommodation, and different facilities, to meet the needs of the local population, and to retain and improve land resources to meet the recreational and countryside needs of the metropolitan area; (iii) give effect to the Epping Forest Community Strategy (produced by the Local Strategic Partnership) which is in force at the time; (iv) meet the employment needs of those who are unemployed and secure/achieve a mix of local employment and commercial activities that both meet local needs and reduce the need to travel, and reduce reliance on use of the private car; (v) avoid further commuting, especially where it is dependent upon private car use; (vi) help achieve prudent use of natural resources; and (vii) minimise the use of non-renewable resources, including greenfield land.

Policy CP2 – Protecting the Quality of the Rural and Built Environment

The quality of the rural and built environment will be maintained, conserved and improved by:

(i) sustaining and enhancing the rural environment, including conserving countryside character, in particular its landscape, wildlife and heritage qualities, and protecting countryside for its own sake; (ii) enhancing and managing, by appropriate use, land in the Metropolitan Green Belt and urban fringe; (iii) retaining the best and most versatile land for agriculture; (iv) safeguarding and enhancing the setting, character and townscape of the urban environment; (v) preserving and enhancing the biodiversity and networks of natural habitats of the area, including river and wildlife corridors and other green chains;

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(vi) giving priority to protecting and enhancing areas designated as having intrinsic environmental quality at international, national and strategic levels, in compliance with policy NC1 and PPS9; (vii) managing the demand for water resources and sewerage infrastructure by controlling the location, scale and phasing of development so as to protect environmental and wildlife interests.

Policy CP3 – New Development

In considering planning applications and in allocating land for development, the Council will require the following criteria to be satisfied:

(i) the development can be accommodated within the existing, committed or planned infrastructure capacity of the area (or that sufficient new infrastructure is provided by the new development/developer); (ii) the development is accessible by existing, committed or planned sustainable means of transport; (iii) sequential approaches have been used to ensure that appropriate types of development, redevelopment or intensification of use take place at suitable locations; (iv) the achievement of a more sustainable balance between local jobs and workers; (v) the scale and nature of development is consistent with the principles of sustainability and respects the character and environment of the locality.

The Council may use Planning Obligations to ensure these criteria are satisfied.

Policy CP5 – Sustainable Building

Planning permission may be refused for proposals which the Council believes do not do enough to conserve energy, make the most efficient use of water and other resources, recycle waste or protect environmental features and local amenities. Where possible, proposals for new development, or for the conversion or re-use of sites and buildings should incorporate measures which:

(i) reduce fuel use and greenhouse gas emissions (e.g. heat recovery, passive solar gain, cycle parking/storage, links with footpath and cycle networks to encourage sustainable transport); (ii) minimise overall energy use and input of raw materials (e.g. building form, orientation, thermal mass, fenestration, natural ventilation, landscaping to create shelterbelts, use/reuse of construction materials); (iii) encourage efficient use of water and recycling of waste (e.g. enable use of greywater and collection of rainwater, incorporation of water efficient appliances within the development, provision of facilities and space for waste recycling and composting); (iv) incorporate renewable energy facilities or schemes; (v) adopt methods to protect wildlife habitats, trees and other landscape features during construction and which minimise disturbance to adjoining landowners and local amenities.

The Council may require that proposals for new development, or for the conversion or re-use of sites or buildings, demonstrate in a ‘Sustainability Report’ how various aspects of sustainability (including those in criteria (i) to (v) above) have been taken into account. The report should address the siting, massing, design, orientation and layout of development, and the construction and lifecycle of buildings.

Policy CP6 – Achieving Sustainable Urban Development Patterns

Development and economic growth will be accommodated in a sustainable manner which counters trends to more dispersed patterns of living, employment and travel by:

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(i) giving the emphasis to improving the quality of life in urban areas, making them more attractive places in which to live, work, shop, spend leisure time and invest, and achieving a significant enhancement of the vitality and viability of the urban environment; (ii) concentrating new economic and housing development and redevelopment within urban areas by maximising the use of spare capacity in terms of land, buildings and infrastructure; (iii) applying a sequential approach when considering development proposals so as to give preference to development within urban areas; (iv) giving priority to infrastructure and transport proposals that will facilitate the development and regeneration of urban areas and increase choice of sustainable means of transport; (v) reducing disparities between the economic prospects of different parts of the local plan area; (vi) seeking to achieve a better balance between housing and employment provision within local areas; (vii) promoting mixed use neighbourhood developments; (viii) seeking appropriate recreational provision including access to the countryside.

Policy CP7 – Urban Form and Quality

In line with policies CP6 and ST1, one of the Council’s primary objectives is to make the fullest use of existing urban areas for new development before locations within the Green Belt. In view of this primary objective, the environmental quality of existing urban areas will be maintained and improved as attractive places in which to live, work and visit. Where the existing urban fabric provides for high quality in design and local environment by virtue of its existing character, open land uses and buildings and areas of architectural, historic and archaeological importance, this will be strongly protected and enhanced. New development in all urban areas which results in overdevelopment, unsympathetic change or loss of amenity will not be permitted. Subject to those considerations, existing built-up areas will be used in the most efficient way to accommodate new development by the:

(i) recycling of vacant, derelict, degraded and under-used land to accommodate new development; (ii) re-use of existing buildings by refurbishment, conversions, changes of use and extensions; (iii) re-use of urban sites, which are no longer appropriate to their existing or proposed use in the foreseeable future, for alternative land uses; and (iv) use of higher densities where compatible with the character of the area concerned and urban design controls.

Policy CP8 – Sustainable Economic Development

Provision will be made for economic, commercial and housing development and transport investment which will:

(i) facilitate economic regeneration in areas of relative social deprivation to reduce disparities in economic success across the district; (ii) reflect capacity and result in balanced and sustainable economic and housing growth in urban areas and across the district as appropriate; (iii) within the rural areas, make provision for environmentally and economically sustainable activities and adequate housing to encourage renewal and maintain vitality; (iv) encourage local economic diversity; (v) encourage the development of appropriate high value-added economic activities where this is economically beneficial and environmentally acceptable; (vi) satisfy other plan policies.

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Policy GB2A – Development in the Green Belt

Planning permission will not be granted for the use of land or the construction of new buildings or the change of use or extension of existing buildings in the Green Belt unless it is appropriate in that it is:

(i) for the purposes of agriculture, horticulture, or forestry; or (ii) for the purposes of outdoor participatory sport and recreation or associated essential small-scale buildings; or (iii) for the purposes of a cemetery; or (iv) for other uses which preserve the openness of the Green Belt and which do not conflict with the purposes of including land in the Green Belt; or (v) a dwelling for an agricultural, horticultural or forestry worker in accordance with policy GB17A; or (vi) a replacement for an existing dwelling and in accordance with policy GB15A; or (vii) a limited extension to an existing dwelling that is in accordance with policy GB14A; or (viii) in accordance with another Green Belt policy.

Policy RP4 – Contaminated Land

The Council will not grant planning permission for the development or reuse of land which it considers likely to be contaminated unless:

(i) prior tests are carried out to establish the existence, type and degree of contamination; and (ii) if contamination is found, appropriate methods of treatment and monitoring are agreed with the Council, pollution authorities and water companies; and (iii) the agreed methods of treatment include measures to protect or recreate habitats of nature conservation interest.

Policy U3B – Sustainable Drainage Systems

In consultation with the Environment Agency and, where appropriate, sewerage undertakers, the Council may require developments to include sustainable drainage systems to control the quality or attenuate the rate of surface water run-off. Contributions in the form of commuted sums may be sought in legal agreements to ensure that the drainage systems can be adequately maintained.

Policy U2A – Development in Flood Risk Areas

Development proposals within the Environment Agency’s currently designed Flood Risk Zones will be determined in accordance with a sequential approach as set out in PPG25. This will be, in order of priority: (a) areas with little or no flood risk (b) areas of low to medium risk (c) areas of high risk (d) areas of functional flood plain.

In accordance with this order of priority, the Council will only permit development in areas of functional flood plain if: (i) it involves use of land only, and would not increase flood risk or danger from flood risk; or (ii) it is proven to be essential infrastructure which cannot be located elsewhere. No such development will be allowed if it would cause any negative impacts on any part of the flood regime of the watercourse involved.

Development in high risk areas will only be allowed if:

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(iii) there will be no increased risk of flooding either on site or elsewhere in the floodplain or suitable mitigation measures will be incorporated as part of the scheme; and (iv) the development would not reduce the effectiveness of existing flood defence measures; and (v) there is no suitable alternative site available in the locality which is at a lower risk of flooding; and (vi) there will be no significant adverse effects upon a watercourse, navigable waterway or sewer; or (vii) adequate and appropriate flood-prevention measures to minimise the risk of flooding are incorporated as part of the development. Development in all other flood risk areas will be allowed under this policy, provided that suitable flood minimisation and/or mitigation measures are included as part of the development.

All applications or proposals for development in flood risk areas will be required to be accompanied by a Flood Risk Assessment covering matters (i) to (v) above, to be carried out to the satisfaction of the Council and/or the Environment Agency.

Policy H2A – Previously Developed Land

The re-use of previously developed land will be encouraged when considering residential and mixed use (including residential) development schemes. The Council will seek to deliver at least 70% of all new housing on previously developed sites. A plan, monitor, manage approach will be taken to meet adopted targets.

Policy H3A – Housing Density

New housing developments will achieve a net site density of at least 30 - 50 dwellings per hectare, unless the following factors dictate otherwise:

(i) the size and shape of the site, including any significant heritage, landscape or wildlife features; (ii) the character and density of any surrounding development; (iii) the impact of development on the residential amenity of adjoining dwellings; (iv) where appropriate, the impact of the development on the wider settlement, including long distance views; (v) the need to provide well designed public space and parking facilities; and (vi) good quality design and layout.

Policy H4A – Dwelling Mix

The Council will require that provision is made for a range of dwellings, including an appropriate proportion of smaller dwellings, to meet identified housing need on a site-by-site basis. This mix should be reflected in both market housing and affordable housing. When considering extensions to, conversions or amalgamations of, existing dwellings, needs identified in the latest Housing Needs Survey will be considered to ensure that an adequate mix of dwellings is maintained. The Council may therefore refuse planning permission for extensions to, or conversions of, existing dwellings where the result will adversely affect the range and mix of dwellings available.

Policy DBE1 – Design of New Buildings

The Council will require that new buildings:

(i) respect their setting in terms of scale, proportion, siting, massing, height, orientation, roof-line and detailing; (ii) are of a size and position such that they adopt a significance in the streetscene which is appropriate to their use or function; and (iii) only employ external materials which are sympathetic in colour and texture to the vernacular range of materials.

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Policy DBE2 – Effect on Neighbouring Properties

Planning permission will not be granted for new buildings which have a detrimental effect upon existing neighbouring or surrounding properties in either amenity or functional terms.

Policy DBE3 – Design in Urban Areas

Outside the Green Belt, new development will be required to ensure that:

(i) all spaces between and around buildings are deliberately created to be functional, attractive and safe for their intended users; (ii) spaces are of individual identity and character and are satisfactorily enclosed; (iii) public, private and semi-private spaces are clearly discernible to their intended users; (iv) the informal supervision of public and semi-private spaces around buildings by their occupiers is encouraged; and (v) front elevations face outwards onto public spaces and contain the main entrances.

Policy DBE6 – Car Parking in New Development

The Council will require that car parking for new residential developments is:

(i) conveniently situated for its intended users and adequately lit; and (ii) located such that parked cars do not visually dominate the street scene.

Policy DBE8 – Private Amenity Space

New residential developments will be expected to provide private amenity space. This will usually:

(i) be at the rear of dwellings or flats; (ii) be directly adjacent to and easily accessible from the relevant buildings; (iii) be of a size, shape and nature which enables reasonable use; (iv) have an aspect which ensures that reasonable parts receive sunlight throughout the year; (v) not have an excessive slope in its finished form; and (vi) achieve privacy on a continuing basis.

Policy DBE9 – Loss of Amenity

The Council will require that a change or intensification of use, extension or new development does not result in an excessive loss of amenity for neighbouring properties. The factors which will be taken into account are:

(i) visual impact; (ii) overlooking; (iii) loss of daylight/sunlight; and (iv) noise, smell or other disturbance.

Policy LL11 – Landscaping Schemes

The Council will:

(i) refuse planning permission for any development which makes inadequate provision for landscaping; (ii) not approve landscaping schemes which:

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(a) are inappropriate because they fail to take account of the setting or intended use of the development; or (b) are ineffective because they would be unlikely to retain trees and other existing landscape features or to establish new long-term planting.

Policy ST1 – Location of Development

New development will be located in places that encourage walking, cycling and the use of public transport (including the provision of additional services and infrastructure). The Council expects new development to satisfy the following criteria:

(i) major trip generating uses will be located in the principal centres and be in accordance with the retail hierarchy listed in policy TC1; (ii) facilities used on a day-to-day basis will be located in non key frontage of principal centres or smaller, district and local centres; (iii) housing will principally be located in existing urban areas, and make the best use of land which is, or could be, highly accessible to public transport or close to services and employment opportunities.

In rural areas, for development which has transport implications, preference will be given to locations with access to regular public transport services and containing basic shops and other facilities. Proposals that are not in accordance with this policy and where their location is considered to be unsustainable will be refused.

Legal agreements may be used to secure the provision of new or additional public transport services and facilities.

Policy ST2 – Accessibility of Development

New development must be designed to provide safe, pleasant and convenient access for pedestrians and cyclists, including where appropriate, integrated transport choices and practical links with adjoining public rights of way and cycleway networks. Major developments must be well served by public transport and, if necessary, make provision for enhanced services and infrastructure. Proposals should therefore incorporate the following measures, where relevant:

(i) traffic management to improve safety, give priority to pedestrians, cyclists and public transport over ease of car movements, enable environmental improvements (e.g. town centre enhancement schemes) and to direct heavy goods vehicles onto suitable roads; (ii) secure, convenient and sheltered facilities for cycle and powered two wheeler storage and parking; (iii) more road space and internal networks for sustainable modes of transport; (iv) vehicle parking standards that reflect location in relation to public transport, employment opportunities and town centres and are in accordance with the standards required by policy ST6; (v) design and layout which will reduce the potential for crime and fear of crime; (vi) the provision of suitable and adequate facilities for mobility impaired people entering, exiting and within the site, including appropriately located parking facilities.

The Council may use legal agreements to achieve some of these measures, especially if they involve operations outside the application site.

Policy ST4 – Road Safety

The Council will grant planning permission for new development only when the proposal either:

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(i) is well related to the road hierarchy; (ii) is unlikely to lead to an excessive degree of traffic congestion; (iii) will not be detrimental to highway safety; and (iv) is not likely to result in excessive adverse effects, from traffic generation, on the character or environment of any part of the area through which the new traffic will move;

or when satisfactory mitigation measures will be adopted to address any potential adverse road safety implications.

In the interests of highway safety, the Council may use legal agreements to ensure that alterations to the public highway are completed, in some cases, before a scheme is commenced, and in other cases before a development is occupied or used.

Policy ST6 – Vehicle Parking

The Council will expect all development proposals to provide on-site parking in accordance with the Adopted 2001 Standards or its successor documents.

Emerging Epping Forest District Local Plan Submission Version (2017)

5.03 The Epping Forest District Local Plan Submission Version (2017) was submitted to the Secretary of State for Examination on 21 September 2018. Hearing sessions took place through February, March, May and June 2019. In August 2019 the Inspector issued her Interim Findings. These highlighted that further work was required on a number of areas of the Plan, particularly with regard to the Epping Forest Special Area of Conservation.

5.04 Given that the Plan has now been through a number of Hearing Sessions it is considered that moderate weight can be given to those policies which the Inspector has not raised queries with regard to in the interim findings.

Policy SP 1 Presumption in favour of sustainable development

A. The Council will take a positive approach to the consideration of development proposals, reflecting the presumption in favour of sustainable development contained in the National Planning Policy Framework. The Council will work proactively with applicants to find solutions for development proposals that help to improve the economic, social and environmental condition in the District.

B. Proposals which accord with the development plan will be approved. Proposals that do not accord with the development plan will be refused, unless material considerations indicate otherwise. When taking decisions, the Council will apply the presumption in favour of sustainable development within national planning policy.

Policy SP 2 Spatial Development Strategy 2011-2033

A. Within the period 2011-2033 the Local Plan will provide for a minimum of 11,400 new homes allocated in accordance with the following sequential approach:

(i) The creation of Garden Town Communities around Harlow recognising its strategic economic role and needs; (ii) A sequential flood risk assessment – proposing land in Flood Zone 2 and 3 only where need cannot be met in Flood Zone 1; (iii) Sites located on previously developed land within settlements;

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(iv) Sites located on open space within settlements where such selection would maintain adequate open space provision within the settlement; (v) Previously developed land within the Green Belt; (vi) Greenfield/Green Belt land on the edge of settlements: - Of least value to the Green Belt if the land meets other suitable criteria for development. - Of greater value to the Green Belt if the land meets other suitable criteria for development. - Of most value to the Green Belt if the land meets other suitable criteria for development. (vii) Agricultural land: - Of Grade 4-5 if the land meets other suitable criteria for development. - Of Grade 1-3 if the land meets other suitable criteria for development. (viii) Enable small scale sites in smaller rural communities to come forward where there is a clear local need which supports the social and economic well-being of that community.

B. The new homes will be distributed as follows:

Settlement Allocated Housing Coopersale, Fyfield, , , ~ 175 Sheering and Stapleford Abbots

C. The new homes will be delivered by: (i) permitting development proposals within the defined settlement boundaries where they comply with all other relevant policies of the Local Plan; (ii) the development of Garden Town Communities around Harlow and at other settlements as allocated through this Local Plan (as identified in Policy SP 5 and Chapter 5); (iii) Permitting rural exception sites in accordance with Policy H 3 and all other relevant policies of the Local Plan; (iv) the delivery of sites identified in made Neighbourhood Plans; (v) making the best use of land by ensuring that development densities are appropriate to the location and size of the site in accordance with Policy SP 3; and (vi) resisting developments which would result in a net loss of homes, unless it can be demonstrated that the benefits of doing so will materially outweigh the harm.

Policy SP 3 Place Shaping

H. Strategic Masterplans and development proposals must reflect and demonstrate that the following place shaping principles have been adhered to with respect to the scale of development proposed: (i) strong vision, leadership and community engagement; (ii) provide for the long-term stewardship of assets; (iii) provide mixed-tenure homes and a range of housing types and sizes; (iv) ensure a robust range of employment opportunities with a variety of jobs within easy commuting distance of homes; (v) provide high quality and imaginatively designed homes with gardens or access to usable and accessible amenity space, combining the very best of urban and rural living to promote healthy and active lifestyles and vibrant communities; (vi) ensure generous, well connected and biodiverse rich green space provision; (vii) extend, enhance and reinforce strategic green infrastructure and public open space; (viii)ensure that development enhances the natural environment; (ix) deliver strong local cultural, recreational, social (including health and educational where required) and shopping facilities to support day-to-day needs in walkable neighbourhoods; (x) ensure positive integration and connection with adjacent rural and urban communities thereby contributing to the revitalisation of existing neighbourhoods;

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(xi) maintain and enhance the important features, character and assets of existing settlements; (xii) conserve and positively enhance key landscapes, habitats and biodiversity; (xiii)provide for sustainable movement and access to local and strategic destinations (including rail, bus and pedestrians/cycling); and (xiv)positively respond to sustainable water management.

I. To ensure the best and most efficient use of land as a guide the Council will normally expect: (i) a greater density of development at places with good public transport accessibility; (ii) densities above 50 dwellings per hectare in towns and large village centres, and along main transport routes and/or close to transport nodes; (iii) in the areas outside town and large village centres, new residential development should achieve densities of between 30 and 50 dwellings per hectare, and should enhance the distinctive character and identity of the area; (iv) lower density developments may be appropriate in other areas of the District. Some parts of the urban areas and some villages are particularly sensitive to the impact of intensification and redevelopment because of the prevailing character of the area and the sensitive nature of the surrounding countryside or built form.

Policy H 1 Housing Mix and Accommodation Types

A. Development will be permitted where the mix of new homes: (i) includes a range of house types and sizes to address local need including for ‘down-sizing’; (ii) is appropriate to the size, location and characteristics of the site and its surroundings; (iii) takes into account the existing housing stock in the settlement or neighbourhood in order to avoid any over-concentration of a single type or size of homes, or specialist accommodation, where this would undermine the achievement of mixed and balanced communities; and (iv) allows for community-led approaches such as co-housing and co-operatives where appropriate; (v) provides for all new homes to be accessible and adaptable as defined by the Building Regulations in effect at the time of the application.

B. Planning applications will be required to be supported by evidence, proportionate to the nature and scale of development proposed, to justify the mix of new homes to be provided. Such evidence will also need to reflect latest housing needs evidence published by the Council.

C. Proposals for housing, requiring specialist accommodation, self-build/custom build housing, sites upon which caravans can be stationed, or locations for mooring houseboats, will be supported where: (i) they meet a proven identified need; (ii) the location is appropriate in terms of access to facilities, services and public transport and; (iii) It can be demonstrated that the development is designed and managed to provide the most appropriate types and levels of support to the proposed occupier and adequately caters for the needs of support staff.

D. The Council will require all New Housing Development to include affordable housing in accordance with Policy H 2 (Affordable Housing).

E. Where there is evidence of an identified unmet need in the local area and the location is appropriate in terms of access to existing or proposed facilities, services and public transport, larger scale new residential developments should incorporate specially designed housing/specialist accommodation for people with support needs (including for older people and housing with care).

F. The loss of bungalows and specialist accommodation will be resisted.

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G. The Council will support the development of self-build homes on appropriately sized, serviced sites in the first instance or on appropriately sized sites that are capable of being serviced. The provision of such will be encouraged as part of larger development schemes.

Policy T 1 Sustainable Transport Choices

A. The Council will work in partnership with relevant stakeholders to promote a safe, efficient and convenient transport system which will: (i) build on the District’s strategic location, through improvements to strategic road and rail connections and other public transport networks to the wider area; (ii) promote transport choice, through improvements to public transport services and supporting infrastructure, and providing coherent and direct cycling and walking networks to provide a genuine alternative to the car and facilitate a modal shift; (iii) provide opportunities to improve access to the two Town and four Small District Centres and rail stations by all modes of transport and ensure good integration between transport modes; (iv) manage congestion, seek to reduce journey time and maintain consistency in journey times; (v) promote and improve safety, security and healthy lifestyles; and (vi) improve the efficiency of the local highway network.

B. Development should minimise the need to travel, promote opportunities for sustainable transport modes, improve accessibility to services and support the transition to a low carbon future.

C. Development proposals will be permitted where they: (i) integrate into existing transport networks; (ii) provide safe, suitable and convenient access for all potential users; (iii) provide on-site layouts that are compatible for all potential users with appropriate parking and servicing provision; and (iv) do not result in unacceptable increases in traffic generation or compromise highway safety.

D. Development proposals that generate significant amounts of movement must be supported by a Transport Statement or Transport Assessment and will normally be required to provide a Travel Plan. Development proposals which generate a significant number of heavy goods vehicle movements will be required to demonstrate by way of a Routing Management Plan that no severe impacts are caused to the efficient and safe operation of the road network and no material harm caused to the living conditions of residents.

E. Development will, where appropriate, ensure that transport infrastructure will be of a high quality, sustainable in design, construction and layout, and offer maximum flexibility in the choice of travel modes, including walking and cycling, and with accessibility for all potential users.

F. Development will be permitted where it: (i) does not result in cumulative severe impact on the operation and safety of, or accessibility to, the local or strategic highway networks; (ii) mitigates impacts on the local or strategic highway networks and London Underground station infrastructure within the District, arising from the development itself or the cumulative effects of development, through the provision of, or contributions towards, necessary transport improvements, including those secured by legal agreement, subject to viability considerations; (iii) protects and, where appropriate, enhances access to Public Rights of Way; (iv) provides appropriate parking provision, in terms of amount, design and layout and cycle storage arrangements, in accordance with adopted Parking Standards and which mitigates any impact on on-street parking provision within the locality. Reduced car parking, including car free, development in sustainable locations will be supported; and

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(v) ensures that, where appropriate, development proposals provide a coordinated and comprehensive scheme that does not prejudice the future provision of transport infrastructure on and through adjoining sites.

G. In order to accommodate the use of low emission vehicles to support improvements in air quality within the District the provision of electric vehicle charging points will be required within all new developments which make provision for car parking for vehicles.

Policy DM 1 Habitat Protection and Improving Biodiversity

A. All development should seek to deliver net biodiversity gain in addition to protecting existing habitat and species. Development proposals should seek to integrate biodiversity through their design and layout, including, where appropriate, through the provision of connections between physical and functional networks.

B. Development proposals must protect and enhance natural habitats, areas and corridors for biodiversity and should not negatively impact upon areas of international or national designation. The creation of new corridors for biodiversity will be supported in appropriate locations. The provision of buffers to protect sensitive habitats including those of wetlands and ponds will be required where necessary.

C. Development proposals which are likely to have a negative impact on a locally designated site (Local Wildlife Site and Local Nature Reserve) will only be permitted where the benefits of the proposed development clearly outweigh the value of the ecological feature adversely affected and there are no appropriate alternatives.

D. In exceptional circumstances where the negative impacts of development on natural habitat and biodiversity are unavoidable, the negative impacts must be proportionately addressed in accordance with the hierarchy of: (i) mitigation; (ii) compensation in the form of habitat; and finally (iii) offsetting within the locality.

E. The details of any necessary enhancing, mitigating or compensatory measures should accompany the planning application as appropriate. When appropriate, conditions will be put in place to require that monitoring is undertaken (by a suitably qualified ecological professional), and to make sure that any mitigation, compensation and offsetting is effective.

F. The loss, deterioration or fragmentation of irreplaceable habitats, such as veteran trees and ancient woodland, will not be permitted by the Council, unless the need for, and benefits of, the development in that location can be demonstrated to clearly outweigh the loss.

G. Where there are grounds to believe that a Protected Species, Priority Species, Priority Habitat or other valuable habitat may be affected by proposed development, applicants must provide a full survey and site assessment to establish the extent of potential impact. This evidence should inform appropriately designed plans and mitigation measures.

H. Ecological impacts of a proposed development will be quantified by using the Biodiversity Impact Assessment Calculator (BIAC) where appropriate. Development proposals must demonstrate a net gain in ecological units.

I. Ecological information must be supplied in accordance with BS 42020 2013 for all relevant planning applications.

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Policy DM 4 Green Belt

A. The purposes of the Green Belt are to: (i) Check the unrestricted sprawl of large built up areas; (ii) Prevent neighbouring towns from merging into one another; (iii) Safeguard the countryside from encroachment; (iv) Preserve the setting and special character of Within the Green Belt planning permission will not be grantec for inappropriate development, except in very special circumstances, in accordance with national policy.

B. Within the Green Belt planning permission will not be granted for inappropriate development, except in very special circumstances, in accordance with national policy.

C. The construction of new buildings is inappropriate development in the Green Belt. Exceptions this are: (i) Buildings for the purposes of agriculture and forestry; (ii) Provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as any development preserves the openness of the Green Belt and does not conflict with the purpose of including land within it; (iii) The extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; (iv) The replacement of a building, provided the building is of the same use and not materially larger than the one it replaces; (v) Limited infilling in smaller settlements and limited affordable housing related to smaller settlements, in accordance with Policy H 3; and (vi) Limited infilling or the partial or complete redevelopment of previously developed land, which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.

Policy DM 9 High Quality Design

A. All new development must achieve a high specification of design and contribute to the distinctive character and amenity of the local area. The Council will require all development proposals to be design-led and: (i) relate positively to their context; (ii) make a positive contribution to a place; (iii) where appropriate, incorporate sustainable design and construction principles that consider adaptation and mitigation approaches to address climate change; (iv) are planned, where appropriate, to minimise vulnerability to climate change impacts and which will not exacerbate vulnerability in other areas; and (v) incorporate design measures to reduce social exclusion, the risk of crime, and the fear of crime.

Design Standards

D. Development proposals must relate positively to their locality, having regard to: (i) building heights; (ii) the form, scale and massing prevailing around the site; (iii) the framework of routes and spaces connecting locally and more widely; (iv) the rhythm of any neighbouring or local regular plot and building widths and, where appropriate, following existing building lines; (v) the need to provide active frontages to the public realm; and (vi) distinctive local architectural styles, detailing and materials.

Landscaping

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E. Development proposals must demonstrate how the landscaping and planting has been integrated into the development as a whole. The Council will expect development proposals to respond to: (i) levels, slopes and fall in the ground; (ii) trees on and close to the site; (iii) natural boundary features; (iv) the biodiversity of the site and its surroundings; and (v) the need to maximise the use of permeable surfaces.

Public Realm

F. Where appropriate development proposals must contribute positively to the public realm and to public spaces to which it is physically or functionally connected.

Connectivity and Permeability

G. Where appropriate, development proposals must maximise connectivity within, and through, the development and to the surrounding areas including the provision of high quality and safe pedestrian and cycle routes.

Privacy and Amenity

H. Development proposals must take account of the privacy and amenity of the development’s users and neighbours. The Council will expect proposals to: (i) provide adequate sunlight, daylight and open aspects to all parts of the development and adjacent buildings and land (including any private amenity) space; (ii) avoid overlooking and loss of privacy detrimental to the living conditions of neighbouring residents and the residents of the proposed development; (iii) not result in an over-bearing or overly enclosed form of development which materially impacts on either the outlook of occupiers of neighbouring properties or the residents of the proposed development; and (iv) address issues of vibration, noise, fumes, odour, light pollution, air quality and microclimatic conditions likely to arise from any use or activities as a result of the development or from neighbouring uses or activities.

I. All development proposals must demonstrate that they are in general conformity with the design principles set out in other relevant Local Development Documents, Design Guides, Neighbourhood Plans or Village Design Statements (VDSs) adopted or endorsed by the Council.

Policy DM 10 Housing Design and Quality

A. All new housing development is required to meet or exceed the minimum internal space standards set out in National Prescribed Space Standards and open space standards.

B. Ground floor family housing must provide access to private garden/amenity space, and family housing on upper floors should have access to a balcony and/or terrace, subject to acceptable amenity, privacy and design considerations, or to shared communal amenity space and children’s play space.

C. Where appropriate development proposals should seek to include enhanced provision of green infrastructure, including the quantity and quality of landscaped areas, tree provision and the provision of additional open space as required by Policy DM 5 and DM 6.

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D. Mixed tenure residential development proposals must be designed to be ‘tenure blind’ to ensure homes across tenures are indistinguishable from one another in terms of quality of design, space standards and building materials.

Policy DM 11 Waste Recycling Facilities in New Development

A. All development which generates waste will be required to make on-site provision for general waste, the separation of recyclable materials and organic material for composting. The on-site provision must: (i) ensure adequate dedicated internal and external storage space to manage the volume of waste arising from the site; (ii) provide accessible and safe access to on-site storage facilities, both for occupiers and collection operatives including vehicles; and (iii) be located and screened to avoid nuisance and adverse impact on visual and other amenity to occupiers and neighbouring uses; and for mixed use development, suitably separate household and commercial waste.

Policy DM 15 Managing and Reducing Flood Risk

A. The Council will require all development proposals to demonstrate that they avoid and reduce the risk of all forms of flooding to future occupants and do not increase the risk of flooding elsewhere;

B. The Local Plan allocations are directed towards Flood Zone 1 or to areas with the lowest probability of flooding. Any proposals for new development (except water compatible uses) within Flood Zone 2 and 3a will be required to provide sufficient evidence for the Council to assess whether the requirements of the Sequential Test and Exception Test, have been satisfied.

C. Proposals within Flood Zones 2 and 3a must be informed by a site specific Flood Risk Assessment (FRA) taking account of all potential sources of flooding and climate change allowances and should: (i) demonstrate the application of a sequential approach for the development of individual sites to ensure that the highest vulnerability of land uses are located in areas of the site that are at lowest risk of flooding; (ii) preserve overland flood and flow routes and ensure there is no net loss of flood storage; (iii) ensure that there is no adverse effect on the operational functions of any existing flood defence infrastructure; (iv) provide adequate flood storage and compensation on site; (v) where appropriate, set out the mitigation measures that will be incorporated on site to manage residual flood risk including finished floor levels to accord with Environment Agency’s Standing Advice; and (vi) naturalise water courses where opportunities arise, in line with Policy DM 17 (Watercourses and Flood Defences).

D. All proposals for new development will be required to: (i) manage and reduce surface water run-off, in line with Policy DM 16 (Sustainable Drainage Systems); (ii) manage water and waste water discharges, in line with Policy DM 18 (On-site Management of Waste Water and Water Supply); (iii) ensure safe access and egress for future users of the development and an appropriate emergency evacuation plan where appropriate; and (iv) include measures to assist existing communities at risk of flooding where feasible.

E. All proposals for development within a Critical Drainage Area (CDA) or an EFDC Flood Risk Assessment Zone (FRAZ) will be required to provide a site specific flood risk assessment consisting of: an assessment of the risks involved, focussing predominantly on surface water and ordinary watercourses; details of any mitigation measures on-site where required (e.g. increased thresholds); and a drainage strategy incorporating the use of SuDS (Policy DM 16) to mitigate any impacts of site.

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F. With the exception of water compatible uses and essential infrastructure, subject to passing the Exception Test, development in areas designated in Epping Forest District’s Strategic Flood Risk Assessment or as determined by specific Flood Risk Assessment as being within Flood Zone 3b will not be permitted.

G. Proposals for developments within identified Critical Drainage Areas could, based on the outcome of the site specific flood risk assessment, be subject to a section 106 contribution or CIL funding for the delivery of appropriate flood alleviation schemes.

Policy DM 16 Sustainable Drainage Systems

A. All proposals for new development must seek to manage surface water as close to its source as possible in line with the following drainage hierarchy: (i) store rainwater for later use; (ii) use infiltration techniques, such as porous surfaces in non-clay areas. Porous surfaces are suitable in areas of clay but must be adequately tanked with an outfall. Epping Forest District is predominantly clay so any infiltration proposals must be subject to and pass the relevant percolation tests; (iii) attenuate rainwater in ponds or open water features for controlled release; (iv) attenuate rainwater by storing in tanks or sealed water features for controlled release.

B. Other methods must also reflect the stringent drainage hierarchy contained within the current CIRIA1 SuDS Manual (2015), which provides further detailed guidance over and above Building Regulations: (i) controlled discharge of rainwater direct to a watercourse/surface water body; (ii) controlled discharge rainwater to a surface water sewer/drain; (iii) controlled discharge rainwater to the combined sewer.

C. The Council will encourage the use of green, brown and blue roofs.

D. The Council will require Sustainable Drainage Systems (SuDS) to be sensitively incorporated into new development by way of site layout and design, having regard to the following requirements: (i) all major development proposals will be required to reduce surface water flows to the 1 in 1 greenfield run- off rate and provide storage for all events up to and including the 1 in 100 year critical storm event including an allowance for climate change, and include at least one source control SuDS measure resulting in a net improvement in water quantity and quality discharging to a sewer; (ii) all brownfield development proposals should aim to achieve the 1 in 1 greenfield run-off rate and, at a minimum, achieve a 50 per cent reduction in existing site run-off rates for all events, including an allowance for climate change, SuDS measures resulting in a net improvement in water quantity and quality discharging to a sewer; (iii) all ‘minor’ and ‘other’ development proposals should aim to achieve the 1 in 1 greenfield run off rate where possible, including an allowance for climate change, or a rate as otherwise agreed with the Council; and (iv) for all development where the greenfield runoff rate cannot be achieved, justification must be provided to demonstrate that the run-off rate has been reduced as much as possible.

E. Where Sustainable Drainage Systems are implemented they will be expected to: (i) meet the requirements set out in national standards, and meet the Council’s standards if they exceed national guidance; (ii) incorporate measures identified in Surface Water Management Plans; (iii) be designed to maximise biodiversity and local amenity benefits and where appropriate, ensure that SuDS techniques provide for clean and safe water at the surface; (iv) improve water quality; and

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(v) full details of the means of achieving future management and maintenance of the SuDS scheme to ensure that it will function effectively over the lifespan of the development will be required, including responsibilities and funding.

F. The Council will give consideration to adopting SuDS. Contributions in the form of commuted sums or CIL will be sought for maintenance if adopted by the Council.

G. Where SuDS cannot be implemented due to site constraints (such as land contamination) robust justification must be provided along with proposed alternative approaches to surface water management.

H. Where particular sites and the wider catchment have identified existing flood issues, the implementation of good practice on Natural Flood Management must be explored.

Policy DM 18 On Site Management and Reuse of Wastewater and Water Supply

A. The Council will expect planning applications to set out how they will ensure that there is adequate surface water, foul drainage and treatment capacity to serve their development and demonstrate that it does not impact on the adequacy of existing development in this regard. All proposals for new development will be required to: (i) ensure the separation of surface and foul water systems; and (ii) implement sustainable drainage systems, in line with Policy DM 16.

B. Where the local public sewer network does not have adequate capacity to serve the existing and proposed development, proposals will be required to demonstrate that it provides for suitable alternative arrangements for storing, treating and discharging foul water. Should there be capacity issues resulting from development that can be addressed through upgrades of the sewerage network, developers will are required to demonstrate how these will be delivered in advance of the occupation of development.

C. The Council will expect new development to connect to mains foul drainage, and will restrict the use of non- mains drainage for foul water disposal, particularly in Groundwater Source Protection Zones, in line with Environment Agency guidance. The location of and likely impact on the private water supplies within the District must also be taken into account. Where non-mains drainage is proposed for the disposal of foul water, a foul drainage assessment will be required to ensure the most sustainable drainage option will be implemented.

D. All proposals for new development will be required to: (i) ensure that there is adequate water supply infrastructure capacity both on and off-site to serve the development with wholesome water of sufficient quantity, flow rate and pressure, without adversely impacting on existing users; and (ii) make provision for the installation and management of measures for the efficient use of mains water and where possible with direct connection to the mains public water supply. Please also refer to Policy DM 19.

Policy DM 21 Local Environmental Impacts, Pollution and Land Contamination

A. The Council will require that the residual local environmental impacts of all development proposals after mitigation do not lead to unacceptable impacts on the health, safety, wellbeing and amenity of existing and new users or occupiers of the development site, or the surrounding land. These potential impacts can include, but are not limited to, air and water (surface and groundwater) pollution, dust, noise, vibration, light pollution, odours, and fumes as well as land contamination.

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B. The Council will: (i) resist development that leads to unacceptable local environmental impacts, including, but not limited to, air pollution, noise and vibration, light pollution, odours, dust and land and water contamination; (ii) require that activities likely to generate pollution are located away from sensitive uses and receptors where possible, practical and economically feasible; (iii) require development proposals to mitigate and reduce to a minimum any adverse local environmental impacts and activities that may have wider cumulative effects; (iv) where there are unacceptable risks of contamination or land instability, require these to be properly and fully addressed through remediation. If remediation measures are not suitable then planning permission will be refused; and (v) where necessary, apply planning conditions to reduce local environmental impacts on adjacent land uses to acceptable levels.

Land Contamination

C. The Council will expect the remediation of contaminated land through development. Potential contamination risks will need to be properly considered and adequately mitigated before development proceeds. To deliver this the Council will require development proposals on contaminated land: (i) to be informed by a desktop study and preliminary risk assessment, including an assessment of the site’s history, potential contamination sources, pathways and receptors; (ii) where necessary to undertake a site investigation and detailed risk assessment in line with current best practice guidance, including where appropriate physical investigations, chemical testing and assessments of ground gas risks and risks to groundwater; (iii) where necessary to provide a remediation strategy that sets out how any identified risks from the assessments above are going to be addressed. If remediation measures are not suitable then planning permission will be refused; (iv) where necessary to provide a long term maintenance and monitoring regime for the mitigation of any ongoing risk and identify the person/s responsible for the regime; (v) where necessary to provide a validation report once remediation has taken place, including evidence that demonstrates that risks from contamination have been controlled effectively; and (vi) to ensure that all above assessments and investigations are carried out by a competent person.

Construction and Demolition

D. The Council will seek to manage and limit environmental disturbances during construction and demolition as well as during excavations and construction of subterranean developments. To deliver this the Council requires the submission of Construction Management Statements for the following types of developments: (i) all major developments; (ii) any basement developments; (iii) developments of sites in confined locations or near sensitive receptors; and (iv) if substantial demolition/excavation works are proposed.

E. In addition the Council supports the use of sustainable design and construction techniques, including where appropriate the local or on-site sourcing of building materials enabling reuse and recycling on site.

Epping Town Council Neighbourhood Plan

Epping Town Council is currently preparing their draft Neighbourhood Plan, which covers the town of Epping and surrounding areas including the proposed subject site. Given the application site is not identified on the proposals maps as a proposed allocation for residential development, policy 4 of the draft consultation document does lend support to residential development of up to 5 dwellings on sites which are not identified

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for residential development in policy 3. However, as the draft plan has not yet been adopted, it is to be afforded little weight.

National Planning Policy Framework

5.05 The National Planning Policy Framework (NPPF) (2019) sets out the Government’s planning policies for England and how these should be applied (paragraph 1). Relevant policies of the NPPF are set out below.

Achieving sustainable development 7. The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.

8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure; b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and c) an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

10. So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development (paragraph 11).

11. Plans and decisions should apply a presumption in favour of sustainable development.

For decision-taking this means:

c) approving development proposals that accord with an up-to-date development plan without delay; or d) where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date, granting permission unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

Decision-making

38. Local planning authorities should approach decisions on proposed development in a positive and creative way. They should use the full range of planning tools available, including brownfield registers and permission in principle, and work proactively with applicants to secure developments that will improve the economic,

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social and environmental conditions of the area. Decision-makers at every level should seek to approve applications for sustainable development where possible.

Pre-application engagement and front-loading

39. Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community.

Determining applications

47. Planning law requires that applications for planning permission be determined in accordance with the development plan, unless material considerations indicate otherwise. Decisions on applications should be made as quickly as possible, and within statutory timescales unless a longer period has been agreed by the applicant in writing.

48. Local planning authorities may give weight to relevant policies in emerging plans according to: a) the stage of preparation of the emerging plan (the more advanced its preparation, the greater the weight that may be given); b) the extent to which there are unresolved objections to relevant policies (the less significant the unresolved objections, the greater the weight that may be given); and c) the degree of consistency of the relevant policies in the emerging plan to this Framework (the closer the policies in the emerging plan to the policies in the Framework, the greater the weight that may be given).

Delivering a sufficient supply of homes

59. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.

Rural housing

78. To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.

Making effective use of land

117. Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.

Achieving well-designed places

124. The creation of high quality buildings and places is fundamental to what the planning and development process should achieve. Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities. Being clear about design

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expectations, and how these will be tested, is essential for achieving this. So too is effective engagement between applicants, communities, local planning authorities and other interests throughout the process.

Protecting Green Belt Land

134. Green Belt serves five purposes: a.) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c.) to assist in safeguarding the countryside from encroachment; d.) to preserve the setting and special character of historic towns; and e.) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Meeting the challenge of climate change, flooding and coastal change

148. The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.

Conserving and enhancing the natural environment

170. Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan); b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland; c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate; d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures; e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and f) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

Heritage

The significance of a heritage asset is defined in the National Planning Policy Framework (NPPF) as being made up of four main constituents: architectural interest, historical interest, archaeological interest and artistic interest.

196. Explains that ‘where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use’.

197 . States that ‘the effect of an application on the significance of a non-designated heritage asset should be considered in determining the application. In weighing applications that directly or indirectly affect non- designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.’

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Green Belt

144. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.

145 . A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are:

i. buildings for agriculture and forestry; ii. the provision of appropriate facilities (in connection with the existing use of land or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial grounds and allotments; as long as the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it; iii. the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; iv. the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces; v. limited infilling in villages; vi. limited affordable housing for local community needs under policies set out in the development plan (including policies for rural exception sites); and vii. limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings)

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6.0 APPLICATION ASSESSMENT AND CONCLUSIONS

Principle of Development

6.01 The principle of the proposed development is discussed as follows:

Development within the Urban Area

6.02 Following the receipt of pre-application advice, the Council agreed that part of the application site (to the east) constitutes residential garden land, located outside of the built-up area, and hence would be considered ‘previously developed land’. Furthermore, the Local Planning Authority agreed that the subdivision of the garden would not have any material harm upon the openness of the Green Belt. The proposed landscaping and boundary treatment could be controlled by way of a suitable planning condition.

6.03 Adopted Development Plan policy CP7 outlines that one of the Council’s primary objectives is to make the fullest use of existing urban areas for new development. This proposed development is located within the sustainable Coopersale urban area, close to existing infrastructure and results in the redevelopment of a brownfield site. The development potential of the site has been optimised with the dwellings located within the urban area and the rear gardens to four of the properties situated within the Green Belt. The sub-division of the existing garden within the Green Belt, continues to preserve the openness of the Green Belt and maintain its five purposes as set out in the paragraph 134 of the NPPF.

Sustainable Local and Local Employment

6.04 The Local Plan Policy CP1 seeks to achieve sustainable development by locating new development where the need to travel by private car is reduced and near to sources of employment and local facilities which will meet the needs to new residents. Additionally, Policy ST1 requires housing to be located in existing urban areas, that are highly accessible to public transport, close to services and employment opportunities.

6.05 The proposed development is accessible to a range of services and facilities within Coopersale and Epping. It is accessible without the means of private car but by regular public transport, walking and cycling links. As such the site is considered to be in a highly sustainable location and complies with these policies.

Previously Developed Land

6.06 The Local Plan Policy H2A supports the principle of sustainable re-use of previously developed land, which is strongly encouraged when considering residential schemes. The Council seeks to deliver at least 70% of all new housing stock on previously developed land, which represents a significant proportion of the housing supply. In the context of a predominantly rural District with a limited supply of deliverable brownfield sites, the development makes efficient use of previously developed land within the boundary and as such should be looked upon favourably.

Housing Need

6.07 Epping Forest District Council commentary on the 5-year assessment of land supply recognise that there is a housing supply shortage in the District. This is largely due to the constraint on suitable land for housing posed by the Green Belt that covers 92% of the District. As a result, the Council heavily reply on the effective use of land within build up areas for housing provision to meet the need for growth set out in the NPPF and meet the

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local housing needs. The proposed development would provide an important contribution towards providing additional housing to meet the housing land supply shortage in Epping Forest District.

6.08 In line with paragraph 64 of the NPPF (2018) the application scheme does not constitute a major development (of 10 or more dwellings or over 1000sqm combined floor area) the scheme is not required to make contributions towards affordable housing.

6.09 The proposed development with adopted Local Plan policies CP1, CP2, CP3, CP6, CP7, CP8, H2A, GB2A and ST1 and emerging Local Plan policies SP 1, SP 2, SP 3, DM4 and the NPPF.

Design

6.10 The proposed dwellings will be two storeys in height arranged in two blocks, one of four and other two, separated by parking. All properties would be provided with one car parking space. To the rear, all of the proposed dwellings would be provided with good sized private gardens. The site has accessible pedestrian and vehicular access to the site via Garnon Mead. The proposed development will create six well-proportioned family sized homes that exceed the national minimum space standard requirements and will provide an excellent standard of accommodation.

6.11 The scale and high quality design of the proposed development is appropriate for the edge of village location and is in keeping with surrounding residential dwellings in order to ensure the scale, design and materials are well related to the existing character of this part of the village

6.12 The design of the proposals has therefore been led by the character of the surrounding area in order to ensure that the proposals site well within this. Accordingly, the proposed developed complies with policies contained within adopted Local Plan policies CP2, H3A, H4A, DBE1, DBE3, DBE6 and DBE8, and emerging Local Plan policies H 1, DM 9, and DM 10 and the requirements of national planning policy.

Amenity

6.13 The proposals have also been designed in order to ensure that they have no unacceptable adverse impact on the amenity of surrounding dwellings. This is achieved by ensuring a separation distance of 20m between the two western properties and four eastern properties. Additionally, the front to side relationship of these properties means that opportunities for overlooking and loss of privacy are minimised. The intervening distance between the proposed properties also ensures that the potential for adverse impacts in terms of loss of daylight or sunlight are limited.

6.14 In accordance with policy DBE8, the proposal provides each new dwelling with generous amount of private amenity space, consisting of well sized rear gardens that enables reasonable use that are accessed directly from the dwellings they serve. These external amenity spaces are also not unduly overlooked or overshadowed therefore will provide good areas of useable external amenity space. Additionally, the proposed dwellings have all been designed in accordance with the nationally described space standards and will provide a good quality internal living environment. Accordingly, the proposals will provide good levels of internal and external amenity for future residents.

6.15 Due to the location of the site in relation to neighbouring properties, the proposed development would not have any unacceptable impact upon the occupiers of neighbouring properties.

6.16 Accordingly, the proposals comply with adopted Local Plan policies DBE1, DBE2, DBE3 DBE8 and DBE9 and emerging Local Plan policies DM 9 and DM 10.

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Heritage

6.17 The application is supported by a Heritage Assessment prepared by the Heritage Collective. The assessment concludes that the site has no historical associations of note, and there is no evidence of any architectural quality associated with the existing building on site. The building does not accord with the Council’s standard for local listing by some margin, and it should not even be considered for local listing. It should not and need not be regarded as a non-designated heritage asset within the meaning in paragraph 197 of the NPPF. It is not a heritage asset of any type or description. Therefore, the consideration of the redevelopment of the site can and should proceed on the basis that there is no heritage issue consider in policy terms.

Ecology

6.18 The proposed application has been carefully designed to conserve and enhance the countryside. The new dwellings are located within the built-up area and beyond this, land within the Green Belt will be residential garden land and therefore the nature of this use will be the same as the existing. It has been designed to minimise impact upon the adjacent Epping Forest SSI and this can be controlled by appropriate ecological mitigation, a landscaping scheme comprising new native planting and appropriate boundary treatment along this boundary.

6.19 The application submission is supported by an Ecological Walkover Survey, a Reptile Survey and a Bat Survey prepared by James Blake Associates Ltd to support the planning application and which confirms that the application proposals will result in a net gain in biodiversity across the site of almost 13% for habitat units and 42% for hedgerows.

6.20 The Reptile Survey confirms that an ‘exceptional’ population of slow worm and ‘low’ population of grass snake was found to be present on site. The Reptile Survey Report submitted with the application also suggested some biodiversity enhancements which could be incorporated into the landscaping proposals. An appropriate portion of the proposed donor site which is within the applicant’s ownership would accept the slow worms and grass snakes that are proposed to be translocated from the site. The donor site is within close proximity of the site and can be identified using the following co-ordinates (X (Easting) 548596 and Y (Northing) 200976).

6.21 The Bat Survey confirms that a single common pipistrelle bat was recorded emerging from the gable end vent at the east facing and day roost and potential occasional roost is considered to be present within the outbuilding building. No other roosts were identified on site during the surveys. Foraging activity on site was moderate. Commuting activities were dominated by common pipistrelles with occasional noctules. The Bat Survey Report has also recommended some biodiversity enhancements which can be incorporated into the proposed development.

6.22 The Ecological Walk recommends that the addition of bird boxes will provide more nesting/roosting opportunities these species. Hedgehog links are recommended to enable small mammals to move through the development. If these precautionary measures are followed, it is considered that the development is able to proceed with minimal impact on the local conservation status of any protected and important species within the area.

6.23 The proposals therefore accord with the requirements of adopted Local Plan policy CP2, emerging Local Plan policy DM1 and national planning policy and will deliver significant biodiversity enhancements.

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Trees

6.24 Local Plan policy LL11 requires developments to retain trees and other existing landscape features or to establish new long-term planting. This is supported by policy CP5 that requires developments to adopt methods to protect wildlife habitats, trees and other landscape features during construction.

6.25 Emerging policy DM10 that requires development to include enhanced provision of green infrastructure, including the quantity and quality of landscaped areas, tree provision and the provision of additional open space.

6.26 The development will retain the majority of existing trees on site and also have minimal impact upon the visually important buffer along the southern boundary.

6.27 Accordingly, the proposals comply with adopted Local Plan policies LL11 and CP5, and emerging Local Plan policy DM10.

Landscaping

6.28 Local Plan policy LL11 requires developments retain trees and other existing landscape features or to establish new long-term planting. This is supported by policy CP5 requires development to adopt methods to protect wildlife habitats, trees and other landscape features during construction.

6.29 Emerging policy DM10 that requires development to include enhanced provision of green infrastructure, including the quantity and quality of landscaped areas, tree provision and the provision of additional open space.

6.30 The existing overgrown hedgerow on the western boundary will be replaced with a new indigenous hedge to offer visual protection. The proposed landscaping will help to incorporate the development into its surrounding and enhance the existing ecology by providing a variety of species that are appropriate to the location on the edge of Epping Forest.

6.31 A biodiversity net gain calculation has been prepared by James Blake Associates. The calculation concludes that the landscaping and ecological enhancements will result in an overall score gain of almost 13% for habitat units and 42% for hedgerows. This means that the development exceeds the nominal target of 10% gain in both categories.

6.32 Accordingly, the proposals comply with adopted Local Plan policies LL11 and CP5, and emerging Local Plan DM10 policy.

Access and Connectivity

6.33 The proposals will result in a net increase of four dwellings. As set out above, it is therefore acknowledged that the proposals are likely to result in a modest increase in vehicles utilising the site. However, the site is in an accessible location and this minor increase in vehicles will not have any detrimental impact on highway capacity or safety.

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6.34 Additionally, the village of Coopersale has a range of services and facilities including a Cricket Club, Primary School, number of shops and convenience stores, a Church and Coopersale Social Institute Hall. Therefore, future residents would therefore be able to service some of their day to day needs within the village within the need for the use of the private car.

6.35 Coopersale is also located in close proximity to Epping which is accessible by pedestrian footpath links close to the subject site, which is approximately 20 minutes by foot or 5 minutes by bicycle. Epping offers numerous services, facilities, employment opportunities and direct access into London via Epping underground station. Regular bus services connect Coopersale to Epping with a limited journey time of just 5 minutes. The site is therefore considered to be in a highly sustainable location where there are opportunities to access services, facilities, and employment without the need to use the private car.

6.36 The proposed site plan illustrates an area of car parking between the proposed dwellings. The existing access to the site will be suitably upgraded to serve the proposed development. The shared access has been designed in a safe manner with good visibility onto Garnon Mead. The existing access serving number 1 Coopersale Common will be removed in the interest of highways safety to ensure the application will provide safe and convenient access and parking and comply with the standards set in policy ST6.

6.37 Safe and secure cycle parking provision has been provided for each dwelling.

6.38 Accordingly, the proposals comply with adopted Local Plan policies ST1, ST2, ST4, ST6, DBE6 and emerging Local Plan policy T1.

Waste and Recycling Facilities

6.39 Adopted policy CP5 requires development to conserve energy, make the most efficient use of water and other resources, recycle waste or protect environmental features and local amenities.

6.40 Emerging policy DM11 requires all new developments to make suitable provision for the storage of refuse and recycling. Covered and secure areas have therefore been integrated into the proposals at the side of each dwelling in order to allow for ease of access.

6.41 The proposed development incorporates the provision for the storage of refuse and recycling located at the side of each dwelling.

6.42 Accordingly, the proposals comply with adopted Local Plan policy CP5 and emerging Local Plan policy DM11.

Contaminated Land

6.43 Policy RP4 states that the Council will not grant planning permission for the development which it considers likely to be contaminated, unless prior tests are carried out and if contamination is found, methods of treatment and monitoring are agreed with the relevant authorities and that the agreed methods of treatment include measures to protect or recreate habitats of nature conservation interest.

6.44 Emerging policy DM21 states that the Council will expect the remediation of contaminated land through development. Potential contamination risks will need to be properly considered and adequately mitigated before development proceeds.

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6.45 The application supported by a Phase 1 Desk Study and Preliminary Risk Assessment prepared by Stansted Environmental Service. The conclusions drawn from the study has not identified any significant pollutant linkages associated with the site, however, given the proximity of the site to a railway, and the sensitive use proposed, contaminated land investigations could be required. Any additional investigations could be secure through a planning condition. Accordingly, the proposals comply with adopted Local Plan policy RP4 and emerging Local Plan policy DM 21.

Flood Risk and Water

6.46 Policy U3B requires developments to include sustainable drainage systems to control the quality or attenuate the rate of surface water run-off. Contributions in the form of commuted sums may be sought in legal agreements to ensure that the drainage systems can be adequately maintained.

6.47 Policy U2A states that development proposal within flood Zone 1 is considered an area with little or no flood risk. In accordance with this, the Council will only permit development in areas of functional flood plain if it involves use of land only and would not increase flood risk or danger from flood risk.

6.48 Emerging policy DM 15 states that the Council will require all development proposals to demonstrate that they avoid and reduce risk of all forms of flooding to future occupants and do not increase the risk of flooding elsewhere. All proposals for new development will be required to: manage and reduce surface water run-off, manage water and waste water discharges, ensure safe access and egress for future users of the development and an appropriate emergency evacuation plan where appropriate; and include measures to assist existing communities at risk of flooding where feasible.

6.49 The site is located within flood zone 1 and is therefore at low risk of flooding and is a suitable location for residential development. It is proposed that the new dwellings will utilise the surface and foul water drainage infrastructure on site that services the existing two dwellings.

6.50 The application submission is supported by a Flood Risk Assessment and Sustainable Drainage Strategy prepared by MTC Engineering to support the planning application.

6.51 The report confirms that the site is in Flood Zone 1 and is considered to be at low risk of flooding. No specific flood resistant or resilient construction methods are required.

6.52 It is recommended that infiltration testing will be undertaken once conditional planning approval has been granted to establish infiltration rates at the site, and if sustainable rates are achieved then surface water drainage will be partly or completely via infiltration.

6.53 The report confirms that the Sustainable Drainage Strategy provided successfully demonstrates an available and workable solution for managing surface water in accordance with applicable SuDS guidance exists. Therefore, recommends it would be appropriate to apply a surface water drainage condition to any planning approval granted requiring the final detailed drainage design to be undertaken once conditional planning approval has been granted.

6.54 The report concludes that the Flood Risk Assessment and Sustainable Drainage Strategy is fully in line with current Local and National Policy and there are no flood risk or drainage related grounds on which to object to the proposed development.

6.55 Accordingly, the proposals comply with adopted Local Plan policies U2A and U3B, and emerging Local Plan policies DM15, DM16 and DM18.

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Sustainability

6.56 As set out in the previous section of this Statement, paragraph 8 of the NPPF identifies that sustainability has three key dimensions: economic, social, and environmental. The Council’s Development Plan broadly aligns with this interpretation of sustainability.

The Economic Dimension

• The application scheme will make an important contribution to towards providing additional housing to meet the housing land supply shortage in Epping Forest District with the provision of six modern sized family homes. The District’s supply of suitable land for housing is considerably constrained by the Green Belt and this application scheme provides an opportunity to develop a sustainable site within the urban area.

• The development proposals will generate construction, real estate, and legal employment in the short term. In the longer term, as the site is occupied, future residents will supplement the local labour market, increase spending locally, and utilise local services within Coopersale and Epping.

The Social Dimension

• The development proposals will contribute to the provision of a six new market homes in Coopersale (with the existing properties vacant and in a poor state of repair). The substantial need for new housing in Epping Forest, and nationally, is well documented and reflected in both local and national planning policy.

• The proposed development represents a high-quality design and density that is appropriate for the rural character and edge of village location.

• The proposed development is accessible to a range of services and facilities within Coopersale and Epping by walking and cycling. The rang of facilities include a Cricket Club, Primary School, number of shops and convenience stores, a Church and local recreational facility. The site is therefore considered to be in a highly sustainable location where there are opportunities to access services, facilities, and employment

• Additionally, future residents will utilise local facilities, support existing services and community groups within Coopersale and Epping contributing to the local society.

The Environmental Dimension

• The proposed development will make most effective use of a parcel of land in a sustainable location. It will encourage travel by sustainable modes of transport, and, by virtue of its high quality and respectful design, it will preserve and enhance the character and appearance of the area.

• The portion of the site which is located within the Green Belt will remain as residential garden land in order to preserve the character of the countryside and the openness of the Green Belt and to minimise any potential impacts upon the adjacent Epping Forest SSSI.

• The proposed incorporation of ecological enhancement measures will result in a gain for local wildlife. Additionally, the landscaping proposed as part of the scheme will result in a net gain in biodiversity across the site.

• Additionally, the proposed new homes would be built to a high standard of energy efficiency having regard to current building regulations and policy.

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6.57 The proposed development therefore represents a sustainable scheme that has social, environmental, and economic benefits and where there are no material considerations that indicate otherwise. The proposed development therefore complies with the Local Plan and relevant paragraphs within the NPPF.

Summary and Conclusions

6.58 The proposed development is in accordance with a key spatial objectives within the adopted and emerging Local Plans, which seeks to locate all new development within the urban area of the District, to preserve the character of the countryside and the openness of the Green Belt. Furthermore, the application scheme also makes efficient re-use of previously developed land for new development.

6.59 The proposed development will make an important contribution towards meeting the District’s housing land supply as much of the districts suitable land for housing is considerably constrained by the Green Belt. This application scheme provides an opportunity to develop a sustainable site within the urban area, as well as enhancing bio-diversity resulting in an overall net gain.

6.60 The proposals have been assessed against both adopted and emerging local planning policy and shown to comply with both. The proposals also comply with the requirements of the NPPF.

6.61 The development proposals meet the three objectives of sustainable development as outlined above and will bring numerous additional economic, social, and environmental benefits. Therefore, the proposed development has therefore been shown to be sustainable both intrinsically and when considered through the lens of NPPF policy.

6.62 The council is therefore respectfully request to grant planning permission for the application scheme.

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APPENDIX 1: EPPING FOREST DISTRICT COUNCIL PRE-APPLICATION RESPONSE DATED 20 APRIL 2020

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