Save Jessel Green Campaign Recipient: Local Plan Regulation 19 Representation, Epping Forest District Independent Local Plan Inspector Letter: Greetings, We consider the Regulation 19 (Submission Version) Epping Forest District Local Plan 2017 defective and unsound due to the inclusion of site LOU.R5 (Jessel Green) in the Plan, page 122 section B, Policy P2 Loughton. Community Visioning consultation 2010/11 The Community Visioning Consultation in 2011 sought to understand what the planning issues are for the local community and how people would like to see the area develop in the future: Question 1 asked: What do you think the priorities are for the District over the next 20 years? 32.4% (the largest response) said 'Protect & enhance green spaces’ (not focused solely on greenbelt) Question 2 asked: What planning issues do you think most need to be addressed in your local area? 20.6% (the largest response) said ‘Protect green spaces’ (not focused solely on greenbelt) 'Policy SP 6 Green Belt and District Open Land' (page 51), and 'Policy SP 3 Place Shaping' fails to identify any Urban Public Open (community used and accessible) Spaces, which are to be given Local Open Space Designation. All focus in the Plan is on protecting the Green Belt and gaps/holes in the Green Belt, not the heavily populated areas that need protected recreational spaces like Loughton, Chigwell, Buckhurst Hill and Epping. We, the undersigned, petition the Local Plan Examiner to: -Consider the Regulation 19 (Submission Version) Epping Forest District Local Plan 2017 unsound, poorly prepared, unjustified and inconsistent with National Policy because: -It incorporates a central and unsupported sequential test which leads to greenfield recreational land in towns being given a higher development priority than similar land elsewhere -It ignores the amenity and wellbeing value of public urban open space, and the great public affection of residents and others for Jessel Green (LOU.R5) -It purports to support and enhance such land, but as a contradiction, proposes to allocate it for housing -It relies on a so called proportionate distribution of housing whereas in fact it allocates Loughton 196 dwellings per square mile where an even spread would be 67 dwellings per square mile -Site selection across Epping Forest District has not been consistently assessed -Alternative sites were offered by land owners within Loughton and neighbouring towns, which would remove the need for any housing allocation on Jessel Green, but have been removed from the Regulation 19 Submission version of the Epping Forest District Local Plan, without clear explanations why -Jessel Green (site LOU.R5) appears to meet the criteria for designation as a Local Green Space in accordance with National Planning Policy Framework sections 76 and 77. -Emergency services (the Essex & Hertfordshire Air Ambulance service) use Jessel Green as a landing location in extreme cases – 5 times in the last 18 months. -City of London/Conservators of Epping Forest in their 2016 Draft Local Plan consultation response identified concerns over this site being included (page 8); 'At Loughton The Conservators would disagree with the proposed loss of green space at Borders Lane and Jessel Green. The latter site in particular, if lost, would place considerable pressure on the nearby Forest and also would seem to be in contradiction to the green infrastructure policies in the draft Plan. Such a large green space is currently valuable and has considerable potential to be developed for both access and for wildlife'. -All schools in the area (5 actually on the estate) oppose this volume of development due to overcapacity and health impact on its children and their families. The inclusion of large developments throughout Loughton will have a cumulative effect. -All local bus services have either been reduced to a limited service or are under review -According to Transport for London’s 2016 Draft Local Plan consultation response, they are relying on Crossrail opening in 2019 to reduce its capacity problems. This is on the basis that commuters will be willing to travel substantially further to board trains in The London Boroughs of Havering, Newham or Waltham Forest. Encouraging more car use, congestion, parking pressures and increased poor air quality does not support EFDC’s Air Quality or Sustainability Transport (Policy CP9) and Sustainable Travel Plans (Policy ST5) policies. -Roads throughout the Debden estate are underserved greatly by Essex County Council Highways In respect to the allocation of Jessel Green, site LOU.R5 for a housing development, the plan is unsound, as non-compliant with NPFF National Guidance Paras 73, 74, 76 and 77 for the following reasons: 1. The evidence provided by the EFDC Open Space Strategy Nov 2017 by 4 Global identifies a significant shortfall in recreation space for young people. Furthermore, the Open space audit of March 2009 commissioned by EFDC for Loughton states that Jessel Green was well used by young people and its use has grown significantly since then. Building on this location will therefore create a further deficit in open recreational space, which is counter intuitive and contrary in the extreme to the healthy community objectives that EFDC aspire to, in its commitment to National Planning Policy. 2. Loughton residents through its Local Town Council have identified Jessel Green as having special importance as a Local Green Space, specifically as a highly utilised and valuable recreation space at the heart of Loughton. This request and requirement made by the Loughton community through its elected representatives, Loughton Town Council has not been taken into account by EFDC and its consultants ARUP, despite an overwhelming petition and response from local residents to the proposals for residential development on this open space. To confirm, this open space is enjoyed by all ages and abilities throughout the year, which culminates in an annual event, which brings together 1000s of residents across the district to a community fun day. This location therefore has a unique significance and provides an incredibly valuable service in connecting the community. 3. There is no provision in the plan for replacing this valuable recreation space, if built on, so again is not compliant with National Planning Policy. Actions to be taken: We therefore ask the Epping Forest District Independent Local Plan Inspector to: a) Advise/recommend Epping Forest District Council support the request by Loughton Town Council, to register site LOU.R5 (Jessel Green) as a protected ‘Village Green’ as per the application to Essex County Council in December 2013. b) Request page 121 of the submission version Local Plan 2017 paragraph 5.33 should be replaced with, 'In its commitment to promote healthy communities, Jessel Green shall be designated as a ‘Local Open/Green Space’ as having unique importance to the local community as a vital recreation space and connection point for the local community'. This is consistent with National Policy in promoting healthy communities, specifically it is fully compliant and aligns with the requirements as set out in NPFF para 77, to provide this status to spaces that are particularly valued by the local community. c) Request on page 122 of the submission version Local Plan 2017 site LOU.R5 (Jessel Green) should be removed from the list of residential sites under section B, Policy P2 Loughton.