HAP Response to Epping Forest DC Plan

Below is the letter that was recently sent by HAP to the Government Inspector of the EFDC plan. The Government Inspector wrote to Epping Forest DC about their plan on 14th July, Epping Forest did not reply until September 4th, and then took yet another 3 weeks before their reply was made public on their website.

From the outset the Harlow Alliance Party took the view that those parts of the Local Plans of Epping Forest DC (EFDC), Harlow DC (HDC) and East Herts forming The Harlow and Gilston Garden Town should have been produced in one single Plan for the area. Each could then have consulted residents across the whole district at the same time and in the same way, without any conflict of interest. The outcome of not doing this has resulted in mixed messages, conflicting information about infrastructure requirements for an enlarged Harlow and each taking action in the meantime for the benefit of their own district to the detriment of others such as HDC’s plan for a tramway running from Gilston through Harlow and North Weald and on to Epping Tube Station and EFDC’s plan to redevelop parts of Epping.

The Government have recently indicated that they would like to see a reorganisation of Local Government, reducing the number but increasing the size of Local Authorities. We believe that by removing the sites from around Harlow from this Plan would give the opportunity to seek boundary changes, bringing into HDC’s boundary the Green Belt surrounding the town (which consists mostly of farm land), ensuring that it’s future is decided by the elected representatives of Harlow’s residents and not those of EFDC who in many cases live many miles away.

At the heart of the matter now is the fact that like HDC, EFDC’s document which runs to 27 pages gives predictions about future trends any of which could be affected by an infinite number of changes within society and concludes by saying that there is no need to make a single change to the proposals laid out in their Local Plan.

We would like to provide you with the following information, which leads us to the contrary view that thousands of new homes do not need to be built on (Harlow’s) Green Belt surrounding the town:

The predicted growth in the number of new households being created has continued a downward spiral since 2012, not just a few percentage points but a dramatic decline of over 50%. We note that other Planning Inspectors are questioning and rejecting Local Plans in other parts of the country where Local Authorities continue to ignore this downward trend at the expense of the Green Belt.

At point 2.4 in The Epping Forest District Draft Plan of October 2016 it states that the population in the EFDC district has only increased by 17,000 in the 50 year period 1961 to 2011. The population of an area will only see significant increases when more homes are built, evidenced by the fact that since 2011 the population has grown by another 5000, due in the main to house building programmes already undertaken and the migration of people moving into the area from London

Most significantly, based on recent facts, in 2009 the population of the UK increased by 0.87%, the highest for many years. In the period 2016 to 2020 the increase averaged 0.63 per year. The figure for the period 2020 to 2025 is predicted by the Government to fall to 0.51% and in the years 2025 to 2030 to just 0.43%. With a new points based immigration system on the horizon, these figures are likely to fall even further. It is no coincidence that the 50% reduction in the yearly increase in the population mirrors the decline in the number of new households being predicted by the ONS.

There is no evidence provided that this Plan will address the acute housing need of a larger elderly population. Nationally there were 387,000 people in the UK over the age of 90 in 2002 but as at 2019 this figure had risen to 605,000. In the EFDC area the number of people over the age of 65 is expected to increase by 20% within the next five years. Very few of the homes being built in the area in recent years have been specifically designed for residents in this age group and with so few homes being built by the public sector, the real housing need is not being met by housebuilders who are just looking for profits.

The world of business has changed for ever as a result of Covid. Who would have thought in January 2020 let alone when this Plan was first published how the rest of the year and beyond would pan out. On-line shopping and working from home mean that for an increasing number of people it is no longer necessary for them to live near their work or shop. We have made the case to the Planning Inspector of the Harlow Local Plan that simply building a large number of homes will do nothing to regenerate Harlow by itself. EFDC’s plan to build a new leisure centre, shops and cinema in Epping gives even less confidence that building more homes in the EFDC area within The Harlow and Gilston Garden Town will help regenerate Harlow.

In conclusion, to ignore the evidence about the increase in household numbers is an error of judgement, building on Green Belt is a one off, once lost, always lost.