Benjamin Murphy

The Conservators of Epping Forest have submitted the following objection to the London Borough of Redbridge in response to planning application 231/24

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Regeneration, Property and Planning,
Development Management,
11th Floor, Lynton House,
255-259, High Road,
Ilford,
Essex, IG1 1NY

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Dear Redbridge Planning Team,

Open Space and Sports Ground, Royston Gardens, Ilford – LBR 2391/24

I refer to the above proposed application for a recreational space that comprises a nine-hole pitch and putt course for a kids golf area. Teaching zone, café, an office, and car parking space.

Epping Forest is owned by the City of London and comprises some 6000 acres (2,5000 hectares). It is supported by a further 1,800 acres (730 hectares) of Buffer Lands, acquired by the City to protect the Forest from encroaching development and to maintain the links between the Forest and the wider countryside. The Epping Forest Act 1878 charged the City as Conservators of Epping Forest, with a duty to conserve varied vegetation and preserve the Forest’s natural aspect and keep the Forest unenclosed as a public open space.

The Conservators object to the above planning application on the following grounds:
* Water run off into the River Roding
* Decline in wildlife value for the site

The Conservators wish to propose
* Greater opportunities for nature conservation and public recreation

Water run off into the River Roding
The Flood Risk and Sustainable Drainage Assessment provided as a supporting document with the application produced by Herrington Consulting is still marked as a ‘Draft’, so it is unclear if this is the final document.

The Conservators have serious concerns regarding the intent of this document that surface water runoff from the site will be discharged into the Roding given the change of use from a former amenity grassland which offers reasonable amount of water interception, to a manicured golf course which will inevitably increase water runoff.

Given the current state of the grassland there would be need of intense herbicide, insecticide, fungicide usage and fertiliser use in order to maintain as a golf provision, which would leach into the River Roding leading to pollution of the watercourse and increase chances of eutrophication.

Therefore, the Conservators strongly advocate for a significantly improved SUDs scheme, wholly contained upon the site to intercept runoff and contaminates so they do not enter the River Roding.

Decline in wildlife value of the site
The Environmental Impact Assessment for the site was completed on the 22/11/2023 which is outside of the optimal Primary Ecological Assessment period of April to October. Therefore, the Conservators have concerns that this document does not represent a true reflection of the wildlife value of the site and indeed the impact this development would have.

Table 4 of the EIA, contains a plethora of errors in that the site has an extensive record of invertebrate species, is a known area for grass snakes and there have been many otter sightings along the Roding at this location, which the report suggests in unlikely.

Therefore, the Conservators are of the firm opinion that proper field survey works should be completed in spring, summer and autumn, especially focusing on reptiles and invertebrates on the site.

The Conservators also have concerns that the limited BNG interventions on the site will have little impact or permanence and could be removed in the future.

Greater opportunities for nature conservation and public recreation
Whilst accepting that the site is held privately, the Conservators believe that the site offers much greater opportunities for the London Borough of Redbridge to meet their own conservation objectives as part of their current Local Plan 2015-2030.

The site is identified as a SINC (Site of Importance for Nature Conservation) is adjacent to an identified Nature Conservation Deficiency site as well as being observed as an Open Space. The proposed planning proposal very much seeks to transform this site into a private space with a very limited scope of public recreation.

6.6.9 of the Local Plan says that the Council will resist any inappropriate and harmful development on SINCs, unless there are exceptional circumstances and where the importance of any development coming forward outweighs the nature. The Conservators do not believe any such justification exists on this site.

The Conservators are aware that Redbridge is commencing on an exciting project to re-wild Ilford Golf Course. Royston Gardens is situated a mere 700m from the golf course in a green arc which includes: the Wanstead Park Recreation Ground, Whiskers Island (Epping Forest) and the adjoining woodland and allotments. There is a significant opportunity for Redbridge Council to include this site within the London Local Nature Recovery Strategy (LNRS) and the Conservators are very pleased to see this site, which offers so much potential within aforementioned green arc, bordering Epping Forest and adjacent to the River Roding has been included in the opportunity areas, as the site as huge potential to increase the biodiversity opportunities for the site and the
area as a whole.

The inclusion of the site within a green arc of Open Space between Wanstead Park and the A406, will have improved recreational benefits for those living within the local area especially residents of Royston Gardens and east of the A406.

The Conservators of Epping Forest are grateful for the opportunity to comment on this proposal and for the reasons given.

Epping Forest Land Agent & Planning Officer
City of London Corporation