Planning Application No: CC/EPF/88/22
Proposal: Demolition of the existing building and the construction of new part 5/part4/part 3 storey building to provide (i) a public library; (ii) space for offices, community use and Jazz Archive; (iii) the provision of 38 residential apartments; and (iv) associated access, parking, servicing, utilities, and landscaping
Location: Loughton Library, Traps Hill, Loughton, Essex, IG10 1HD
Applicant: Essex County Council
The Conservators of Epping Forest have submitted the following objection:
“This site is shown in the EFDC Local Plan Policy Document P2 Loughton, and states that the site would have a net capacity of 20 dwellings. This application is for nearly double this volume of dwellings and there does not appear to be any justification within the Design Statement or Shadow-HRA for how such an uplift can be justified. The Conservators object to this development for the following reasons:
Recreational Impact
The Shadow HRA accompanying the application clearly indicates that LSE would occur from this development. There is little/to no amenity space provided, aside from the nearby (LEAP) which has a limited scope of use for potential new residents and is already extremely popular with local residents.
As the Forest is the closest ‘green / open’ space within the locality (300m) and the nearest alternative green space, which is very limited in size is nearly twice the distance away, it is significantly likely that the Forest would represent the most attractive area for recreation. As Epping Forest Visitor Surveys have shown, about half of all visits to the Forest are made by those living within 3km of the boundary, it is likely that this proposal will add to the existing level of visitor disturbance. This likelihood increases in the case of the proposed development given that the private outdoor space for each development is very limited.
Given that LSE from the site cannot be ruled out then an Appropriate Assessment must be conducted. At present the mitigation proposals set out in the application, suggest that the site is too small to provide mitigation and therefore all mitigation needs to be conducted upon the SAC. The Conservators would argue therefore that such a statement does not justify the 18-dwelling uplift on the site above the Local Plan allocation, which would provide greater amenity space per dwelling.
Air Quality Impact
The AADT of 47 trips, of which 30 would likely utilise roads within the 200m of the SAC. The traffic modelling was for the 20 dwellings and therefore would require a revision to rule out the uplift of 18 vehicles. ULEV vehicles, regardless of their emissions volume, would still cause increased traffic upon a compounded junction High Road/Traps Hill. In addition, there would be an increase in trips generated from deliveries, taxis and visitors to all the residential dwellings.
The Conservators believe therefore, that EFDC as the competent authority on planning cannot permit this development, especially above the planned site allocation of 20 dwellings as part of the Local Plan. Therefore, we await further developments of the Local Plan to understand how this proposal fits with the overall approach towards the local authority’s legal requirement to protect Epping Forest SAC.
We refer you to the recent decision by EFDC to refuse permission for the development on 69 Church Hill, Loughton (EPF/2369/20) which was refused on its effect on the integrity of the EFSAC. This decision was further supported at appeal at the Planning Inspectorate (3270758).
You can find out more about this application and its progress via Epping Forest District Council here: Planning Application: EPF/2257/22 (force.com)
