Strategic Growth Options
Much has changed since the last Local Plan consultation in 2013. Several issues need to be reconsidered before the Council can progress to the next stages of Local Plan preparation. This consultation document provides the opportunity to reconsider issues and sets out development options for public comment.
1.1 Brentwood Borough Council is required to plan for the needs of the Borough. The Council is committed to doing so while maintaining the quality of life and environment enjoyed by those who live and work in the Borough. This consultation document sets out the options being considered to meet future development needs in order that we might positively plan for the next 15-20 years.
1.2 Much has changed since 2013, when the Council last consulted on the emerging Local Plan (see paragraph 1.10). Several issues need to be reconsidered before the Council can progress to the next stages of Local Plan preparation. This consultation document provides that opportunity, by setting out:
- Sites that have been suggested to the Council to meet local development needs, such as housing, employment and retail; and
- Information on the key issues to consider as part of assessing sites, such as appropriate areas for growth in light of transport infrastructure, local services, and the environment.
1.3 Options for development, whether broad locations or individual sites, need to be considered in light of Borough-wide issues. 89% of Brentwood Borough is Green Belt, the sixth highest in England by percentage of total area. This helps protect much of the Borough’s high quality environment but also constrains development opportunities, making it difficult to meet local needs.
1.4 The Council is required to meet local housing and employment needs, among other needs. For housing, evidence suggests that need is around 360 new homes per year, or 5,500 new homes over a 15 year period. The capacity of brownfield sites in urban areas over 15 years is 2,500, some 3,000 short of total need.
1.5 Responses to this consultation will help inform decisions the Council will need to make about where the most appropriate locations are to meet the needs of the Borough. The results of previous consultations will also inform preparation of the new Local Plan, such as representations received to the 2013 Preferred Options document, which are currently being considered.
1.6 It is important to consider all options through public consultation before proposing a strategy going forward. Options will also need to be considered in light of the Evidence Base. Technical evidence documents used to help draft this consultation document and inform the Plan are available to view on the Council’s website at www.brentwood.gov.uk/localplan
1.7 Until recently, regional plans set local housing and employment targets, among other things. The Localism Act 2011 introduced provisions to abolish regional plans and enable Councils to set their own targets. Previously, the East of England Plan set a requirement for Brentwood Borough of 3,500 net additional new homes between 2001 and 2021 (175 homes per year). When identifying housing targets Councils are required by the National Planning Policy Framework (NPPF) to identify their objectively assessed needs, in other words, the amount of housing needed without considering local constraints and policies (such as Green Belt).
1.8 The East of England Plan was revoked in January 2013. This means that since that time the Council has been required to ensure that the supply of new homes and jobs matches the Borough’s needs. In order to do this in a planned way and in the most appropriate locations, the Council is preparing a new Local Development Plan, or Local Plan for short. The Plan has to be subject to rounds of consultation and pass independent examination before it can be adopted for use.
1.9 The Local Plan needs to be consistent with national policy and guidance, such as the NPPF and Planning Practice Guidance. The NPPF is the national framework, provided by central government, which sets out the principles that development must follow across England.
What’s Changed Since 2013?
1.10 Following the conclusion of the consultation in late 2013 it became apparent that several issues needed to be reconsidered, specifically:
Objectively assessed housing need:
- Objections were received from three neighbouring authorities (Basildon Borough Council, Chelmsford City Council, and Thurrock Borough Council) through the duty to cooperate. The Preferred Options document did not propose to meet all of the Borough’s housing need, and the adjoining authorities’ responses stated they would not accept any shortfall from Brentwood Borough within their own boundaries.
- Consequences of failure to meet full need became more clearly evident in decisions by Planning Inspectors to other Local Plan examinations; Plans that did not meet full need were found ‘unsound’ on the basis that they did not conform with the NPPF.
- The need to positively prepare the Plan supported by published technical evidence.
- New employment land and job provision: The need to review economic evidence in light of the related housing supply position.
- Crossrail: The need for additional evidence on the economic impacts arising from the arrival of Crossrail and other related impacts, was raised as an issue that required further consideration.
- Sustainability: Renewable energy evidence undertaken suggested proposed sustainability policies needed to be reviewed.
- Planning for Gypsies & Travellers: A new Gypsy & Traveller assessment for all Essex authorities has been produced. The Council will need to consider the conclusions of this in preparation of the next version of the Draft Local Plan.
- Basildon Borough Council proposals: The Council became aware of proposals by Basildon Borough Council through duty to cooperate discussion that the Basildon Draft Local Plan (December 2013) proposed a strategic development allocation at Dunton up to the Brentwood Borough boundary.
1.11 The Local Plan needs to be consistent with national policy and guidance. The risk to the Council of continuing without reconsidering the above is that the Plan would be likely to be found ‘unsound’ at examination. As a result it is considered inappropriate to proceed to the Pre-Submission stage with the Preferred Options strategy, without further consultation.
1.12 The NPPF requires local planning authorities to meet the full objectively assessed needs for housing. This is in order to significantly boost the supply of housing nationally. Authorities must calculate their need based on up to date evidence, including demographic changes, and changes due to migration.
1.13 It is essential that the Local Plan is informed by robust and up to date evidence. In addition to the existing evidence base, since 2013 several technical studies have been produced or are forthcoming (as at December 2014):
- Brentwood Economic Futures 2015-2030 (December 2014)
- Revised Retail & Commercial Leisure Study (December 2014)
- Green Infrastructure Study (forthcoming)
- Landscape Capacity Assessment (forthcoming)
- Surface Water Management Plan for Brentwood Borough (forthcoming)
Housing & Demographic Evidence
- Strategic Housing Market Assessment (SHMA) (July 2014)
- Greater Essex Demographic Forecasts Phase 6 (September 2014)
- Objectively Assessed Housing Needs for Brentwood Borough (December 2014)
- Housing Viability Study (forthcoming)
- Crossrail Economic Impacts (forthcoming)
- Highways Modelling (forthcoming)
- Leisure & Facilities Evidence
- Open Space Study (forthcoming)
- Sports Facilities Study (forthcoming)
- Renewable Energy Evidence
- Renewable Energy Study (forthcoming)
For a complete list of evidence, including past documents, please see the Council’s website at www.brentwood.gov.uk/localplan
What Are We Consulting On?
1.14 The Council is undertaking two consultations in parallel during January as follows:
Consultations starting in January 2015
For more information on both documents and to respond please visit www.brentwood.gov.uk/localplan.
Life of the Plan
1.15 The Local Plan will be prepared to cover a specified period of time, or the ‘Plan Period’. The Plan period proposed in the 2013 Preferred Options was from 2015-2030, in line with the NPPF recommendation that Plans should ideally have a life of 15 years. This means that this document is based on a 15 year period. As part of the plan-making process the Council will need to consider whether a 15 year Plan period is appropriate. In order to take account of previous years’ shortfalls, particularly since 2013 and the abolition of the East of England Plan, it may be more helpful to begin the Plan period from 2013. The longer the Plan period, the more need that will be required to be met.
1.16 The Council is required to undertake a Sustainability Appraisal (SA) to inform preparation of the Local Plan. This ensures that policies and proposals contribute to the objectives of sustainable development and incorporate the requirements of the European Directive on Strategic Environmental Assessment. The Growth Options consultation document is accompanied by an Interim SA which is also available for public comment. To view the Interim SA and for more information please visit www.brentwood.gov.uk/localplan
Duty to Cooperate
1.17 Local Planning Authorities are required to cooperate on strategic planning matters. The Council has been working with and will continue to work with its neighbours on cross boundary issues (see Figure 2).
1.18 In addition to adjoining authorities, the Council is also required to cooperate with other authorities such as Essex County Council and those in the wider region where appropriate. The Council will also cooperate with utility providers and other statutory bodies such as the Highways Agency and Environment Agency.
The Consultation Process so far
Pathway to a Sustainable Brentwood (2009)
1.19 A joint consultation between the Council and the Local Strategic Partnership, this document set out the issues and options for both the emerging Core Strategy and Sustainable Community Strategy. This included four spatial options for growth in the Borough, but were based on housing and employment targets set by the now revoked East of England Plan.
Your Neighbourhood Consultation (2011)
1.20 During Summer 2011 the Council undertook a neighbourhood consultation to give local residents and stakeholders an opportunity to put forward their views about issues that matter in their area, comment on possible housing numbers for the Borough and suggest priorities for the Local Plan.
Local Plan 2015-2030: Preferred Options (2013)
1.21 The 2013 Draft Local Plan Preferred Options consultation took place between July and October 2013. The document set out the long term vision for how the Council proposed the Borough should develop by 2030 and the draft strategy and policies for achieving that vision.
1.22 Representations received in response to the Preferred Options consultation are available to view on the Council’s website. A Consultation Statement is soon to be published, setting out main issues raised, a summary of each of the representations and the Council’s assessment of each.
1.23 In addition, consultation has also taken place on Sustainability Appraisals for the plan and specific consultation on planning for Gypsies & Travellers.
For more information, including archive documents and consultation analysis see the Council’s website at www.brentwood.gov.uk/localplan
1.24 The 2013 Draft Local Plan Preferred Options set out 11 strategic objectives to help achieve the Council’s vision, strategy and policies. These strategic objectives are separated into five overarching themes that relate to policies within the Draft Plan. For the purposes of this Growth Options consultation and future Draft Plan, these themes will be used to provide a structure to the document and a common narrative between consultation versions. The themes and related draft objectives are set out below:
The Strategic Objectives formed part of the the 2013 Preferred Options Consultation. The objectives are provided to help set the structure of the document. They are not being consulted on as part of this consultation. Comments received during the 2013 Preferred Options Consultation are being considered and will inform any future amendments as part of future Plan preparation. The Strategic Objectives as above may change in response to previously received comments.