brentwood.gov.uk

There are significant concerns with the validity of 'objective' assessments -- in the case of Brentwood, the report makes clear that the housing completion rates during the recession were anomalously large due to the conclusion of several major projects that had started before the recession (see §5.28). This means that projections that may have been appropriate for other local authorities are likely to be overestimates in the case of Brentwood. Another suspect matter is the definition of appropriate housing densities in Brentwood's Strategic Housing Land Availability Assessment Main Report. In that report, dated October 2011, it is suggested that "in the current climate [flats/apartments] are not proving to be popular", and Table 3/1 consequently suggests that flats are appropriate only in "Brentwood centre, Shenfield centre plus sites on the main roads coming out of these centres". Even more suspect is the Table's suggestion that terraced houses can be suitable only in Brentwood, Shenfield, and the centres of a couple of select villages (Ingatestone, W. Horndon, and Doddinghurst). Given the popularity of less centrally located neighbourhoods such as Clement's Park, a mixed-density development that includes many blocks of flats and terraced houses, it is clear that the Housing Land Availability Assessment Report is underestimating the popularity and suitability of high- and mid-density development, which also has the advantage of facilitating viable and accessible public transport, such as bus services, an important consideration in view of the need to substantially reduce car usage. What this means in practice is that it is eminently feasible to develop a large number of homes on a much smaller plot of land than the one proposed, to the extent that any need for the green belt to be compromised can be obviated, given sufficient political will not to bow to the demands of estate agents and developers, who naturally prefer low-density development on greenfield sites due to their higher profitability, and who prioritise such profitability over the needs, wishes, and best interests of local residents. Even if the Objectively Assessed Housing Need were to be accepted on its current basis, it would not mandate the destruction of large swathes of green belt: there is considerable potential for high-density development on urban brownfield sites, and, legally speaking, the green belt takes precedence over development needs. Paragraph 34 of the Planning Practice Guidance stipulates that "Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the 'very special circumstances' justifying inappropriate development on a site within the Green Belt." Paragraphs 44 and 45 also make clear that Objectively Assessed Housing Need is not the only pertinent factor in determining housing targets, and the significant amount of green belt land in the Brentwood and Basildon districts would be sufficient justification to set housing targets at a lower level than that suggested by the Objectively Assessed Housing Need (Brentwood's green belt is, according to the council's own strategic growth options development plan, "the sixth highest in England by percentage of total area").