Comment
Draft Local Plan
Representation ID: 15342
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
PPG directs that OAN should be adjusted to reflect economic forecasts and market signals.The OAN for Brentwood should take account of:
- Economic Led Need: level of job growth underpinning PBA's conclusion on economic-led need is constrained by a housing provision target. This is considered in conflict with the PPG which advises that plan makers should not apply constraints to the overall assessment of need.
- Market Signals: Brentwood affordability ratio is significantly higher than Essex and national averages. The PBA assessment identifies that the affordability in Brentwood has not worsened compared to national and regional indicators and therefore an additional uplift is not required. As a result of this, BBC's housing target would simply allow the issue of affordability to continue and would not assist in addressing such a trend.
- Greater London - Brentwood borders the Greater London Authorities (GLA) and there is strong evidence to suggest that LPAs outside the GLA will need to accommodate London's housing shortfall.
See attached.