Comment

Preferred Site Allocations 2018

Representation ID: 18250

Received: 12/03/2018

Respondent: CODE Development Planners Ltd

Agent: CODE Development Planners Ltd

Representation Summary:

The council's assessment of OAHN is considered to be robust given current data inputs. We urge the council though to continue monitor any changes to input data and review as necessary.
We support the council's approach to the possibility of further assessment and solutions should they need to adopt the Government's proposed standardized objectively assessed housing needs methodology.

Full text:

We welcome the Council's acceptance to prepare a Plan designed to meet the full Objectively Assessed Housing Need (OAHN). The work undertaken by PBA on behalf of the Council and contained in the Strategic Housing Market Assessment Part 1 (January 2018) (SHMA) appears to be a robust and up to date assessment of OAHN. The Council are therefore correct to rely upon this evidence in the current stage of the local plan process.
As stated in paragraph 7.18 of the SHMA though Objectively Assessed Need is not a science. Small changes in input data over time can have significant impacts on the levels of need. The NPPF (paragraph 158) urges Councils in preparing their local plans to ensure they use the most up to date and relevant evidence. We would therefore urge the Council to ensure that the OAHN is monitored closely and kept under review as the later stages of the local plan process progress. In the meantime, we are satisfied that the conclusion to seek to meet the full OAHN of 380 dwellings per annum is robust and a sound element of the current Regulation 18 consultation draft.
We also support the Regulation 18 consultation draft where it properly notes that the Government's proposed standardized objectively assessed housing needs methodology indicates a need for Brentwood to deliver a capped figure of 454 dwellings per annum. The Promoters fully support the Council's approach to recognizing the implications of adopting the standardized methodology and are fully engaged in the Council's appropriate investigation of how DHGV might contribute towards meeting this higher figure. Further comment is contained in paragraph 2.5.4 of these representations.
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