Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22472

Received: 19/03/2019

Respondent: Hallam Land Management Limited

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Plan has not taken into account any unmet needs from neighbouring areas in establishing the amount of housing to be planned for (paragraph 60 of the Framework).

No reference is made to co-operation over unmet housing need, and specifically no discussions are referenced in respect of whether Brentwood could accommodate some of the identified need in accordance with Paragraph 137 criteria c of the Framework.

Therefore, the BBDP is currently not sound as matters relating to unmet housing needs have not been dealt with and the Duty to Co-operate has not met the necessary legal tests.

Change suggested by respondent:

The Local Plan must be amended to explain how unmet housing needs within neighbouring areas will be addressed.

Full text:

The Pre-Submission Document (February 2019) (BBDP) makes provision for housing solely to meet the housing needs from within its administrative area. It has therefore not taken into account any unmet needs from neighbouring areas in establishing the amount of housing to be planned for (paragraph 60 of the Framework).

Neighbouring authorities have potential unmet housing needs. For instance, Basildon have stated in its recent Regulation 19 Plan that it has unmet needs of up to 4,000 homes over its plan period. Thurrock have stated that its current housing land supply falls significantly short of its housing needs, at around 15,000 dwellings.

Brentwood Borough also adjoins greater London Authorities. The London Plan is currently under examination and it is possible that unmet housing needs will be established.

The Duty to Co-Operate Position Statement (February 2019) describes engagement with other local authorities, in particular in the South Essex area. However, no reference is made to co-operation over this unmet housing need, and specifically no discussions are referenced in respect of whether Brentwood could accommodate some of the identified need in accordance with Paragraph 137 criteria c of the Framework.

Further, the ASELA Statement of Common Ground (June 2018) does not reflect the latest position on unmet housing need or how it will be addressed. It has therefore not been maintained contrary to paragraph 27 of the Framework.

Therefore, the BBDP is currently not sound as matters relating to unmet housing needs have not been dealt with and the Duty to Co-operate has not met the necessary legal tests.

This approach to plan making has been found unsound elsewhere in similar circumstances. Please see attached the Inspector's Letter of 1st June 2015 to Warwick District Council in respect of its Local Plan following initial hearings. In particular, please note paragraphs 23 to 29.

The duty to co-operate has therefore not been complied with, and as a consequence resulted in an underestimated housing requirement.