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The Local Plan must be amended to reflect the most up-to-date approach to assessing the local housing need, and take into account unmet housing needs from neighbouring areas when establishing its housing requirement.

The total housing supply must demonstrate that it provides a sufficient supply and mix to meet the requirement, including for the first five years of the Plan period.

The stepped trajectory must be consistent with the evidence as to when strategic Green Belt allocations will start delivering.

The Local Plan should plan for a minimum of 15 years from adoption.

Establishing Local Housing Need and Requirement

The Pre-Submission Document (February 2019) (BBDP) defines an annual housing need of 350 dwellings per annum (dpa) using the standardised method based on the 2016 based household population projections.

Since the BBDP was drafted, the Framework has been amended to make clear that the 2014 household population projections are the baseline for calculating the standard housing need. On this basis, the annual housing need in the BBDP should be adjusted to 452 dpa.

In addition, an allowance may be necessary for unmet housing needs arising from neighbouring areas (see representations made by Hallam Land Management in relation to the Duty to Co-operate). Any figure would need to be added to the annual housing requirement.

The BBDP also proposes a housing supply buffer of 20% to allow for flexibility in meeting the requirement. This is supported in order to ensure the requirement is achieved. Without planning for a buffer to the housing requirement, there is the potential that housing needs will not be met. This is particularly necessary within Brentwood on the basis that the majority of Borough is Green Belt, and therefore there is very limited capacity for speculative windfall development to address any shortfall arising during the plan period.

Notwithstanding this has yet to be demonstrated, on the assumption that there are no unmet needs arising from neighbouring authorities, the housing requirement with a 20% buffer would be 542 dpa. If there are unmet housing needs, this figure would clearly be greater.

Provision should therefore be made in Policy SP02 for at least a minimum of 9,214 dwellings (based on 542 dpa) in the plan period 2016 to 2033.

On this basis, and setting aside the issue of unmet needs, the total housing supply in Figure 4.2 does not show a sufficient supply and mix of sites to meet the minimum number of homes required. It also does not demonstrate a five year supply on adoption of the Plan.


Stepped Trajectory

Policy SP02 proposes a stepped trajectory in housing supply due to existing Green Belt boundaries currently constraining growth. However, the increase in housing supply starts at 2023/24, which is a year after the housing trajectory assumes delivery starts on a number of the strategic Green Belt allocations (2022/23). The two dates should be consistent with each other.

Plan Period

It is assumed that adoption of the BBDP will be at the earliest in 2019/20. The Plan will therefore fall short by 1 year in ensuring the Plan looks ahead over a minimum 15 year period from adoption (NPPF paragraph 22).