brentwood.gov.uk

Object

Representation ID: 230

Received: 29/09/2013

Respondent: Basildon Borough Council

Policy S2 identifies that the OAN for Brentwood is 331-373 dwellings per annum or 4,950-5,600 dwellings over the plan period 2015-2030. However, the Local Plan proposes to make provision for just 200 dwellings per annum between 2015 and 2020 and, 250 dwellings per annum between 2020 and 2030, (3,500 homes in total over the plan period). There is therefore a shortfall of between 1,450 and 2,100 homes over the plan period which is not provided for within the Brentwood Local Plan and there is an expectation in the NPPF that in such an instance, the Council would have to demonstrate that in doing so, the adverse impacts would significantly and demonstrably outweigh the benefits, or specific policies in the NPPF. The proposed delivery of 3,500 dwellings over the plan period in Brentwood Borough would also not support the adequate provision of affordable housing that the Borough requires, nor would it provide the level of homes required to support its local economy. The justification for not meeting the full objectively assessed housing needs is not regarded as sufficient. As most of the key evidence is noted as being 'forthcoming' and the Sustainability Appraisal was not completed before the Local Plan was published for consultation, it is questionable as to how these could have been used to formulate the Local Plan's strategy to ensure it is robust and positively prepared. The plan is therefore not in conformity with the NPPF, which states that it should be based on a proportionate, robust evidence base and the justification to Policy S2 does not provide a robust and legitimate reason why Brentwood Council has not sought to meet its objectively assessed need within its boundaries. Basildon Council also raises concerns that the evidence presented does not even support the delivery of Policy S2 and consequently its reduced housing target of 3,500 homes.