brentwood.gov.uk

It is considered that the Brentwood Local Plan will need to be re-assessed in light of the implications of the Government requirement to use the standard methodology with CLG 2014-based household projections.
The plan will need to be revised make provision for a higher housing target and provision for additional housing sites to provide a contingency buffer.
In light of the revised housing baseline figures the SA will need to be reviewed to take account of this requirement.
Technical evidence and the IDP will need to be reviewed and where necessary amended to take account of revised housing target.
The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a further review of the South Essex SHMA that would incorporate the outcome of changes to projections and methodology referred to above. It is considered that as a partner in the joint working that Brentwood Council should include any review of its OAHN in the South Essex review SHMA.

The Pre-Submission Brentwood Local Plan (Regulation 19) fails to take into account the latest Government approach (as published in February 2019) to housing need assessment and use of the appropriate household and demographic data and is therefore considered unsound. The baseline housing target in the pre-submission plan of 350 dwellings per annum is now considered inappropriate and out of date. The upper end flexible target of 456 dwellings per annum is now just above the baseline requirement of 452pa as set out in the standard methodology approach.

It is noted that the previous Preferred Site Allocations consultation of 2018 had been based on the then January 2018 Strategic Housing Market Assessment of Objectively Assessed Housing Need providing a figure of 380 dwellings per annum and 7600 dwellings over the plan period 2013-2033. The OAHN figure was based upon a demographic derived need of 280 dpa uplifted by 30% to take account of market signals and 6% contingency figures to allow for possibility of increase due to new official population and housing projections. There is no employment uplift to these figures. The objectively assessed need was therefore using an approach set out in Planning Practice that related to the NPPF of 2012. The Government had published in September 2017 draft options for a standard methodology. The draft target for Brentwood using this methodology and based upon the 2014 CLG Household Projections was 454 dwellings.

Due to the uncertainty regarding the proposed Government options for assessment of need and pending new demographic projections Brentwood Council plan housing target numbers slightly above the then assessed objectively assessed housing need to allow some degree of flexibility and to make a contingency. Furthermore it is noted that the Council considered that there was potential to accommodate the housing numbers proposed by the Government proposed standardised methodology at Dunton Hills Garden Village. Thurrock Council had sought further clarification as to the actual level of housing requirement and provision that will be included in the local plan and that this can be accommodated within the Brentwood Borough boundary.

The revised NPPF and Guidance of July 2018 stated the standard methodology should be used for calculating objectively assessed need and use of the most recently published household projections. At the time the 2014 CLG based Household Projection formed the starting point with a OAN figure of 452 homes per annum.


In September 2018, ONS published 2016-based Household Projections. Using the standard methodology these projections show a reduced rate of household growth resulting in a reduced housing requirement for Brentwood of 350 dwellings per annum. It is this figure that have been used to assess the OAN for Brentwood in the revised SHMA of November 2018 and incorporated as the baseline housing target figure in the Pre-Submission Brentwood Local Plan (Regulation 19). The Pre-Submission Plan includes a higher figure of 456 dwellings per annum as an upper range to provide flexibility and act as a contingency figure. The total housing provision in the Brentwood local plan is 7,752 dwellings between 2016-2033 (456 dwellings per annum).

However in February 2019 the Government published a revised NPPF, Planning Guidance and response to its consultation on assessing need. It has made clear that the 2016-based household projections should not be used for the standard methodology calculation and the 2014 CLG household projections used instead.

Therefore the Brentwood Pre-Submission Local Plan (Regulation 19) in making an upper provision for up to 456 homes per annum just meets the OAN for housing in the plan period having regard to the current standard methodology. However the baseline housing target of 350 dwellings is now based upon a methodology that does not comply with Government Policy. This calls into question the soundness of the plan but also means the plan no longer provides for a contingency above the OAN and no buffer requirement to meet any failure of the thresholds of the housing delivery test.

The Government's recently published Housing Delivery Test figure for Brentwood indicate that it is required to provide a 20% buffer. As the Housing requirement for Brentwood is now based upon the higher standard methodology figure of 452 dwellings per annum. It is unclear whether Brentwood is able to meet these figures for its five year supply as the Pre-submission plan housing trajectory was assuming 310 dwellings in the early period of the plan.