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.
It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

The overall approach of the Brentwood Local Plan remains the same as the previous consultations of the draft 2016 plan and 2018 Preferred Site Allocations consultation with Brentwood Council proposing to accommodate all of the identified objectively assessed need for housing and employment within the Borough Boundary during the plan period. However the period of the plan now covers 2016-2033. The Local Plan includes a revised housing requirement of 7,752 dwellings (up from 7,240 dwellings in the 2016 Local Plan consultation and up from 7600 dwellings in the 2018 consultation) and a provision of approximately 47.4ha of net employment land.

Brentwood Council intends to plan for housing numbers and land supply above its assessment of identified Objectively Assessed Housing Need of 350 dwellings per annum to allow some degree of flexibility and to make a contingency for future housing requirements. Furthermore it is noted that Brentwood Council considers that there is potential to accommodate the housing numbers proposed by the Government standardised methodology with further capacity at Dunton Hills Garden Village.

Thurrock Council seeks further clarification as to whether level of growth proposed for Brentwood could be accommodated in the plan in light of the concerns with regard to the assessment of housing need being required to be altered to meet Government policy at 452 dpa and due to the current concerns regarding the proposed strategic location at Dunton Hills Garden Village to accommodate this growth. Thurrock Council would wish to further engage with Brentwood Council to discuss other alternative options in the borough including at West Horndon.

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.

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.

* 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.

It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.