Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 23667
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
Brentwood's most recent five-year housing land supply, reported in the Five Year Housing Land Supply Statement 2018, is 4.1 years; however, this is predicated on outdated requirement, therefore, the actual housing land supply is considerably less. The HLSS includes sites without detailed planning permission and without evidence they will be delivered within five years, these cannot be considered deliverable for the purposes of the five-year housing land supply. The acute housing land supply shortage underlines the importance of allocating sites that can deliver early in the plan period and avoiding over reliance on large strategic sites.
Aditional non-strategic sites are required. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings).Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.