brentwood.gov.uk

LLLP consider that the Plan requires modification to Policy SP02 to:
* increase the overall housing requirement in order to meet the current Local
Housing Need with a suitable, additional 20% supply buffer;
* extend and increase the housing requirement set out to ensure that there is a
minimum 15 year lifespan for the Plan at the point of adoption;
* remove or significantly modify through the allocation of additional sustainably
located sites the proposed stepped housing delivery trajectory from the policy
so that there is a significant increase in delivery in the early part of the Plan
period; and
* redress the imbalance in housing distribution that over-emphasises the DHGV
site and fails to align with the Plan's stated sequential land use test.

Representations for and on LaSalle Land Limited Partnership
Local Housing Need and Policy SP02: Managing Growth
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Local Housing Need and Policy SP02:
Managing Growth.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Local Housing Need and Planned Requirement
4. The Standard Method assessment for Brentwood Borough published by the
Ministry of Housing, Communities and Local Government (MHCLG) in September
2017 identifies an assessed local housing need of 454 dwellings per annum (dpa).
5. The Brentwood Borough Strategic Housing Market Assessment (January 2018)
was undertaken by consultants PBA in January 2018 and concluded that the
Borough had an Objectively Assessed Housing Need (OAN) of 360 - 380 dpa.
6. The latest The Brentwood Borough Strategic Housing Market Assessment: Part
One (October 2018) was prepared by consultants PBA for the Borough Council.
The latest update considers the housing requirement using the Standard Method
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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updated to a 2019 base date. It concludes at Figure 2.1 that there is an uncapped
need for 365 dpa in the period 2019 - 2029.
7. The updated SHMA's calculation of the Local Housing Need requirement by the
Standard Method uses the 2016-based Sub National Housing Projections (see
paragraph 2.7). These are the latest projections available, however the National
Planning Policy Guidance (February 2019) confirms (Section 2a-005-20190220)
that the 2016-based projection should not be used for the purposes of projecting
the Local Housing Need requirement and that the older 2014-based Household
Projections should be used.
8. If the 2014-based projection is used within the Standard Method and applied with
the appropriate affordability adjustment (based on the latest median workplace
affordability ratio of 11.2) and the increase capped at 40% (as per the NPPG) then
LLLP calculate that the Borough's Local Housing Need is 452 dpa.
9. The Borough's SHMA as a key piece of the Plan's evidence should be updated to
take account of the current NPPG requirements and the stipulated use of the
2014-based household projections in calculating the Local Housing Need. The
latest SHMA (October 2018) identifies the importance of further review prior to the
Plan's submission for Public Examination at paragraph 9.6. LLLP support this
need for further review and update before the Plan is submitted.
10. LLLP are concerned that the Local Plan's Local Housing Need figure (set out at
paragraph 4.13 and in Figure 4.1) of 350 dpa does not represent the appropriate
starting point for establishing the Local Housing Need and must be updated and
revised to 452 dpa in order to accord with the NPPG, particularly the expectation
at Section 2a-003-20190220, that the Standard Method will be used and that any
other method will only be used in exceptional circumstances. LLLP do not
consider that there are exceptional circumstances arising in this case.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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11. The proposed housing requirement of 7, 752 new dwellings over the plan period
set out in Policy SP02 should be increased to at least modified to 9,214 dwellings1
in the 17 year period 2016 - 2033.
12. Furthermore, with regard to LLLP's concern that the Local Plan period will not be
15 years at the date of adoption in accordance with the NPPF (see LLLP's
separate representation regarding paragraph 1.1 of the Local Plan), the Local
Housing Need and the planned housing requirement should be adjusted
accordingly.
Housing Land Supply and Housing Delivery Test
13. Figure 4.1 of the Pre-Submission Local Plan identifies an annual housing supply
buffer of 456 dpa. This figure is understood to be based on the application of a
20% uplift to the 380 dpa annual housing figure set out in the Borough's SHMA
(January 2018 version). The Plan states that the housing supply buffer allows for
additional housing supply to be maintained throughout the plan period.
14. LLLP welcomes the principle of setting a housing land supply position in excess of
the annual housing requirement as a positive and pragmatic approach to meeting
and significantly boosting the Borough's housing supply.
15. As set out above LLLP considers that the Local Housing Need is 452 dpa based
on the application of the Standard Method using 2019 data. It therefore follows
that a 20% uplift to the Local Housing Need (452 dpa + 20% uplift = 542 dpa)
should be applied in order to provide additional flexibility in the supply and delivery
of sites. The additional uplift is also to serve as a safeguard for any further uplift in
the Local Housing Need resulting from future changes to the Standard Method
prior to the Examination and Adoption of the Plan.
16. This additional housing supply is particularly important in Brentwood Borough
given the failure to maintain a five year housing land supply as paragraph 4.18 of
the Pre-Submission Local Plan identifies.
1 The increased figure of 9,214 dwellings is based on the current Local Housing Need of 452 dpa + the 20%
additional supply buffer proposed by the Council which totals 542 dpa. 17 years x 542 dpa = 9,214
dwellings
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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17. Paragraph 4.18 of the Plan also notes that it is not possible to identify a five year
housing land supply capable of delivering the annualised housing requirement.
18. The Government's recently published Housing Delivery Test (February 2019)
confirms a significant and persistent shortfall in housing delivery (only 51% of the
relevant housing target was delivered in the past three years to 2017/18 - totalling
474 dwellings in total), resulting in the Borough needing to add a further 20%
buffer to its housing land supply.
19. LLLP conclude that the Borough's lack of five year housing land supply represents
a failure to meet the requirements of the NPPF at paragraph 67. The persistent
lack of delivery arises from an inability to bring forward sufficient sites and land in
the immediate period and is due to the Council's failure to identify and allocate
housing sites capable of development in the short term.
20. LLLP's land interest at Honeypot Lane in Brentwood is a sustainable development
location (as earlier versions of the Local Plan identified in allocating the site and as
the Sustainability Appraisal continues to demonstrate) and is capable of making an
immediate contribution to the five year housing land supply. This would represent
a significant positive benefit for the Borough in the context of persistent failures to
deliver sufficient housing or to provide a mix and choice of sites.
Stepped Housing Delivery Trajectory
21. Policy SP02 proposes a stepped housing trajectory with an annual average rate of
delivery of 310 dpa for the period 2016/17 - 2022/23 rising to 584 dpa from
2023/24 to 2033.
22. Paragraphs 4.19 et seq. set out the Council's rationale for a stepped trajectory,
noting that Green Belt covers a large proportion of the Borough making it difficult
to achieve a five year land supply. The issue of land constraint has however been
well understood in Brentwood Borough for many years and the failure to put a new
Local Plan in place with adequate allocations of housing land in sustainable
locations has compounded the acute problems that now result in terms of the lack
of a five year housing land supply. Put simply, too little has been done to
positively address the issue.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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23. The Plan's proposed spatial strategy and distribution of growth (which favours
substantial housing delivery in the form of a long-term new settlement at Dunton
Hills Garden Village (DHGV) representing 35% of all the proposed future housing
supply according to Figure 4.2) will not remedy the persistent lack of immediate
and short term housing land supply.
24. There is an inherent risk to longer term delivery and supply of housing as new
settlements and large scale extensions necessarily take many years to be
effectively planned, consented and then to deliver the expected housing. With
such a strategy immediate housing supply shortfalls are not effectively resolved
and the lack of housing supply is compounded in the remainder of the plan period.
25. The NPPF is clear that local authorities should significantly boost the supply of
housing. Brentwood Borough is an area with a persistent record of under-delivery
and housing shortfall. The stepped trajectory represents a failure to plan positively
over many years. It artificially restricts the supply of housing land and continues to
risk a mismatch with meeting housing needs and the wider principles of
sustainable development as well as the Local Plan's own stated strategic driving
forces. It undermines the national policy of significantly boosting the housing
supply.
26. The housing delivery trajectory should take a far more positive and proactive
approach to meeting, in full, the housing needs arising, including the extant
backlog caused by the lack of a five year land supply.
27. The barrier to delivery of sufficient sites in the first five year period is caused by the
lack of an appropriate mix and range of housing allocations in sustainable
locations (including LLLP's land interest at Honeypot Lane, Brentwood) and the
Council's spatial strategy that pursues housing development through Green Belt
release to create a standalone new settlement that will inevitably take far longer to
come forward and be in a position to contribute to the Borough's housing land
supply.
28. The stepped trajectory is not effective in meeting housing needs, is not positive or
sufficiently proactive and essentially pushes back the delivery of adequate levels
of new housing with no guarantee that an increased level of completions will be
secured in the longer term.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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The Sequential Approach to Housing Location
29. The distribution of future housing growth is apportioned through a sequential land
use test according to paragraph 4.22. The test priorities growth based on
brownfield and land in urban areas first, followed by brownfield land in the Green
belt.
30. Figure 4.2 sets out the results of the sequential approach to allocating housing
land which indicates inter alia: that 15% of housing is to be allocated on brownfield
land within the Brentwood urban area; 7% on brownfield land elsewhere; and
some 16% of Green Belt land at the edge of Brentwood urban area. 35% (2,700
dwellings) are proposed to be allocated to Dunton Hills Garden Village.
31. LLLP have two principal concerns with the distribution of housing land resulting
from the use of the sequential approach:
* the approach under-values the importance of existing settlements, such as
Brentwood, to provide sustainable locations for future housing growth,
including use of greenfield and Green Belt land within and adjacent to the
urban area. Such locations, including LLLP's land interest at Honeypot Lane
in Brentwood, represent sustainable development locations capable of
comprehensive integration with the existing urban fabric; swift delivery to meet
evident housing needs; and contribution towards community facilities and
services as appropriate. It is evident (as the Sustainability Appraisal identifies
reasonable alternative sites, including Honeypot Lane, Brentwood) that there
is a greater opportunity for development in and adjacent to Brentwood than
the Plan currently makes allowance for.
* having failed to maximise the opportunities for existing higher order existing
settlements like Brentwood (as set out above) the sequential approach then
directs much of the Borough's new residential development to DHGV an
undeveloped, greenfield/Green Belt location that is unconnected to the
existing settlement pattern or transport infrastructure and which would involve
very extensive loss of Green Belt land. The proposed strategic allocation at
DHGV does not align with the sequential approach given the Plan's failure to
maximise development opportunities in or at the edge of existing settlements
first and foremost. In addition, LLLP are concerned that development of
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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DHGV will have significant adverse effects including, inter alia, landscape
character and visual impact, flood risk, highways capacity/connectivity and
ecology and that these effects are, at this stage, largely untested or evaluated
in any detail.
Conclusions
32. LLLP conclude that:
* the Local Plan's stated housing need figure does not represent the appropriate
starting point for establishing the Local Housing Need in accordance with the
Standard Method and the NPPG; and is an under-estimate of the housing
required in the Borough;
* the housing requirement should be increased to at least 9,214 dwellings in the
period 2016 - 2033;
* there is a persistent lack of a five year housing land supply contrary to the
NPPF and that the lack of delivery of housing arises from the lack of sufficient
sites and land available now and in the short term;
* the proposed stepped housing delivery trajectory proposed in Policy SP02 at
point A is not consistent with the NPPF; is not justified in terms of meeting an
acute and evident shortfall in housing land supply; and does not represent an
effective or positive strategy;
* the spatial distribution strategy, including a significant reliance upon DHGV to
bring forward 35% of all the future housing will not address the acute shortfall
and lack of five year housing land supply. The barrier to delivery of sufficient
sites in the first five year period is caused by the lack of an appropriate mix
and range of housing allocations in sustainable locations (including LLLP's
land interest at Honeypot Lane, Brentwood).
33. As concluded from the matters set out above, LLLP object to Policy SP02. The
policy is not sound as it is not justified, effective, positively prepared or consistent
with national policies.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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Modifications Required
34. LLLP consider that the Plan requires modification to Policy SP02 to:
* increase the overall housing requirement in order to meet the current Local
Housing Need with a suitable, additional 20% supply buffer;
* extend and increase the housing requirement set out to ensure that there is a
minimum 15 year lifespan for the Plan at the point of adoption;
* remove or significantly modify through the allocation of additional sustainably
located sites the proposed stepped housing delivery trajectory from the policy
so that there is a significant increase in delivery in the early part of the Plan
period; and
* redress the imbalance in housing distribution that over-emphasises the DHGV
site and fails to align with the Plan's stated sequential land use test.