brentwood.gov.uk

Object

Representation ID: 30026

Received: 29/11/2021

Respondent: Hallam Land Management Ltd

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

The housing requirement figure is not positively prepared as it fails to provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs. Further, it is not consistent with national policy and paragraph 61 of the Framework. Local housing need calculated using the standard method may be relied upon for a period of 2 years from the time that a plan is submitted to PINS for examination. As the plan is unlikely to be adopted prior to 14 Feb 2022 the plan cannot rely upon the previous Standard Method figure from Feb 2020.
As at Nov 2021 LHN based on standard method is 459 dwellings per annum. Although the difference is modest, the proposed housing requirement in MM4 now no longer reflects the LHN as informed by the Standard Method.

Further, it is not an appropriate strategy taking into account reasonable alternatives (i.e. including a housing requirement figure that meets the area’s objectively assessed need). The Council has not justified with evidence why it is unable to meet its objectively assessed needs.

The trajectory within Main Modification 4 and Annexe 1 illustrate that the Plan is not effective and that the housing requirement is not deliverable over the Plan period. Further, it is not consistent with national policy as it does not make sufficient provision for new housing.
The updated trajectory shows there is now a shortfall of 606 dwellings against the proposed housing requirement set out in MM4. Hallam have made previous representations explaining that the plan could be modified to include additional site allocations to address the shortfall;