Object

Representation ID: 14513

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

Para 5.36 - The notion that Brentwood is a self-contained district really lacks credibility. The local plan and the OAN report attest to the district's strong inter-connectivity with London and Essex. The district is located within the London Arc as Figure 2.3 illustrates. Figure 8.1 illustrates the economic and transport links. The construction of Crossrail will only increase this connectivity with London and Essex (Chelmsford especially).

We consider that Brentwood should be considering a joint-SHMA based on an HMA with Basildon, Chelmsford and Epping Forest. Figure 2.3 shows strong commuting flows with Basildon and Chelmsford. An HMA based on this area could use a SHMA that applies consistent assumptions relating to migration to and from London, reflecting the Mayor of London's demographic assumptions that have shaped the London Plan. The local plan must make allowance for above trend household formation in Brentwood as a consequence of the London Plan.

Comment

Representation ID: 14514

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

The local plan would benefit from a more detailed discussion of the duty to cooperate issues. While we acknowledge the statement in paragraph 2.10 of the OAN report that 'no potential HMA partner has requested that the Borough help meet their unmet need', this situation may change over the next few months as more of the Essex local authorities bring forward new plans.

Comment

Representation ID: 14515

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

It is unclear from the local plan and supporting documentation how the Council has engaged with the Mayor of London and the London boroughs on the matter of migration. The inspector for the London Plan, in his report (dated 18 November 2014), does refer to this effect. He notes that the Mayor's SHMA "includes assumptions relating to migration...likely to be material to the preparation of local plans outside London."

Paragraph 2.10 of the OAN report does acknowledge the potential problem of London but states that it is unable to assess the implications of the Mayor's new plan until this adopted. The report therefore implies that the OAN figure of 360 dpa is very much a provisional one.

Object

Representation ID: 14516

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

Para 5.37 - The OAN figure has been prepared without the benefit of the DCLG 2012 Household Projections and therefore the Council is likely to need to do more work on the OAN, taking into account more recent household projections as well as the implications of the London Plan.

The 2012 SNPP does not provide adequate compensation for the Major's migration assumptions. Moreover, the projections are trend-based so there would still need to be an increase in supply above the trend level in Brentwood to compensate for potentially higher numbers of people moving to the borough as well as fewer people leaving to live in London.

Object

Representation ID: 14517

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

Para 5.37 - Un-persuaded by the argument that the ONS has built-in a higher migration propensity. There is no evidence to support this claim. We note that neighbouring Basildon Council is not advancing this claim. Instead it has increased it OAN above the 2012 SNPP. We consider that Brentwood should do likewise.

Even if migration with London is accounted for by the latest projections, there is still the problem of London's unmet need.

Even if there is no agreement in place between London and the local planning authorities of the south east as to how this issue will be dealt with, it does not mean that the issue will go away. The paucity of supply in London relative to the need will mean that relatively more affluent households will move to Brentwood. As a consequence the local affordable housing need will probably increase more sharply than the SHMA evidence currently suggests.

Comment

Representation ID: 14518

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

We agree that a figure of 330 hpa should be adopted as the starting point for Brentwood (as established in paragraph 5.30 of the OAN report). However, there is a possibility that the projection favoured by the Council is still just a trend-based projection, albeit one showing increased net internal migration, but one that would still require adjustment upwards to compensate for the Mayor of London's own demographic assumptions.

It is not entirely clear from the OAN report how the Council alighted upon the figure of 362 dwellings per annum (dpa) as being representative of the OAN.

Comment

Representation ID: 14519

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

We note paragraph 5.69 [of OAN Assessment 2014]. Providing jobs in line with the past long-term trend would generate a need for 411 dpa. To our mind this would represent a more appropriate OAN for Brentwood as it would align housing supply in accordance with the long-term trends in the economy. It would also provide more by way of contingency just in case the Council's assumptions relating to migration from London prove to have underestimated the problem (e.g. the 2012 SNPP does not include a higher migration propensity for Brentwood).

Comment

Representation ID: 14520

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

The OAN Assessment 2014 considers that no adjustment for market signals is warranted because prices in Brentwood are no worse than the national and local indicators. We question the Council's decision not to adjust its supply to help counter issues of affordability in view of the observation in the draft plan about the problems of housing affordability.

Comment

Representation ID: 14521

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

The OAN report is not a SHMA. It does not include an assessment of the affordable housing need. We would expect to see an updated assessment of the OAN, including the need for affordable housing, through a SHMA. Evidence of a high need for affordable homes is evidence of strain in the local housing market. In turn this would suggest the need for an increase in supply above the trend. It is questionable whether the trend-derived figure of 362 dpa does represent the full OAN and whether it would provide the 'significant boost' to supply that is sought by the Government through the NPPF.

Comment

Representation ID: 14522

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

We note the Council's wish to adopt the nationally described space standard through the new local plan. The Council will need to justify this by meeting the tests set out in the relevant section of the NPPG. The tests are ones of necessity, viability, and the impact on affordability including the supply of starter homes.