Frequently Asked Questions
FOCUSSED CHANGES CONSULTATION OCTOBER 2019
What is the 'Addendum of Focussed Changes to the Pre Submission Local Plan' consultation?
Brentwood Borough Council has an addendum of focussed changes to the Brentwood Pre Submission Local Plan (Regulation 19, February 2019). This proposes some changes to housing numbers on 5 sites in the Pre Submission Local Plan. The proposed amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth. The Council are consulting on these changes.
How do I comment on the Addendum of Focussed Changes?
Representations (comments) may be made electronically or in writing. Anyone wishing to make comments are encouraged to use the Council's online consultation system which can be accessed via www.brentwood.gov.uk/localplan.
Alternatively, comments can be made in writing by email to firstname.lastname@example.org
What if I have commented before?
The Council welcomes comments on these focussed changes.
If you have made comments to the Pre Submission Local Plan there is no need to repeat what has been made before as these remain relevant, they are being fully considered and will be submitted to the Planning Inspector for their consideration during the Local Plan Examination in Public.
The Council will not accept comments on the Pre Submission Local Plan that are not related to the focussed changes or that repeat a representation already submitted by that person.
Where can I read comments made before on the Local Plan?
All representations (comments) made on the Pre Submission Local Plan (Regulation 19) consultation (February 2019) have now been published online via the Consultation Portal. This can be accessed via www.brentwood.gov.uk/localplan.
PRIVACY AND DATA PROTECTION
What personal details do I have to provide with my comment?
The Council has a duty to collect your information under the Town and Country Planning (Local Planning) (England) Regulations 2012 and any comments you make will be a matter of public record. Please note whilst all personal contact details will be treated as confidential, each comment and the name of the person who made them will be featured on the Council's website. We cannot take anonymous comments.
Your comments, including your name, address and contact details will be shared with the Planning Inspectorate and Programme Officer. Please advise us if you do not wish this information to be shared, however this means that your comments will not be accepted.
By submitting a comment, you are agreeing to the above conditions.
GENERAL QUESTIONS AND THE PLAN-MAKING PROCESS
What is a Local Development Plan or Local Plan?
The Local Plan will be used to help shape the direction of future change within the Borough. Among other things, the Plan influences where new homes, jobs, infrastructure, local facilities and green space will be provided. It will set a strategy for how the needs of the Borough can be met, while ensuring that our environment and local character are protected and enhanced.
Why should I comment? How will my views be taken into account?
Once the Plan is officially in place, development proposals over the next 15+ years will need to follow the Plan’s policies. The Plan will help shape the design and location of future development, among other things. It is therefore vital that your views are heard so that the Plan can be informed by local aspirations.
At the end of the consultation the Council will analyse all responses and publish a report summarising the key issues. Representations along with the plan and associated evidence will be taken into account through the examination process presided over by an Independent Planning Inspector.
What has happened to the comments I have made on previous consultations?
Comments made on previous consultations, including Preferred Options (2013), Strategic Growth Options (2015), Draft Local Plan (2016), and Preferred Site Allocations (2018) have been considered and summarised in our consultation statement documents. These are available to view on the Work So Far webpage. All comments made are available to view on our Local Plan Consultation Portal.
What type of development will be built on the sites proposed in the Local Plan and what will it look like?
The proposed allocated sites for residential and employment development have been identified as a result of a detailed site selection process. All sites which were put forward as part of the call for sites have been assessed to determine their suitability, deliverability, and viability. Planning applications for these sites will need to be in accordance with the planning policies found in the Local Plan. Developments will need to be in keeping with the surrounding environment and character of the area.
What about localism?
The Council recognises the changes the Government has made and the responsibility that has been placed on local authorities to determine housing targets at a local level. Consultation provides an opportunity for local people to have their say. The Localism Act 2011 also enables Neighbourhood Plans to be prepared by local communities, although these must be in accordance with up to date Local Plans.
What is the difference between Regulation 18 and 19?
Regulation 18 stages explored several different policy options, allowing for ‘open’ questions and a wider remit for input during the consultation phases. Under Regulation 18 the Council consulted on Issues and Options (2009), Preferred Options (2013), Strategic Growth Options (2015), Draft Local Plan (2016), and Preferred Site Allocations (2018).
As the plan-making process continues, the number of policy options are refined and become more focussed. This reflects the purpose of Regulation 19 as a planning document with specific policy recommendations for the Borough, resulting in more formal and technical questions in the consultation process. These questions relate to the four Tests of Soundness and whether the Local Plan is compliant with relevant legislation. The representation form focuses on three core areas – is the Plan sound, does the Council adhere to the Duty to Cooperate, and is the Plan legally compliant. Under Regulation 19 the Council has published the Pre-Submission Local Plan (2019).
What is meant by sound and legally compliant? How will I know if the Local Planning Authority adhered to the duty to cooperate?
Soundness: Local Planning Authorities must prepare a Local Plan based on relevant and appropriate evidence base. They are required to publish these documents on their website. The evidence used to develop the Brentwood Local Plan can be found on the Council’s website under Evidence Base.
Duty to cooperate: Throughout the plan-making process discussions have taken place with various statutory consultees and neighbouring authorities. A summary of these meetings can be found within the Duty to Cooperate Statement, published as part of the Regulation 19 consultation. This is a live document and will be updated prior to being submitted to the Secretary of State.
Legally Compliant: Local Planning Authorities must prepare a Local Plan which adheres to the requirements as set out in the National Planning Policy Framework (NPPF), planning practice guidance, and other relevant planning regulations & legislation.
What are the Tests of Soundness?
The Tests of Soundness are set out at paragraph 35 of the National Planning Policy Framework (NPPF). There are four tests:
a) Positively prepared: providing a strategy which as a minimum seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and consistent with achieving sustainable development
b) Justified: an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective: deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with nation policy: enabling the delivery of sustainable development in accordance with the policies in the NPPF
How many homes will be built? Why do we need so many houses?
Currently the Borough’s need has been calculated to be around 456 new homes a year, which is approximately 7,700 over 17 years (2016-2033).
The Government introduced a standardised methodology for calculating local housing need alongside the NPPF in July 2018. This calculates local housing need and is based on household projections published by the Office for National Statistics, applying an uplift for areas considered to need more affordable housing on the basis of high house prices.
In preparing the Local Plan the Council has continued to update its Strategic Housing Market Assessment SHMA (Part 1) in identify local housing need from which strategic policies have been informed. The Standard Method number for Brentwood, as calculated in the SHMA following current national guidance (2018), is 350 new homes per year using the annual average growth over years 2019-2029.
The Council is committed to planning positively for new homes to help significantly boost the supply of housing to meet the needs of the area. Taking into account the government’s ambitions for housing growth, it is appropriate to consider the government’s response document to the revised NPPF, and its intention to adjust the standardised methodology to ensure that the starting point in the plan-making process is consistent with ensuring that 300,000 homes are built per year by the mid-2020s nationally.
Mindful of the above and to provide flexibility in the supply of housing sites, helping boost delivery, the Council proposes to allocate development sites in the Local Plan to provide an uplift from the 350 dpa housing requirement.
The Council is committed to provide a housing supply buffer. The buffer allows for an additional housing supply in the borough to be maintained throughout the Local Plan period and is an approach supported in national planning guidance. When taking the supply buffer into account, provision is made for a total of 7,752 new homes in the period 2016-2033; an annualised housing target of 456 new homes per year.
When are the homes going to be built?
Once the Plan is adopted the length of time before homes are built is dependent on the nature of each individual site. Smaller sites could be developed within five years or less. For larger sites such as strategic allocations, the time taken for designs to be developed and applications to be dealt with can be longer. It could be five to ten years before any work begins on site, and up to five years or more from when construction starts until all homes are built. However, large scale sites are often developed in phases, which could minimise the impact of ongoing construction work to those living in surrounding areas.
What happens if the Plan does not provide for 7,700 homes?
If the full housing need is not planned for there is a risk that development will occur in an unplanned way in locations around the entire Borough. This will give developers a basis to challenge refused applications within the Green Belt and elsewhere.
Furthermore, Brentwood was sent one of the 15 intervention letters sent from Central Government. The Council has responded to the letter identifying the fact that Brentwood is committed to developing a Local Plan. Central Government will be monitoring the progress of the Local Development Plan closely. It is important that the Council adheres to the Local Development Scheme which outlines the projected time frames for completing the LDP.
Local Authorities are required to have a “Five Year Supply” of land, to help boost the national supply of housing. Without this local planning policies will be considered out of date. Developers can exploit this by arguing that the Local Plan is not in accordance with national policy if it does not meet housing requirements. This will put the Borough’s environment in a vulnerable position, as planning decisions may then be made at a national level.
Why don’t we just build where nobody lives, so development doesn’t affect anyone?
As part of the plan-making process the Council has to consider the social, environmental and economic sustainability of individual sites, as well as to what extent particular sites are in line with the Plan’s vision and strategic objectives. Infrastructure is a key concern for us. Allowing for managed development around existing settlements will enable financial contributions from developers to provide better economies of scale. These contributions will go towards improving valuable existing community infrastructure, such as schools and doctors surgeries. This means existing communities can benefit from these improvements.
Has the “village feel” of where I live been considered, as any development would change this?
The Council recognises the value of the high quality natural environment enjoyed around the Borough. This is particularly important around villages, and so a strategy is proposed to maintain local character. The “hierarchy of place”, which takes into account the scale of existing settlements, has been one of the considerations which sites have been assessed against. Policies in the Local Plan are not just focused on meeting development needs, they also protect our natural environment and enhance our built environment. Getting the balance right between meeting development needs and retaining local character will sometimes impact our natural environment, but there will also be opportunities to improve surrounding green space and access to the countryside.
Why do we need to provide so many Gypsy and Traveller pitches, why are they near people’s homes?
The Council has a duty to provide for the needs of all the Borough’s residents and provide for them equally. This includes allocating new Gypsy and Traveller pitches as well as housing. Locations near existing or new settlements have been proposed to minimise the impact on things such as Green Belt in the Borough, as also needs to be considered with housing site options.
How much affordable housing will be provided and where will it go?
The Council will seek to secure levels of affordable housing in new developments in line with national policy and informed by local evidence. This is currently around 35% of dwellings in new developments. The Council will ensure that affordable housing is distributed fairly across the Borough.
Why is the Council allowing offices to be converted to residential? Is this employment use being replaced?
Offices can be converted to residential as permitted development as per the Town and Country Planning (General Permitted Development) Order 2015. The Local Plan is required to meet identified future employment land needs through identifying suitable allocations.
Why is the Council proposing to build on all the car parks in Brentwood, will this parking be replaced?
The Council has determined a hierarchy in regards to development which prioritises developing brownfield land to limit the amount of sites within the Green Belt. Sites which are currently used for parking which has been identified for possible development would be required to include a design where parking is still provided on site, most likely with parking provided underground with development on top. This will ensure there is no loss of parking on site.
Why is the Council proposing to build on greenfield sites? There must be enough brownfield sites to meet housing needs.
The Council has prioritised development on brownfield land. However, this would only accommodate approximately 20% of development needs. Therefore, the Council must look at other potential sites within the Borough, including greenfield sites to meet full development needs.
How can the Council be allowed to build on Green Belt land? Can’t we just build everything on brownfield land?
The Council’s preferred approach has always been to build on brownfield land in existing urban areas. However, brownfield land alone does not meet fulfil the requirements we must meet. We need to allocate sites for 7,700 homes, but the capacity of available brownfield land in the Borough is only approximately 1,700 homes.
As part of the Local Plan process it is possible for Councils to consider Green Belt boundaries. Other Local Authorities that have failed to meet their full need have been found “unsound” at examination, which is expensive, prolongs the plan-making process and leaves the Council vulnerable to uncontrolled development. Sites in the Green Belt have been proposed to help meet future needs for homes and jobs in sustainable places.
Policies are also in place to protect the Green Belt. 89% of the Borough is currently within Green Belt. Proposals to meet our full housing needs using limited Green Belt would reduce this by just 2%.
What impact will population increase have on local services?
An assessment of key services such as education and healthcare is made in the consultation document where development is proposed. The Council will continue to work with partners to ensure that new development enables investment in services wherever a deficiency is identified.
Has flood risk and water supply been considered?
Evidence for flood risk, water supply and waste, has been considered as part of the proposals for development in the 2018 Preferred Site Allocation document. This particular part of the evidence base is being reviewed to provide more up-to-date information and the Council will continue to work with the Environment Agency and water suppliers to understand the issues.
How will local services and infrastructure cope?
All development will need to meet minimum infrastructure requirements. Transport impacts of all proposals will need to be assessed to ensure that vehicle access and traffic generation do not result in unacceptable levels of congestion on unsuitable roads or in environmentally sensitive areas. Developers are required to make contributions to the Council as part of all new developments. This money is put towards community infrastructure to ensure that services can be improved or provided as necessary, such as schools and doctors and other facilities.
Surely new infrastructure is needed now before the development takes place?
The nature of providing new infrastructure as a result of new development means that often it can only come forward after a planning permission has been granted. Where appropriate infrastructure is required as a result of proposed development contributions will be sought from developers to ensure this is delivered.
DUNTON HILLS GARDEN VILLAGE
What is a Garden Village?
A standalone development, following principles to create neighbourhoods with housing for all tenures (social, rent and private) with enhanced natural environments, local facilities and infrastructure. The concept does not just relate to the design, but is also about ensuring engagement with local communities from early stages, and aiming for long term local stewardship.
Why is Dunton being considered for such a large scale development?
The strategic site at Dunton Hills Garden Village has been identified separately to other development allocations in order to deliver a significant amount of growth to meet local needs, specifically new homes with supporting jobs and retail. In line with objectives and policies in the Draft Local Plan, strategic sites also provide a level of development that achieves the necessary critical mass to bring along supporting services, facilities and infrastructure. Much of the Borough’s infrastructure and services are at capacity, and so in order to deliver growth and not over-burden already stretched services, strategic development sites allow us to deliver new communities with supporting facilities.
Will the Dunton Hills Garden Village development just contribute to urban sprawl?
The proposals for a garden village at Dunton would constitute a new standalone village settlement. There are proposals in the Basildon Draft Local Plan to develop areas near to the Borough boundary which will need to be taken into consideration.
How long would the proposed development at Dunton take to materialise?
With a proposal of this size it could take a number of years for development to begin. However, it is anticipated that at least 2,770 homes can be delivered within the plan period by 2033, with the remainder being delivered in the next plan period.
Why can't all of the housing be proposed in Dunton Hills Garden Village?
The Council is planning for 7,700 new homes over the plan period (2013-2033). Dunton Hills Garden Village has an identified capacity of around 4,000 homes with a minimum of 2,770 to be delivered in the plan period. Whilst this represents a large proportion of the identified need there is still a requirement to ensure the housing needs across the whole Borough is addressed by identifying suitable allocations within or adjoining existing settlements.
WHAT HAPPENS NEXT?
How long will it be until the Plan is finally adopted?
Following consultation on the Addendum of Focussed Changes to the Pre Submission Local Plan (Regulation 19), the Plan, consultation responses (including representations to previous Regulation 18 and Regulation 19 consultations), and related evidence base will be submitted to the Secretary of State. The Planning Inspectorate will then appoint a planning inspector to conduct an Examination in Public. It is expected that submission will be towards the end of December 2019 as indicated in the Council’s Local Development Scheme timetable (LDS). It is anticipated that the Examination in Public will take place during the spring 2020, specific dates to be determined following submission.