BBC's recommendation is not “robust” and despite their claim otherwise the Government have not dictated the number: it is BBC's choice from a range of options available to them. BAG believe that the proposed OAN of 16,000 homes (including 2,500 for Billericay) goes far beyond the figure needed to satisfy the National Planning Inspectorate.
Our conclusions are based on detailed analysis of BBC's “Housing Growth Topic Paper” and other documents which look at different scenarios and projections - such as “Natural Growth” and various “Migration” based projections. BBC has chosen to reject these scenarios instead choosing a far higher number based on an “Economic Scenario”.
BAG WHITE PAPER UPDATED
Our latest revision includes a new, vitally important section showing that Building on Green Belt is a choice, not an obligation. Basildon can choose NOT to build on Green Belt.
No one from Basildon Borough Council has publicly (or privately) challenged anything in our previous versions. Absolutely no one. However, Borough Cllr Dr Richard Moore, responsible for Planning seemed to be echoing our calls for a revision of the numbers in December : “I can confirm that this council …. is considering revisiting the Objectively Assessed Needs … It could in turn inform whether the housing targets for south Essex local plans need to change” whilst Leader of the Council Phil Turner has said that a new Council official has been charged with challenging the numbers
A few months ago we released our White Paper showing that Basildon Borough Council’s “Objectively Assessed Need” (OAN) of 16,000 homes was unjustified. Our newly updated version has just been sent to all Borough Councillors, our MP and Prospective Parliamentary Candidates. It’s worth noting that no one from Basildon Borough Council - political or professional - has either publicly or privately challenged anything in our White Paper. Absolutely no-one.
This latest version includes new or enlarged sections including one on Affordability where we show that Basildon Borough Council can meet, or even exceed, its Affordable Housing need without requiring a high OAN.
- The OAN of 16000 new homes by 2031 goes far beyond the figure needed to satisfy the National Planning Inspectorate.
BAG’s argument is based on detailed analysis of BBC’s Housing Growth Topic Paper (HGTP) and other documents. The HGTP looks at scenarios and projections of various types such as Natural Growth, Migration and others.
BBC has chosen to reject these scenarios. They have instead chosen to utilise a much higher Economic Scenario. This choice is made despite the flawed assumptions built into the scenario, the social consequences of these flaws and the criticism of this approach by the TGSE Partnership and their planning consultants.
2. The Framework and Guidance governing LA plan-making give Authorities considerable lee-way. There are several legitimate ways to reach an OAN.
3. An LA can submit an argument for a Housing Target lower than its OAN, citing constraints such as infrastructure and Green Belt.
4. BBC takes an average from lower, more up to date 2011 census data as well as higher, less robust 2008 data. Giving these datasets equal weight inflates the OAN. Note: BAG’s research only references the 2011 figures, an approach we share with Brentwood Borough Council whose OAN is based on 2011 figures only.
5. Basildon’s ‘Natural Growth’ gives rise to a requirement of 8900 new homes.
6. Comparing this figure to the 16000 minimum shows that 44% of new homes will be provided for new arrivals from neighbouring boroughs, London and beyond.
7. Under the NPPF, BBC could not submit an OAN based on Natural Growth alone but must take past migration trends into account. BBC examined a number of Migration-based projections in the 9700-13300 range, mostly at the lower end. BBC could have selected one of these figures but chose to go further.
8. The proposed OAN is based on an Economic Scenario. Such scenarios take a broad estimate of how many jobs might be created in the borough over the next 20 years as their foundation.
- They deploy a circular argument. In one document BBC argues that they require further new homes to house the outside workers necessary to fill these jobs – while in another document they argue that the large jobs total is only sustainable and necessary as it is assumed a very large number of houses will be built.
- In determining the number of new homes required to house the new workers, BBC makes the assumption that there is no slack in the Basildon labour market despite very high levels of unemployment, economic inactivity and other measures. Measures which will remain the same if and when the jobs are delivered.
- A figure of 790 pa appears in graphs and recommendations and it is rounded up to 800pa in the local Plan, that’s 16000 over the Plan period.
- The assumptions behind the chosen Scenario are provided, but the formulae are not explained and they are only available at a cost of £600.
10. There is no evidence that BBC considered a Windfall Allowance which would alleviate pressure to designate countryside sites.
1. Only Migration based Scenarios should be considered as these have been shown to provide sufficient labour to sustain economic growth and are in line with the NPPF.
Note: A lower OAN and\or Housing Total would mean that a lower and more achievable jobs target could be set. This would allow BBC to:
- Spare Green Belt land round Basildon from industrial development
- Deliver a far better workers\job ratio than the current Plan.
- Spare all of the Green Belt and other open land, around all three towns, from residential development.
3. Consideration should be given to the non-binding recommendation produced by TGSE. Castle Point adopted the recommendation made to them as their OAN.
4. Consideration be given to the inclusion of an allowance for Windfall Sites in the overall OAN.
5. In light of infrastructure and Green Belt constraints, that consideration be given to a Housing Target lower than the OAN.
Who have we sent it to?
These groups include :
- Our local MP, John Baron
- The Leaders of the Conservatives, UKIP, Labour, Liberal Democrats and Independent Labour on Basildon Borough Council
- All Councillors on Basildon Borough Council
- Billericay Town Council
- South Green & Great Burstead Village Council
- Labour, UKIP and the Liberal Democrat Prospective Parliamentary Candidates for Basildon and Billericay (there may be others - if so, please let us know !)
- Local newspapers & radio stations
- Our supporters - via an extensive Social Media campaign on Facebook and MailBAG:
- Other Action Groups with a request that they also write to Councillors and their local MPs
What can you do to help?
- Write to your local MP. For Basildon and Billericay it’s Mr John Baron, House of Commons, London SW1A 0AA. Or email him at the following address : John.Baron.MP@parliament.uk . Remember to be polite, keep your email or letter short and sweet - but let him know what you think.
- Write to your Basildon Councillor (see table below)
- Email your local paper. 250 words maximum. Please remember to include your name and address. Billericay Gazette: editorial@Gazettenews.co.uk, The Echo: firstname.lastname@example.org and Yellow Advertiser: email@example.com
- Register your support with BAG. Email us with your views and comments to info@BillericayActionGroup.org.uk
- Look out for our newsletters and flyers around town
- Like us and Share our Facebook posts: Facebook.com/BillericayActionGroup
- Make a donation. We don’t spend much but we do have incidental expenses - e.g. website hosting, newsletter production. Go to BillericayActionGroup.org.uk/donations
If possible please do more than one of the above. The more feedback the politicians and press get, the more they’ll realise how important this issue is to residents.