Draft SHMA Response

Draft SHMA

An objective assessment of the GL Hearn SHMA for Guildford

Introduction

The GL Hearn SHMA combines a post-NPPF analysis of Objectively Assessed Need (Section 4) with much of the content of an old style SHMA (Section 5). Apparently a few SHMAs are done this way but this approach makes it somewhat confusing in respect of demand and need.

From experience, housing consultants tend to focus on the Section 4 material in their reports. On the other hand, GL Hearn don’t actually make massive use of all their Section 5 analysis in their final conclusions.

It is intriguing as to why the jobs/employment method of assessing Objectively Assessed Need (570 dwellings per annum) was lower than the demographic projections (670 dwellings per annum). In most areas demographics consultants find the reverse is true because a shortfall in working age residents means that extra housing is required to entice in additional workforce to meet predicted jobs growth.

Clearly, therefore, the demographic projections for Guildford must contain an extraordinary share of additional working age residents. This is certainly borne out in the Office for National Statistics (‘ONS’) population projection data.

In the face of such an anomaly it is important to try to establish what is actually happening and what might account for such apparently skewed population data.

The Experian employment growth data for Guildford (set out in Section 2.66 of the Draft SHMA) shows employment growth from 1998 to 2012 of 14,900 employees.  This analysis seems to suggest (without actually stating it) that the 1998 employment base was around 70,000 and that the overall growth over fourteen years was around 20% (equating in compound terms to around 1.3% per year).  This is hardly a stellar rate of growth and GL Hearn suggest that the 85,200 jobs in Guildford in 2011 will grow to 99,500 by 2031 – an average annual growth rate of 0.57%.  Clearly Guildford has managed to achieve higher growth within the current target levels for incremental increases in housing stock.

On the basis that it cannot be employment alone that leads to a suggested NEED for substantial numbers of new housing units, The Guildford Society has analysed the detailed Sub-Regional National Population Profile projections (‘SNPP(2011)’) – source: ONS – by age, and compared the Guildford growth data with England average. There is a massive growth in the 19 to 30 age groups in Guildford compared to benchmark areas.

The housing number that the SHMA arrives at is certainly heavily influenced by what is happening in the 19 to 30 year olds and The Guildford Society is concerned about the robustness of these government projections.

Demographic analysis stresses the importance of exploring the 19 to 30 year olds issue in more detail.

There appears to be some quirk in the (migration) data from the last five years that is now being carried through into the projections.

We first looked at the SNPP(2011) data and mapped the various age cohorts from 2011 across the subsequent years to 2021 (see below).

SHMA-Fig01

This mapping shows very tight data sets across most age-group-cohorts but a major anomaly at age eighteen which takes several years to work through the remainder of the population.  This means that the lasting effect of the anomaly adds somewhere approaching 1,000 extra heads to each year’s population.

Doing some basic mathematics suggests that the population growth is, therefore, around 10,000 overstated for the period of SNPP(2011) from 2011 to 2021.  This translates to a reduction in housing need of 4,132 homes over the ten year period or 413 homes per year.

Based on Option 1 of the How Many New Homes? document this would suggest a required target of 704 LESS 413 homes per year EQUALS 291 homes per year.

The potential overstatement of projected population growth would have a consequent impact on the analysis carried out by GL Hearn and led to The Guildford Society looking deeper into the figures.

GL Hearn would no doubt point to different household formation rates and household size amongst different age cohorts and say it is too simplistic to dampen down by a single average household size.  Whilst not disputing such a response, it is reasonable to seek to have the SHMA conducted on the basis of good data, challenged and qualified to meet local needs (as well as fulfilling regional expectations).

Irrespective of such a response, therefore, the key point is that there is a stark difference in the population growth in Guildford amongst younger age cohorts when compared to most other areas.

Guildford Borough Council in its review of the draft SHMA needs to demand that GL Hearn robustly investigate for the student population and for the statistical blip in the migration pattern for younger age groups in the period 2005 to 2010 (this is the period SNPP uses to base its migration projections) and the extent to which these are now being carried forward into the current household projections.

From an untrained eye, the indexed data from 2002 to 2010 shows a similar blip at student age

Comments on the Draft SHMA

Introduction

1. Definitions

The NPPF gives no definition of the words ‘needs’ or ‘demands’. It uses the word ‘needs’ in

Para 14:

Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

–– any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or

–– specific policies in this Framework indicate development should be restricted.

Para 47:

Local planning authorities should:

use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period;

Para 159:

Local planning authorities should have a clear understanding of housing needs in their area. They should:

prepare a Strategic Housing Market Assessment to assess their full housing needs, working with neighbouring authorities where housing market areas cross administrative boundaries. The Strategic Housing Market Assessment should identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which:

–– meets household and population projections, taking account of migration and demographic change;

–– addresses the need for all types of housing, including affordable housing and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); and

–– caters for housing demand and the scale of housing supply necessary to meet this demand;

The underlinings are ours.

Note the use of ‘demand’ in the last line. Presumably the definitions of these words, which are crucial, are a matter for case law, although we would much prefer to see clarification within the Evidence Base and the Emerging Local Plan to ensure that users of the documents are in no doubt as to the difference between ‘need’ and ‘demand’ for the purposes of arriving at ‘Objectively Assessed Housing Need’.

The Draft SHMA in para 1.20 refers to CLG (August 2013) Draft Planning Practice Guidance – Assessment of Housing and Economic Development Needs:

What is the definition of need?

Need for housing in the context of the guidance refers to the scale and mix of housing and the range of tenures that is likely to be needed in the housing market area over the plan period – and should cater for the housing demand of the area and identify the scale of housing supply necessary to meet that demand. Need for all land uses should address both the total number of homes or quantity of economic development floorspace needed based on quantitative assessments, but also on an understanding of the qualitative requirements of each market segment. Any assessment of need should be realistic in taking account the particular nature of that area (for example geographic constraints and the nature of the market area).  Assessing development needs should be proportionate and does not require local councils to consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur.

Can local planning authorities apply constraints to the assessment of development needs?

The assessment of development needs is an objective assessment of need based on facts and unbiased evidence. Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance infrastructure or environmental constraints. However, these considerations will need to be addressed when bringing evidence bases together to identify specific policies within development plans.

The above definition of ‘need’ is circular. There is also some apparent conflict between the requirement to be ‘realistic’ and the requirement not to apply ‘environmental constraints’.

If we assume the aim of the SHMA is to identify the unfulfilled NEED which needs to be met and also, probably separately in a market context, to estimate the DEMAND which may exist or the circumstances under which demand might need to be met (such as in the event Guildford Borough Council decides to include policies promoting economic growth which may bring with them additional DEMAND for housing).

Characteristics of the Housing Market (Chapter 2)

Housing Market Area

GL Hearn identify the Housing Market Area and discuss the complexity of the market and its designated Housing Market Area comprising Guildford, Waverley and Woking Boroughs.

GL Hearn have rejected considering the data for the wider area envisioned in the CURDS Single Tier Housing Market Area:

SHMA-Fig02

Single Tier Housing Market Area proposed by CURDS

For objective assessment of need, the catchment population would seem more readily to match the CURDS single tier HMA for our area due to its realistic recognition of the excellent rail connections within the area to both Guildford and Woking.

This Single Tier HMA includes the following Local Authority areas:

code Authority Single Tier HMA
24UB Basingstoke and Dean

55

24UC East Hampshire

55

24UG Hart

55

24UL Rushmoor

55

43UD Guildford

55

43UG Runnymede

55

43UJ Surrey Heath

55

43UL Waverley

55

43UM Woking

55

The composition of the LEP M3 is the above Local Authorities plus Winchester and Test Valley.

An approximate overlay of the Single Tier Housing Market Area on the South West Trains network map would look like this (shown by the red border):

SHMA-Fig03

Although this map does not truly represent the rail commuters to Guildford, it probably represents the connections to Woking, Waverley and Guildford combined.

Even if ultimately the determination were that the triple Borough HMA is the most appropriate, it is our contention that GL Hearn should have tested this before discarding it.

The assessment of employment-based need should take account of the rail links for commuting and, given that there is an option being considered to accommodate significant development to the west of the Borough (beyond the Green Belt), the interactions between Ash & Tongham and nearby Aldershot should be assessed to determine whether there is a submarket which would need separate treatment.

The HMA seems to have been drawn following arbitrary administrative boundaries and does not seem to have been adequately justified as the primary evidence base for the Draft SHMA.

At paragraph 2.8 GL Hearn seems to confuse the concepts of migration and commuting which goes to demonstrate the complications in setting an appropriate HMA.

At paragraph 2.13 GL Hearn notes the “identifiable and important functional relationships with the adjoining authorities of Rushmoor, Surrey Heath and Elmbridge”, commenting that for Guildford the relationship with Rushmoor is “particularly notable”.  It is surprising, therefore, that there is no substantive analysis of that particularly notable Borough’s data to establish (a) whether they form part of a more appropriate Local Housing Market Area or not; (b) how Rushmoor might influence the employment-based housing need through commuting; and (c) how the proximity of Aldershot with the second urban area in Guildford Borough (Ash South & Tongham), identified as such in the Settlement Hierarchy, might affect the interactions with new homes.

Guildford is described in the initial Local Plan consultation as being 89% Green Belt.  The rural composition of HMAs has been an issue highlighted by the Commission for Rural Communities (2007) which expressed concerns about potential misleading planning conclusions if HMAs are drawn ‘incorrectly’.

A particular issue is the disparity in characteristic between price and affordability profiles of rural areas versus urban areas.  The conclusions to be drawn from a mixed area might vary considerably relative to each set of individual circumstances.  The particular needs of an area being masked by the generality of the HMA approach.  Were the Evidence Base an integrated set of evidential documents and reports (as The Guildford Society has argued it should be), this is a subject which would have been highlighted by the Settlement Profiles Report and carried forward into the SHMA.

Housing Types

The housing tenant profile mix set out in paragraph 2.18 would benefit from some interaction with the findings in Section 7 of the Draft SHMA – especially where it relates to Houses in Multiple Occupancy by students (7.60) as there are 840 student HMOs shown.  This data – completed for the entire Borough rather than for only the four most affected wards – should then be used to adjust the figures in 2.18 to show both the gross position and the status net of student lets.

Furthermore, the housing tenure section would benefit from the inclusion of analysis on a ward-by-ward basis to establish whether any submarkets exist and the impact these might have on Guildford Borough and the HMA as a whole.

In terms of the Guildford Borough Council Evidence Base, it is unfortunate that there is not such granular evidence within the Settlement Profiles Report on a settlement-by-settlement basis (having regard also to the reservations expressed by The Guildford Society about the agglomeration of the neighbourhoods into the Guildford Urban Area) of housing mix and demographics. This would have helped GL Hearn to frame up a more useful and accurate picture of the provision and need for housing as part of their Strategic Housing Market Assessment.

In assessing the rental stock, no account has been taken of the Broad Rental Market Area (‘BRMA’) in which Guildford sits – how does this differ from the HMA?  A BRMA is, after all, defined in the legislation as an area within which a tenant could reasonably be expected to live, having regard to facilities and services for the purposes of health, education, recreation, personal banking and shopping, taking account of the distance of travel, by private and public transport, to and from those facilities and services.

At 2.32 there is a typographical error on the second line where ‘homes’ should probably be ‘rooms’.

Table 3 shows Guildford as having 56,220 households in 2011, whereas there were 52,350 in the 2001 census.  This implies that Guildford has added 3,870 households over that ten year period at and average of 387 per year. At paragraph 2.44 GL Hearn calculate the housing provision was 3,187 homes over the same period.  What is the explanation for that variance?

Table 4 highlights that across the HMA the housing provision has been 3.6% above planned provision in the period from 2001 to 2013.  If the HMA has credibility as a composite and complete housing market area, this should suggest that there is no historic shortfall to take into account in the housing figures and, whilst it is not necessarily for the SHMA to determine this, it might be helpful if that conclusion were to be drawn at 2.46.

Population Characteristics

Please see the population paper prepared to inform this response, which provides and overview of issues we consider have not necessarily been addressed in preparing for the SHMA.

Chapter 2 of the draft SHMA is full of data.

Fig 8 (reproduced below) is odd. It shows a falling population for Guildford between 2001 and 2004  which gives a misleading figure of 8.3% rise over 2005-12 (1.2% per year). The growth rate between 2001 and 2011, the census years, is 0.58% per year.

As in ‘How many new homes’ (‘HMNH?’), the dominating effect of international net immigration is noted.

SHMA-Fig04

At paragraph 2.50 the incidence of National Insurance Number Registrations is not questioned in terms of overseas students perhaps securing vacation or part-time employment.  This is a critical element of population forecasting for Guildford.

If ONS assesses the number of incoming international students by comparison with GP registrations, but if the data shows that de-registration of students (or rather the failure to de-register) distorts population data. The potential misrepresentation of NI registrations may also underpin overstated immigration projections.

We have reproduced the graph at Figure 9 alongside the Higher Education Statistics Authority (HESA) summary of Surrey university students (below), which, if reproduced on a common scale, would show graphically the similarities between the increase in overseas students and the ONS data but with a one year time lag.

The incidence of increase in GP Registrations over time (as highlighted in our accompanying population paper) does not support a hypothesis of a large amount of immigration.

The structure of Guildford’s population has been analysed carefully in the population paper.  We do not entirely agree with the broad-brush conclusion at 2.54 which seems to accept there may be a student influence on the 15-24 age-group but does not also recognize the 15-24 the impact that the lingering expansion of population at 25-29 has on other population data (for example it contributes to ‘fertility’ data, feeding additional births into the 0-4 group).

SHMA-Fig05

Population-Fig21

Labour Market

It is interesting to note from Table 7 that, unlike in Woking and Waverley, the difference in median earnings in Guildford for residents versus workplace is barely more than the price of a season ticket to London.  This may mean that the reference to “higher-paid jobs in London in particular” may be unnecessarily pejorative – albeit anecdotally supportable in many cases in the upper quartile.

That is not, and should not be the headline feature of the labour market in Guildford and the HMA.

The likely presence of submarkets within the HMA and within Guildford Borough mean that this effect should be considered on a ward by ward basis (assuming the data exists) and a clearer picture generated as to how different the effect is in the urban wards versus the rural villages.

Economic and Employment Trends

Paragraph 2.70 notes that ‘the level of employment in the Borough is likely to support in-commuting to Guildford’. This already happens as shown in the Evidence Base (the Surrey Congestion Programme – 2013) which highlights that only 55% of employees resident in Guildford Borough worked within the Borough:

201302_SCC-CongestionReport-Table4-2001

Assuming the 2011 census data will show a similar characteristic, this demonstrates that, of the 85,200 jobs in 2011 (paragraph 2.71), around 46,750 were taken by Guildford residents.  Comparing this to Guildford household numbers (taken from Table 3), this equates to 46,750/56,220 or 0.832 jobs per household.

Considering the growth forecast of 14,000 jobs between 2011 and 2031 (paragraph 2.71) and applying the same logic for future balance between in-commuting and household numbers, this suggests that 55% ( or 7,700) of the 14,000 jobs will be taken by Guildford Borough residents, equating to 7,700/0.832 or 9,254 households over 20 years.

By simple arithmetic this would suggest the housing need in Guildford Borough to meet the employment growth forecast would be 463 homes per year.

It should also be noted that in Spring 2010 Experian predicted growth in employment of 0.4% pa to 2031 (see ‘How Many New Homes?’ in the Guildford Borough Council Evidence Base).

The draft SHMA quotes Experian April 2013 as predicting an annualized rate of 0.8% pa (paragraph 2.73), which is said to be pessimistic. This doubling just goes to show how difficult prediction is.

Housing Market Dynamics and Market Signals (Chapter 3)

This section focuses very much on DEMAND and, as it is describing the characteristics of the market, this seems appropriate.

It is important to avoid confusing the NEED identified elsewhere with DEMAND which will always outstrip supply in a constrained gap town with almost entirely Green Belt surroundings such as Guildford.  In a sense (looking at Figure 17) the Quality of Place locally, coupled with Employment & Earnings, will tend to ensure the demand and supply equation is at equilibrium at higher than national average prices.  That mean and median house prices remain below Surrey mean and median prices (Table 9) is perhaps indicative that Guildford’s market is better balanced than others elsewhere in the county.

Understanding the Macro-Level Dynamics

Much of the data in this section is generic.

It is interesting to note the findings of Figure 22: ‘Mortgage Payments as a % of Monthly Income’. This shows by this measure housing is now as “affordable” as it was in 1993.  The table is reproduced below with the addition of a dashed red line to illustrate this point.

SHMA-Fig06

The data at 3.23 seems to show that the Guildford market was stable or falling.  This data must be qualified by reference to volumes of transactions in order to confirm that there was sufficient data to make comparison significant.  The sales volumes in Figure 25 unfortunately stop before the data at 3.23.  Figure 25 does, however demonstrate the reduction in volumes of sales since the financial crisis of 2008.

At Table 10, the median figures for the West Surrey HMA and Guildford for semi-detached and terraced houses are broadly similar and do not suggest any material divergence and overall the difference is below 4%.

At 3.34 the Draft SHMA notes that “it is important to recognize that the Guildford private rental market will be somewhat unique across the HMA given the impact of the university”, and yet no attempt to screen out the university lettings with 3.42 noting that “one and two bed properties to let located in the town centre, near the Surrey Research Park and the University are particularly popular.”

Summary

The concluding paragraph on page 57 of the draft SHMA, whilst making a valid point about lower quartile affordability, fails to point out that housing is no less affordable in Guildford than in Woking, and that Waverley is worse.

The fact that the draft shows that there are great similarities in the statistics for all three Boroughs may serve to illustrate the pertinence of the West Surrey HMA.  On the other hand, the rural areas of each Borough may contain anomalies that are screened by the commonality of the aggregated data.  It would also have been worthwhile looking at similar data across Rushmoor Borough as previously noted.

Overall Need/Demographic Projections (Chapter 4)

This Chapter sets out the broad framework required post NPPF.

That the NPPF says the scale of housing required (a third expression alongside ‘need’ and ‘demand’) should be based on meeting “household and population projections, taking account of migration and demographic change.” (NPPF Paragraph 159)

The analysis of the Population Projections has concluded that “the premise for the housing data in the Draft SHMA and that issued by Edge Consultants in the How Many New Homes? document looks as though it is deeply flawed and a full demographic analysis needs to be undertaken to understand the NEED for housing in Guildford during the Local Plan period.

Guildford Borough Council needs to urgently re-examine the core data (particularly within age-group cohorts aged 18 to 24 in 2011) before it moves to adopt any report or figure as the basis for its Objective Assessment of Housing Need in the Emerging Local Plan.

At 4.3 GL Hearn note they have ‘(built) on work undertaken as part of developing the draft Waverley and West Surrey Strategic Housing Market Assessment’. There is no reference to reassessing Woking post South-East Plan to establish what the updated whole-HMA requirement would look like.

Current Projections (Edge Analysis)

The draft SHMA refers to ‘HMNH?’ and in Table 12 quotes the Edge Analysis findings. The four cases giving 649, 470, 666 and 633 housing numbers equate directly to the four entries in Table one on p 23 of ‘HMNH?’ (The 204 figure is taken from Option 4 of ‘HMNH?’).  Edge’s chosen estimate based on migration trends is its Option 3, namely the 633 estimate. Edge explains carefully why they choose this, and the draft HMA’s comment that it is not robust seems a bit trite.  GL Hearn prefers the 5yr 649 figure, albeit five years is rather a brief period on which to base a 15 year (to 2031) projection.

The draft SHMA then quotes Edge’s three job-led housing numbers: Experian 392, IER 614 and Average of the two 502. The draft refers to Experian’s revised employment growth prediction (noted above).

Are CLG/ONS Projections Reasonable as an Assessment of Demographic Trends?

The population analysis sets out a clear case as to why, for Guildford, the ONS/CLG projections do not seem to be representative of the population when stripped of its student residents.

When compared to other university towns such as Cambridge and Exeter, the population spike is prolonged and affects the 18 to 30 data across the ten years of the ONS projection.  This anomaly is not explained and, whereas The Guildford Society has demonstrated the net impact of various alternative methods of adjusting the population to remove the anomaly, this is an exercise that should be undertaken rigorously BEFORE drawing conclusions from the ONS/CLG projections.

The draft SHMA does the best it can with some shaky government predictions (see Fig 29) and plumps for a net migration figure of 817 heads per year. This is almost entirely due to projected international net migration.

There is a huge uncertainty here. 817 heads per year is 0.6% of the March 2011 population of 137,183. ‘HMNH?’ predicts 0.14% pa (ref Fig 11 of ‘HMNH?’, equivalent to 190 heads per year) which is very much less. Natural growth is estimated by both to be about 630 heads per year (0.46%). So in total the draft SHMA predicts 1.06% pa and Edge 0.6%.

SHMA-Fig07

Figure B.5 of Appendix B is revealing. It shows a predicted large net inflow of 15-19 year olds, presumably students, but no corresponding net outflow of 20-24 year olds. Where have the graduating foreign students gone? Are they actually students? There is some outflow for the 25-29 year olds. The projections are ONS 2010 and must be suspect now given the rapid changes in international migration numbers. The Draft SHMA should have tested the effect of assuming the Edge figure.

Changes in government policy to control immigration and overstaying should also be considered by the draft SHMA, including also an attempt to understand the proportion of EU Nationals versus other foreign nationals.

The overall data from the ONS data set have been mapped by The Guildford Society below and this shows that the international migration is assumed to be a constant regular occurrence year-on-year.

We have shown this in two forms, firstly to illustrate the context of the different types of migration relative to the others and then to demonstrate that there is a projected to be a substantial amount of total  net migration

Firstly as an indication of annual flows:

SHMA-Fig08

And secondly as a cumulative figure:

SHMA-Fig09

Just as the net immigration figure is difficult to explain in projection, so was the adjustment made to each year’s data shown in Table B.2 of approximately 700 per year – “Other (Unattributable)”.

In fairness to GL Hearn, they have taken their migration projection to net out an allowance for the unattributable element.

Population growth combined with average household size gives the basic housing requirement.

Figure B.9 of Appendix B of the draft SHMA (reproduced below) is, therefore, crucial. The chart shows a strange upward kink in slope in 2011 rising to a peak in 2015-17 and then declining steadily through to 2031.

The logic behind this decline is not given by GL Hearn and, due to the crucial nature of this component, it should be explained.

The broad answer may be found on the Government website at the following link: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6395/1780763.pdf

When we looked at the Local Authority level detail (summarised in the population analysis) the household formation rate seems to be driven substantially by 15 to 34 year-olds in “Other households”.

SHMA-Fig10

It is reasonable to conclude that this is a signal that the ‘additional households’ are actually predicted to be HMOs or student residences.  This needs to be thoroughly investigated prior to formulating a recommended need projection based essentially on international migration.

Figure B.11 of the draft predicts a population rise of 20.7% 2011-31. This is 0.945% pa compound – more than 50% up on the Edge figure of 0.6%.

SHMA-Fig12 SHMA-Fig11

The Guildford Society has, in the attached Population Analysis, expressed concern about the basis for the population estimates and is concerned that, without a thorough sense check, the evaluation of ‘Objectively Assessed Need’ will only be good for speculative developers for whom there will inevitably be demand but where there is, to our mind, no proven need.

In Figure B.15 the population and household size predictions are combined to give a housing estimate: 54,183 in 2011, 67220 in 2031, growth 24.1%, equals 652 pa. Add 3% for vacant homes gives 671 dwellings per year.

The demographic assumption of population growth (based on 5-year migration trends) is that Guildford will need 671 additional homes per annum

As noted in the accompanying Population Analysis, These figures for the purposes of the SHMA should be restated to 435 to 529 additional homes per annum

The draft SHMA goes on to estimate that the jobs-led housing estimate is 570 dwellings per year.   This is based on the 2013 Experian prediction of 0.78% annual increase in the number of jobs.

The employment assumption of population growth (based on 5-year migration trends) is that Guildford will need 570 additional homes per annum.

As noted above, we have provided a simplified model for the impact of employment growth on households and believe that the appropriate employment-led number for the purposes of the SHMA is 463 homes per annum.

Affordable Need (Chapter 5)

The draft SHMA includes this section even though the post-NPPF SHMAs will typically omit this section.

The draft does not segment the affordable need from the market demand analysis in the previous chapter.

GL Hearn deduce the following table:

SHMA-Fig13

The table is a little clumsy in its layout but broadly suggests a summary need for affordable housing of 718 affordable dwellings per year over the period 2013 to 2031.

The chapter also describes two factors which may mitigate this requirement somewhat (at paragraphs 5.64 and 5.65).

Much the largest contributor to the need of 718 affordable dwellings per year is for newly forming households, at 701 dwellings per year.

This latter figure is heavily predicated on the demographic characteristics for the age group between 18 and 30 and the demographic predictions of population growth for that age-group.

The findings in Chapter 5 are, therefore, almost entirely questionable for all of the reasons given above and within the accompanying Population Analysis.

Need for Different Sizes and Types of Homes (Chapter 6)

At paragraph 6.3 the Draft SHMA notes that: “Demographic changes are … expected to be a key long term driver. It is reasonable to consider the implications of demographic trends (and in particular changes in the age structure of the population) as a starting point for considering what mix of housing might be needed over the period to 2031.”

The demographic profile is precisely the challenge we have faced in trying to get to grips with the ONS population projections against the Guildford we know. This seems to be borne out by the analysis we have undertaken in the attached population projections.

Housing Market Model: Modelling Methodology

The Draft SHMA highlights in Paragraphs 6.7 and 6.8 the difficulty of the exercise as regards formulating a tenure model (owner-occupiers versus rental).

SHMA-Fig14

Table 31 notes that it gives a total need for affordable households of 4,563 over the period from 2011 to 2031.  This equates to 228 affordable homes per year for the HMA. This seems to contradict the 718 figure arrived at above in Chapter 5, and the variance is not explained.

SHMA-Fig15

Table 33 gives a total need for market housing of 8,474. Added to the above 4,563 gives 13,037, i.e. 652 dwellings per year – which suggests that 35.0004% of all housing need is affordable housing.  This seems to be a convenient resolution or perhaps an unwritten target.

Furthermore, despite having identified the ability for people to commute by train and other public transport from outside Guildford to where employment is and may be located, this effect has been completely ignored in GL Hearn’s analysis.

Housing Needs of Specific Groups in the Population

The Draft SHLA seeks in this chapter to identify specific groups whose requirements or characteristics may not have been picked up in the overall housing requirements.

Housing Needs of Older People

The Draft SHMA notes at paragraph 7.15 that by comparison with England, Guildford Borough has a very slightly lower proportion of older persons.

This particular topic may vary depending which wards within Guildford are considered and the SHMA should look at these localised data to establish whether there is a submarket or whether the data are well matched across the Borough.

Fig 37 is of particular interest in that it hints at the degree of under-occupancy by non-single pensioners.

SHMA-Fig16

Young People

At 7.47 the Draft SHMA notes that in the 2011 census there were around 9,000 households headed by someone aged under 35.  The student population need to be screened from this number given that the advice to students in HMOs when completing the census form at the time was to nominate one member of the household as the head for the purposes of completing the form.

Paragraph 7.47 continues that the number of households headed by someone under the age of 35 is set to grow by around 2,400 over the period from 2011 to 2031.

Figure 41 shows the profile of this set I the first two bars:

SHMA-Fig17

Again, the group in private rented accommodation is likely to include significant numbers of student households.  It should be noted that these may cover The University of Surrey, the University of Law, the Academy of Contemporary Music, Italia Conti, PPA, Merrist Wood and other further and higher education establishments, most of which are noted in paragraph 7.52.

For figures 43 and 44 it would help if these were to the same scale in order to avoid a visually misleading picture emerging where net student numbers are falling.

Paragraph 7.57 notes that: “the University has over 5,000 student rooms in halls”.  This suggests that of the full-time students, more than 7,000 have to be accommodated in the surrounding houses.

Furthermore, for the 2,500 or so part-time students there is no data to show how many live in student-style accommodation or how long-term their presence in Guildford might be.

It is worthy of note that, at paragraph 7.60 and table 49, on page 118 of 130 of the draft SHMA report we see the first and only segmentation of the data by ward. This is to demonstrate the six wards with the highest numbers of student-only properties (only four appear in the table):

SHMA-Fig18

At paragraph 7.61 the draft SHMA appears to provide credence or support to the emerging proposals by the University to develop its land at Blackwell Farm and Manor Farm.  This should be removed from the SHMA and picked up in the SHLAA.

At 7.62 GL Hearn highlight that they “plan to further engage with the University of Surrey and providers of student accommodation to understand this issue further.”

GL Hearn need to go further than this and remodel the demographic numbers having screened students in or out of the data.  The lingering doubt about the purity of the data and the ONS projections leaves substantial doubt over the reliability of the projections, the outputs from the SHMA and the Council’s ability to deliver an acceptable (or fully explicable) Local Plan.

In summary for this section, there are 15,055 University students, 12,480 on full time courses. 4,610 (31%) are foreign students.

Figure B.5 referred to above shows a total inflow of 15-24 year-olds of about 5,500 pa, several times the probable university intake.

Assuming a typical average course length of 3.25 years (allowing for sandwich courses for a proportion of students) this would suggest new undergraduate students account for around 2,700 of the influx of 15-24 year olds.

Furthermore, a typical Masters Course may be one or two years (assume 1.5 years) and may account for two thirds of the post-graduate students, suggesting this sector could account for around 2,300 of the balance of the age-group.

Whilst this is pure conjecture, it does show that the University COULD account for more than 90% of the population increase each year.

The issue is not so much that this notional 5,000 cohort of young people arrives, it is that the data does not adequately track their departure.  This black hole of data is the main element of the Housing Debate about which The Guildford Society is the most skeptical and why it finds itself unable to accept on face value the figures proposed in the draft SHMA.

Draft Conclusions and Recommendations (Chapter 8)

Housing Market Area

The draft SHMA makes it clear that the concept of a MHA is a weak one as far as Guildford is concerned. The inability to include the effect of London within the concept is an obvious shortcoming.

Guildford is lagging behind Waverley in its preparation of the Local Plan and Waverley’s draft SHMA – prepared by the same consultants – seems to be conjured up in the same splendid isolation in which this draft SHMA has been proposed.

Woking’s housing allocation was agreed before NPPF within its Core Strategy and looks on the low side as part of the triple borough HMA.  No attempt has been made to challenge Woking to revisit their housing numbers.

Despite the references to the influence of and on Rushmoor, there is no attempt to consider Rushmoor and/or Aldershot in particular in the context of the HMA or Guildford.

The draft SHMA deals just with Guildford and hence avoids the issue.

Overall Housing Need

All the estimates of need should be based on upper and lower estimates of population growth.

The ONS/CLG data seem to be compromised by the student effect (or rather the inability to count the students back out of the area following completion of their courses).

The upper should be the draft’s estimate (adjusted for the demographic anomaly or with a clear unambiguous explanation of it), and the lower could be Edge’s (perhaps also adjusted for the anomaly).

The effect of international net migration is crucial, as shown above. Clearly it is volatile and subject to political decisions. The analysis should divide immigration into EU and non-EU. The whole issue requires much deeper analysis – including the student effect – because the implications are so great.

The draft SHMA seems thoroughly professional and is careful to quote its sources. It relies, however, somewhat blindly on the ONS and CLG predictions, whereas Edge Consultants in the ‘How Many New Homes?’ document were more analytic in that they used an elaborate computer modelling tool (POPGROUP).

No reference is made in the draft SHMA to use of a specific computer model which does tend to take away some of the transparency and replicability of the figures.  In any event, the use of a dedicated model facilitates multi-factor analysis which may have enabled more comparison with the other HMA boroughs and neighbouring boroughs exerting influence on or impacted by Guildford.

Overall Conclusion on Housing Needs

In the ‘Overall Conclusion’, paras 8.19 to 8.25, the apparent professionalism referred to above seems to evaporate.

The two figures developed within the draft SHMA suggest an annual need for new homes of between 570 (employment-led demand) and 671 (migration-led demand).  The figure of 800 homes per year at paragraph 8.24 is simply conjured out of thin air. There is no quantitative justification at all and no qualitative grounds for the leap of presumption.

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About GuildfordPlan

GuildfordPlan is a 'whiteboard' set up by Julian Lyon to think out loud as part of the process of preparing the Guildford Society representations to the various Local Plan Consultations