ONS publishes new Population Projections

On 29th May 2014, the Office for National Statistics published revised population projections for the period 2012 to 2037:

initial reading shows that, whereas under the data on which the SHMA was published, the population would have risen from 137,580 (2011) to 156,299 (2021), the new data shows this to be rising to 151,439 (2021).  This suggests a reduction from 1.28% to 0.964% per year.  The impact on housing numbers is complex because it depends upon household formation rates within the local demographic profile, but, crudely, this might suggest the SHMA figure of 780 should be reduced to around 590 homes (780*0.964/1.28).

The longer term projections take population forecasting out to 2037 and suggest the Borough population would have risen to 165,792 (a 20.5% increase from 2011 levels over 26 years – an average projected annual increase of 0.72%).

Guildford’s current households number in the region of 54,000 and at 0.72% (assuming household formation rates are consistent across the existing supply and the future need – which is unlikely to be the case due to our need for an increase in smaller housing units to fit our demographic profile – this would suggest a long term number of 388 homes per year.

I STRESS THIS IS VERY BASIC ANALYSIS AND DOES NOT PRETEND TO TAKE THE PLACE OF A PROPER PROFESSIONAL MODELLING EXERCISE.

The Guildford Society has advocated a target number of 345 homes (due in part to population trends and partly to existing supply constraints governed mainly by Special Protection Areas and Green Belt designations and Areas of Outstanding Natural Beauty.

Further detailed analysis will be prepared over the coming weeks to seek to inform the discussion and debate from a perspective of good data.  The Guildford Society would also wish to establish whether the anomalies identified in earlier studies (on this site and in the Guildford Society representations) and acknowledged by the Director General of the Office for National Statistics in his letter to Anne Milton have been fully resolved.  Early indications are that adjustment has been made to the assumption of students remaining in Guildford after qualification at the University of Surrey.

20140529_PopStatsUpdated-2021Comparison

On the face of it, some allowance has been made. From these data comparisons, it is possible to see some of the population assumptions at work:

A reduction in population from ages 19 to 30 or so also leads to a reduction in ‘fertility’ numbers and a consequent reduction in the number of births and under-tens.

The reduction in 19-30s is important (not just numerically overall) because this is the age group that feeds most into affordable housing numbers, and household formation numbers.

Equally, the demands on infrastructure will change due to the pattern – fewer than previously projected school places would be required, for example.

This is a really quick overview of the new data and should not be treated as in any way an empirical assessment.

The data are available here.

JDSL 29th May 2014

GSoc comments acknowledged by ONS

In a letter to Anne Milton dated 23rd May 2014 – our MP having taken up the Guildford Society concerns – the Director General of the Office for National Statistics, Glen Watson, has given some hope that the population projections might indeed prove to be overstated when new data is published on Thursday 29th May.

Mr Watson noted:

“ONS experts have reviewed the Guildford Society document which you enclosed and they have confirmed that the document is broadly correct in describing how population statistics and projections are produced.”

He comments that:

“The 2011 Census identified a very different population pattern for Guildford compared with the rolled forward mid-year estimates based on the 2001 Census. Broadly, the total population was around three per cent lower than previously estimated. This effect was particularly evident in the 20-29 age group and will have been largely due to issues with the assumptions on the movement of students into and out of Guildford.”

He concludes that:

“The 2011 Census identified a very different population pattern for Guildford compared with the rolled forward mid-year estimates based on the 2001 Census. Broadly, the total population was around three per cent lower than previously estimated. This effect was particularly evident in the 20-29 age group and will have been largely due to issues with the assumptions on the movement of students into and out of Guildford.”

It will be worth checking in due course to see if the SHMA is adjusted yet again to reflect both these findings and the new data to be published later this week.

In the meantime, thanks to Anne Milton MP for taking this up with ONS for The Guildford Society.

JULIAN LYON 27th May 2014

Senior Planner in Denial over ‘Integrated Evidence’

At the Joint Scrutiny Committee Meeting on 15th May, Guildford’s Senior Planning Officer, Carol Humphrey, was asked to provide the evidence of integration as this is not in the public domain.  In reply, she stated that “there is no obligation under NPPF to prepare an integrated evidence base” and she then went on to quote from the following from paragraph 158 of the National Planning Policy Framework:

  • Each local planning authority should ensure that the Local Plan is based on “adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.”

She did add the word ‘proportionate’ but she not finish NPPF Paragraph 158 (Using a proportionate evidence base), the remainder of which reads:

  • Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals.

National Planning Policy Guidance (NPPG) says:

Appropriate and proportionate evidence is essential for producing a sound Local Plan, and paragraph 158 onwards of the National Planning Policy Framework sets out the types of evidence that may be required. This is not a prescriptive list; the evidence should be focused tightly on supporting and justifying the particular policies in the Local Plan.  Evidence of cooperation and considering different options for meeting development needs will be key for this process.

The evidence needs to inform what is in the plan and shape its development rather than being collected retrospectively. It should also be kept up-to-date. For example when approaching submission, if key studies are already reliant on data that is a few years old, they should be updated to reflect the most recent information available (and, if necessary, the plan adjusted in the light of this information and the comments received at the publication stage).

Local planning authorities should publish documents that form part of the evidence base as they are completed, rather than waiting until options are published or a  Local Plan is published for representations. This will help local communities and other interests consider the issues and engage with the authority at an early stage in developing the Local Plan.”

Guildford is being asked to take on a massive amount of housing which can only really be considered IF the evidence base is integrated in terms of the assessments of housing, employment and other uses (as required by Paragraph 158 of NPPF) and they should focus tightly on supporting and justifying particular policies – in other words we should be able to see the train of thought and the evidence on which that is based.

As an example of the challenges inherent in a non-transparent approach, the policy of 40% to 45% affordable housing is set out in the Local Plan draft, as is the requirement for CIL contributions.  The viability of developments with CIL and a high affordable housing threshold is not covered in the evidence base and so it is not clear that the affordable housing policy is truly deliverable – developers will negotiate reductions in affordable housing quotas due to lack of viability.  This means the affordable housing target may not be sustainable and so the Local Plan may fail on a reasonable test of probability of outcomes.  This is only one such example, but the effects of getting affordable housing allocations wrong can be seen in London where Ken Livingstone’s 50% affordable housing target led to a massive contraction in development as schemes ceased to be viable – even in high value areas.

Key to the allocation of sites is the suitability and completeness of the Settlement Profiles which should help inform the needs of local areas and, frankly, the opportunities to enhance sustainability of settlements through development.  This MUST be a part of the Evidence Base which informs the assessment of housing strategies – ergo, it must be part of an integrated evidence base.

If the senior officer’s line is that there is no need to have an integrated evidence base, it will be small wonder if the policies and allocations fail, when put to the test.

This is not the time for semantics.  This is a time for excellent, unimpeachable, up-to-date and joined-up evidence to inform and shape a sustainable Local Plan that gets Guildford to where we collectively need to be.

If bad decisions are based on good evidence, that is politics.  If poor decisions are based on inadequate evidence, that would be negligence. Our Councillors need the highest standards of evidence (in the same way that good maths students show their workings) and we need to keep the pressure on our Councillors to make great decisions.

 

 

Going into Space without a Space Suit

Following publication of the Draft Local Plan in readiness for the Council’s Joint Scrutiny Committee Meeting on Thursday 15th May, the overriding sentiment is of disappointment.

The senior planning officer told the previous Joint Scrutiny Committee meeting that the Evidence Base was not itself integrated but that it would all come together in the Local Plan and that that was ‘the job of the Local Plan’.

Unfortunately, the inadequacies of the Evidence Base (which urgently needs some major overlays of fundamental information) are only too visible in the Draft Local Plan.

The Evidence Base remains so piecemeal that, either:

a)     The officers have a lot of information they have not shared; or

b)    They have made numerous guesses (or leapt to various conclusions) which, on the face of it, threatens to fundamentally and adversely impact the Borough and our Town.

This is not about NIMBYism; it is not about where the housing number eventually ends up; it is not even about whether Green Belt is used to accommodate growth; it is not about a 2011 retail report based on ten-year-old data.  It is about the whole package.  It is about prematurity:

  • the SHMA is still being challenged – and the underlying data contested with the Office for National Statistics – who are due to issue a new set of numbers within weeks;
  • the fundamental Vision for the town centre has not yet been presented;
  • the infrastructure baseline is insufficiently detailed;
  • the Settlement Profiles still see more than half of the Borough population living in an amorphous area without definition (the Guildford Urban Area) – and it still has errors such as, for example, that the nearest convenience store to Peasmarsh is at East Horsley (p59) – no wonder we have such cross-town traffic issues in Guildford!.

…and that is just picking up a few of the issues.

The NPPF call for Integrated Evidence is NOT adhered to in this Draft; the senior planning officer has apparently not fulfilled her promise; in this form the Local Plan would be open to challenge for years; in this form, the Draft is not ready for publication as a consultation draft.  Pressing ahead through fear of what will happen if there is a delay is not political courage; it is community madness.

To launch this draft spatial strategy for Guildford would be tantamount to sending an astronaut into space without a space suit!

Disappointingly, the draft Guildford Borough Local Plan: Strategy and Sites is NOT YET fit for consultation.

 

Irrespective of the state of readiness for consultation, this Draft Local Plan reads like a plan WITHOUT AMBITION but accommodating vast development. It exchanges its fear of planning by Inspectorate or of a mad developer feeding frenzy in the absence of a plan for a disjointed wholesale urbanisation of countryside with a series of ‘policies’ 20-123 which neither build on existing characteristics nor do they apply any perceived controls.

Imagine sending a five year-old to the supermarket for the weekly shop with the instruction: “buy some food” and expecting to be able to put together seven square meals for your family with the results and you have some idea of the planning deficit here!

No successful town has managed to assimilate such large-scale development without planned interventions by a strong Council, for example to:

  1. assemble land areas (often in partnership with a developer or developers) – this might apply to an area like Walnut Tree Close that could be a major new sustainable masterplanned residential quarter
  2. establish major enabling infrastructure (the GTAMS green snake or golden thread is interesting and environmentally beneficial in the current context, but much more needs to be done to take the traffic canyon out of the town centre)
  3. regenerate challenging neighbourhoods (the plan notes the presence of several areas in the ‘most deprived’ list for Surrey – and then does nothing to address underlying issues)

Having read thousands upon thousands of pages of this plan and evidence base, there is little to commend it – it seems like a magnified version of the pillories, piecemeal Town Centre Development Plan, which itself was little more than a prospectus of sites that could be developed.  Localism and NPPF surely has to offer us more than this to define the next fifteen years for Guildford’s and shape its long term future.

 

Here are a few notes to accompany this summary – the entire suite of documents has not yet been annotated:

Housing numbers:

ONS will publish new population projections in Summer 2014 and new household projections a little later in the year. These may differ sharply from the base numbers used for the SHMA and other key evidence.

The plan has, nevertheless, been based on 652 homes.  Let’s think about that for a moment.  We built around 3,200 homes over the ten years from 2001 – just meeting our targets.

This target of 652 is from 2011 to 2031.

In the first two years of that period we built a total of 491 new homes. Our target for the five years from 2011 up to 2016 when the local plan would be in place) would be 3,260 homes. At the current rate of building, we already have a shortfall of over 400 homes per year for five years to incorporate into our forward planning figures – which transslates to an extra 134 homes per year over fifteen years – and, having consistently fallen short of the new target we may even have to show a five year supply figure of 652 + 134 + 20% = 4,712 dwellings over five years – a shortfall we will have created for ourselves simply by adopting this new target.

So, an adopted target of 652 could easily become a requirement for us, within our seriously constrained supply of land and heavily strained infrastructure, to provide 943 homes per year.

That would be even worse at 1,378 per year for five years if we have to pick up the entire self-inflicted shortfall within the first five years of the Local Plan! (4.28 times our current target EVERY YEAR for five years!).  At, say, 2 people per dwelling on average, this would be an annual population growth of 2% – an annualised growth rate not seen in Guildford since the decade from 1881 to 1891, which was driven in part by the enlargement of Guildford Station and improved connections to London (this was a time when Charlotteville and the rows of houses up the hill from Sydenham Road were developed.  At 1,378 dwellings per year, this would see Guildford expand by 13.5% in just five years.

Over the Local Plan period (from 2016 by which time it will have been adopted to 2031), we would expect to see 15×652 plus 5×400 = 11,780 new dwellings – a 22% increase in households in Guildford in just fifteen years – and the Local Plan Draft does not begin to set out how the current deficit in infrastructure will be dealt with so quickly. The Draft Local Plan does not highlight the measures that will need to be taken in the communities and neighbourhoods to accommodate such unprecedented growth because the Settlement Profiles are so poor and do not take account of separate neighbourhoods.  

THAT IS A CLEAR FAILING OF A NON-INTEGRATED EVIDENCE BASE WHICH HAS NOT ‘COME TOGETHER’ IN THIS DRAFT PLAN

 

Green Belt:

Based on the prematurity of housing numbers, the proposed Green Belt releases are also premature – this could have been dealt with by a subsequent Development Plan Document examined in public and which would have allowed the Local Plan to treat Green Belt as a ‘Constraint’ to the housing numbers but not to shy away from a moral if not legal obligation to consider Green belt releases.

In fact, the problem here is also that the SHLAA suggests some unallocated sites removed from the Green Belt capable of providing 1600 or so homes.  This suggests that the removal of land from the Green Belt will not lead to a permanent redrawing of the Boundary.

At the current level of ‘objectively assessed need’ and the proposed adopted housing figure, this suggests you will need to make another major raid on the Green Belt in the next Local Plan as the so-called unallocated contingency would barely last two and a half years beyond the Local Plan – even assuming the other figures are even correct.

The Draft Local Plan does not set out clearly how changes to the Green Belt boundary will be permanent and sustainable.

 

Infrastructure:

We have a major infrastructure deficit in Guildford.  As a transport hub we are in trouble, and the amount of traffic churning out air pollution in queues in the heart of our town centre is already causing major qualitative blight for residents and visitors to our town.

It cannot be appropriate to add any development to west of Guildford without resolving the limitations of the Farnham Road bridge as the single crossing point over the railway.  This is not to ADD capacity but to deal with current constraints.

The Infrastructure Schedule is uninspiring and born out of the shortcomings of the Infrastructure Baseline – which is insufficiently detailed and which fails adequately to deal (in a strategic planning sense) with fundamental flaws within in linking several communities.

The Schedule actually spends significant time setting out a list of initiatives that are listed for delivery in 2014/15 – before this plan is even expected to be adopted.

The Plan does not – as it should – bring forward strategic vision but sets out tactical initiatives already planned.  This is poor and disappointing.

 

Settlement Profiles Report:

Very little policy direction in the Guildford Urban Area – unsurprising since there is not much background information in the Evidence Base.

This really does need an up to date overlay of character statements and a segmented approach to the neighbourhoods – Guildown is not the same as Stoughton, for example – and then some potential positive direction looking at specific opportunities to regenerate areas or enhance them.

These are areas of Guildford housing more than half of the population where there is no Parish Council to respond to the Council questionnaire.

And then there are the transcription errors!

Guildford Urban Area:

Community Services and Facilities:

Guildford urban area is well equipped with social and community facilities, it offers all of the community facilities and services assessed, and offers more leisure facilities including the Spectrum leisure centre. Northern………………………..”  (the rest of the sentence is missing)

Transport:

Residents within Guildford urban area have access to a range of transport options.”  Well some have better access than others…!

Conclusion:

Guildford is designated as an urban area and contains a high level of services. As such it could support a level of development which exceeds that of any of the borough’s other settlements. If suitable sites are found, there is the option to extend the urban area to enable more development however this may lead to development away from key services. The sustainability of any extension should be assessed in more detail through other evidence base studies. This will include further work to assess the level of infrastructure needed to support the level of growth.”  – no, this is what Neighbourhood profiles would do – which would allow you to see which areas could support development, which areas might need infrastructure enhancements to enable their development and which areas should accommodate relatively organic development rather than major projects.

 

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.

Population Analysis

Population Analysis – GUILDFORD

Introduction

The Local Plan consultation and development has generated substantial concerns about the various housing numbers.

No housing number has yet been adopted by Guildford Borough Council but the indications are that this is likely to be much bigger than (and perhaps even multiples of) the previously adopted figure which was, itself, arrived at as a result of a legal challenge by Guildford Borough Council to the proposed ‘need’ suggested by the now-scrapped South East Regional Plan.

In its draft Strategic Housing Market Assessment (SHMA), the Council’s consultants GL Hearn have relied upon ONS population projection figures in their assessment of need, suggesting a baseline figure of 671 homes are required.

The Guildford Society determined a figure of 345 per year as an adoptable number following analysis of the Council’s “How Many New Homes?” document (based on research by Edge Consulting) which formed part of the pre-Local Plan consultation (The Guildford Society paper is attached to this document).

Why are these figures so different?

The Guildford Society has argued that the population figures are skewed by the numbers of students (particularly overseas students) whose presence is not well catered for in census data and consequently in population projections.

This paper, therefore, sets out to question the validity of projections based on the Office for National Statistics (ONS) Population Projections and the Department for Communities and Local Government (CLG) Housing Predictions which, together, form the basis of the SHMA

Analysis of the Population Data

It is very clear from the publications of the Office for National Statistics that the 2011 census shows a very substantial population peak at aged 21.

Population-Fig01

The data actually show a bulge in population around the typical age of Undergraduate or Masters students.

The 2011 Census

The 2011 census showed Guildford as having a 5.8% rate of growth, adding 7,500 additional heads to its population over the ten year period from the previous census.

The percentages of 2011 census population who were UK-born were:

  • England 86.2%
  • South East 87.9%
  • SURREY 85.8%
  • Guildford 84.5%
  • Waverley 89.4%
  • Woking 80.1%

It is worth noting that the census data shows that Guildford had 21,277 people in its regular population in 2011 who were non-UK born, and there were 12,982 people who did not hold a UK passport.

When we look at the ward data, there appears to be an anomaly in the Onslow Ward, which includes the University.

Only 63.8% of people living in Onslow Ward were born in England (Guildford 81.0%, Westborough, neighbouring Onslow, 81.0%).  The median age in Onslow is 23 (average 31) versus Guildford at 38 (39) and Westborough at 32 (36).

The equivalent figures for Friary & St Nicholas – which also includes a fairly significant student population – are that 72.9% were born in England and the median age is 32 (average age 36)

From our knowledge of the area and of Onslow Ward itself, this anomaly seems to be highly significant and demonstrative of a significant student population which, for the purposes of the census has given its usual residence in Guildford.

It is worth considering the treatment of students (and their inconsistencies) in the censuses of 2001 and 2011.

How are students treated in the census?

It seems, therefore, appropriate to consider how students were treated in both the 2011 and particularly the 2011 censuses.

In 2001, the Census was designed to measure the usually resident population, with students being counted at their term-time address. People were treated as usually resident at the place where they lived for the majority of the time, or at their current address if they had no usual residence.

The ONS Census quality assessment noted that there was broad comparability at a national level with the resident count from the 1991 Census, when students were counted at their home address. However, local results were not entirely consistent with 1991 because of the movement of students to schools and university towns in term-time.

There is some confusion in the 2011 census data.  The ONS document prior to the census (Final Population Definitions for the 2011 Census) noted:

2.4.3 Further clarification on place of usual residence

Students

Students, and children at boarding school, should be counted as usually resident at their term-time address.

They should also be counted as usually resident at their permanent/family address (if different), but only limited information will be collected.

Furthermore, Any UK resident who was staying in a communal establishment (such as a University Hall of residence) on 27 March 2011 and had no usual address in the UK is counted as usually resident at the communal establishment (regardless of how long they have stayed or intend to stay there).  This would apply to overseas students living in Courts at the University.

The key questions in the 2011 Census as it related to the 2001 Census were questions 5 to 8 (reproduced below with the 2001 comparator alongside).

The next key challenge is to understand how the information has been used.

It seems that published data attempts to remove term-time students from the datasets – hence the 10,714 students in Guildford in the Census data falls substantially short of the University’s figures and fails to take account, therefore, of the other Further Education institutions in Guildford.

Population-Fig04

Population-Fig02

Population-Fig03

An analysis of the proportion of the Surrey population in the 2011 Census who are aged between 18 and 74 and who are in full time education shows that Runnymede (London University, Royal Holloway) and Guildford (University of Surrey) – both of which have significant proportions of overseas students – have a substantially greater percentage of their census populations (usual residences) in full time education:

Population-Fig05

Applying the average of all other Surrey Local Authorities for this age group (2.363% of total census population) to the populations of Runnymede and Guildford shows a marked reduction in the numbers of full time students (reflecting the home addresses of the local population and, arguably, screening out the overseas students whose ‘usual’ addresses are in the Runnymede and Guildford boroughs.

Guildford’s adjusted full-time student population would fall from 10,714 to 3,242 – a reduction of 7,472 in the census population of 2011 for Guildford.

Population-Fig06

If the 2011 census data is smoothed between ages 18 and 24, this accounts for only 3,867 people and so perhaps the full-time student adjustment needs to either cover more age-groups or to be more scientifically calibrated (or both).

At the time of the 2011 census, the University of Surrey student numbers (source: HESA) were 13,575 full time students of which 4,005 were post-graduates, possibly supporting the contraction of population numbers from the 2011 census across a wider age range.

Population-Fig07

This over-simplistic analysis merely demonstrates that an apparent population bulge could be explained by reference to the presence of (and method of counting) students, particularly from overseas, in the 2011 census, and the subsequent adoption of a population anomaly into consequently inflated population projections.

Another potential Census anomaly (or another symptom of the student anomaly) is that Guildford and Runnymede have higher than county average numbers of second addresses (given the Census questions) running at more than double the average for the remaining boroughs of Surrey.

Furthermore, Guildford census data for 2011 shows 2.1 times the number of people living in communal housing (which includes student courts) relative to the South East and 2.5 times the national average – again indicative of a higher student count that needs to be adjusted.

It cannot, therefore, have helped that the 2011 census date (27th March) fell on the Saturday night after university terms had typically ended on the Friday.

These characteristics of the Census data, and the potential skew in data caused by the failure to fully count university students within or outside of the census, provide ample reason for these data to be forensically re-examined and for the anomalies to be tested and screened out.

How are interim Population Statistics derived?

Historically, population data derive from two main sources:

  • The resident populations from the decennial national census (2001 and 2011, for example); and
  • The general practice registered populations from the Exeter system (the Family Health Services registration system).

The figures from the GP registrations are backward looking as is the census data, but it provides a useful proxy for population migration, especially where people moving from one area to another register reasonably promptly with a new local GP – whereupon their records (and consequently their demographic data) is shown to have migrated with them.

The Office for National Statistics (ONS) estimates mid-year resident populations each year, using the most recent census data, and adjusts the population according to the estimated number of births, deaths and migrations.

Population projections are produced by ONS every 3-5 years using the mid-year estimates and project population change over 25 years using predicted birth rates, death rates, migration and ageing based on the trends observed over the previous 5 years. The Chelmer Population and Housing Model (CPHM) makes allowance for local housing developments.

The GP Registered Population Estimates (The Attribution Data Set: Exeter System) uses The Attribution Data Set (ADS), which is the national count of patients on GP registers (the Exeter system). This is constantly updated. The data are used for Department of Health estimates and by ONS for estimates of migration.

There are issues with this system and, in Surrey, for example, the Exeter registered-resident population in 2006 was larger than the ONS resident estimate by 24,400 (2.3%).

This may be associated with delays in practice lists being updated when patients re-locate (list inflation) – a particular issue with student populations – but could also be that people living close to Surrey may tend to register with Surrey GPs. The weighted capitation population estimate is typically lower than the GP relevant population figure.

Population-Fig08

For Guildford there is a rising trend in registrations by around 40 or so per year.

One of the known limitations of relying on GP registration data is that young people, particularly young men, can be slow to change their registration when they move. One of the most common reasons for migration among young people is to attend a course at a higher education establishment, so this limitation of the current internal migration estimation process is a key issue in the estimation of internal migration for this population sub-group.

In May 2010, ONS introduced an additional adjustment for students based on HESA data to improve this undercount. HESA data contains records for students registered at higher education establishments and includes both term-time and domicile address variables. An adjustment is made to both first year students moving to higher education establishments and moves made by students at the end of their studies. These data are not complete for overseas students particularly when the students live in multiple occupation (eg., in halls of residence) and may result in overseas students being counted as immigrants whereas they should be tracked as students.

Student halls of residence are usually reserved for first-year undergraduates. Students living in halls at census time would therefore be most likely to have registered with a GP in their university town in the year preceding census, 2010. The chart below shows (nationally) the proportions of students living in student halls in a university town, by year of acceptance on the local Patient Register.

People registering as far back as 2007 would be in their fourth year at the university, and few of these would be expected to be living in halls. However, the graphs show that over a quarter (27.1 per cent) of men and almost a fifth (18.6 per cent) of women in halls were accepted on the Patient Register in 2007. This, alongside evidence that there are many more patient registrations giving student halls as their term time address than the premises could accommodate, suggests that the Patient Register includes people, particularly men, who have left the area.

Population-Fig09

On the above chart, the left hand axis shows the cumulative percentage of students registered with the GP as living in halls of residence (nationally) against (on the horizontal axis) the year in which they first registered with the GP.  In other words, of the 100% of male students registered with a GP who were listed as living in halls of residence, around 95% had registered in 2010 or earlier, around 62.5% had registered in 2009 or earlier, around 40% had registered in 2008 or earlier, 27.1% had registered in 2007 or earlier, around 15% in 2006 or earlier and around 12% in 2005 or earlier.

The graphic demonstrates clearly the issues with estimating student populations and of maintaining accurate assessments of the impact of demographics on the need for housing.  Typically students spend only their first year in hall and yet the GP registration evidence would suggest otherwise.

Interestingly the NHS GP-registrations modelling data shows a similar unaccounted for anomaly around student age – and this example, taken from the ONS document (Results from using routinely-collected government information for 2011 Census quality assurance) which may well relate to a university town or city – the report does not specify which.

Population-Fig10

Patient registrations and census estimates, by age, in a metropolitan area outside London

How does Guildford’s 2011 population profile compare with England?

Broadly, for most age-groups, the demographics are similar.

The stand-out anomaly is the peak at student ages (Guildford is in blue and England in red).

Population-Fig11

The above chart has been set with an index of 100 representing the population at below one year of age.  Subsequent ages have been stated by reference to the index.

The data sets for England and for Guildford are very similar (including the small population peak at age of around 65) with the exception of the student-age anomaly.

Note the broad similarity between the England curve and that for Guildford.  It is perfectly plausible that the removal of the student effect could cause Guildford’s population profile to converge with England.

How have ONS reflected the changes between 2011 and 2021?

The equivalent chart for 2021 is shown below and shows the bulge has broadened as it has been carried over into the successive years from 2011.

The charts below demonstrate a similar visual correlation between England and Guildford with the exception of the student anomaly – again showing a similar small peak, but this time in the mid-seventies.

Population-Fig12

Shown together, these indexed lines are clear evidence of an anomaly in population figures that will need to be addressed before assessing the ‘OBJECTIVELY ASSESSED NEED’ for new homes in Guildford.

Population-Fig13

Note again the broad similarity between the 2021 projected England indexed data curve and that for Guildford.  It is again perfectly plausible that the removal of the cumulative student effect could cause Guildford’s population profile to converge with England.

Comparison with other University Towns

We have viewed the data against Exeter and Cambridge and this shows a similar spike in population at undergraduate age but the effect does not linger in the same way as the Guildford projections suggest (the charts are set out below).

We have also done a similar exercise with Rushmoor, Waverley and Woking to assess whether there is a similar pattern in those local authorities.  Again, the charts are set out below.

Population-Fig14 Population-Fig15

The University towns are certainly distinctive and the effect can be seen for other university towns and cities.

Here, the effect is short-lived and, whilst it may inform the demographer that there is a larger population of student age, it does not seem to linger through the projection period.

Population-Fig17 Population-Fig18 Population-Fig16

The three neighbouring Local Authorities have no such spike – in fact they all seem to lose population of student age.

CLG Housing Projections

The household formation models used by CLG are complex and are based on the ONS population projections.

The data from the ONS SNPP(2011) has clearly influenced the CLG Household projections for Guildford as shown below.

Household Formations and Compositions

The ONS has collected data for household formations which summarise the composition of households based on the Census data from 2011 and then the ONS projects forward based on population composition how many households are likely to be required and of what size or accommodation.

The household types are given as:

One person households: Male
One person households: Female
One family and no others: Couple: No dependent children
One family and no others: Couple: 1 dependent child
One family and no others: Couple: 2 dependent children
One family and no others: Couple: 3+ dependent children
One family and no others: Lone parent: 1 dependent child
One family and no others: Lone parent: 2 dependent children
One family and no others: Lone parent: 3+ dependent children
A couple and one or more other adults: No dependent children
A couple and one or more other adults: 1 dependent child
A couple and one or more other adults: 2 dependent children
A couple and one or more other adults: 3+ dependent children
A lone parent and one or more other adults: 1 dependent child
A lone parent and one or more other adults: 2 dependent children
A lone parent and one or more other adults: 3+ dependent children
Other households

For Woking, for example, the households falling into the ‘other households’ category are around 6.3% (2011) to 6.6% (2021) of all households.  Of people between the age of 15 and 24 years old in Woking, the numbers living in ‘other’ accommodation are 19.2% (2011) to 19.9% (2021).

For Guildford, however, the overall totals in ‘other households’ are 7.8% (2011) rising to 8.7% (2021) of which (and substantially affected by the assertion that) of 15 to 24 year-olds, 54.2% (2011) projected to rise to 64.1% (2021) are living in ‘other households’.

This is consistent with the Guildford student anomaly highlighted earlier and there is a continuing effect in the 25 to 34 age group who show as 15.6% (2011) rising to 20.6% (2021).

These would seem to echo the demographic trends shown in ONS SNPP(2011).

So what adjustment should Guildford make to its housing targets?

In pure arithmetical terms (which does not take account of the idiosyncrasies of population modelling), the impact of the population numbers at student age has been assessed as follows:

For each year group it is possible to view the data diagonally down the page to the right to see the change in population numbers of each age-group cohort.

Population-Fig19

Figures reproduced from the ONS data set for the 2011 all person Sub-National Population Projection

In this case, the age-group of seventeen-year-olds in 2011 grows from 1,543 in 2011 to 1,826 in 2012, 2,924 in 2013 and so on, peaking at 3,217 in 2016 (when they are at age 22 years) until finally falling back to 2,449 in 2021.  This effect can be seen by following the cells diagonally down to the right.

The cohort aged seven years in 2011 is at 1,555, and reaches 1,618 at age seventeen years in 2021, its peak.

Similarly, the cohort aged twenty-four years in 2011 is at 1,951 and reaches 1,924 by 2021, having peaked at 1,957 in 2018.

These are reasonably consistent with national average trends and so the focus is on the cohorts in between those aged seven and those aged twenty-four in 2011.

We have taken the band within the black outlines (aged eighteen to twenty-four in 2012, for example, totaling 17,427) and calculated the expansion of those cohorts against the same cohort in the previous year (viz. aged seventeen to twenty-three in 2011, totaling 15,436).

The effect of this is to demonstrate the effects of the population ‘bulge’ in ARITHMETIC terms (rather than statistical) over the period from 2011 to 2021 as shown below:

Scale of bulge in cohort Years compared

1,991

For ages 18-24 in 2012 versus ages 17-23 in 2011

1,653

For ages 18-25 in 2013 versus ages 17-24 in 2012

1,367

For ages 18-26 in 2014 versus ages 17-25 in 2013

1,191

For ages 18-27 in 2015 versus ages 17-26 in 2014

1,029

For ages 18-28 in 2016 versus ages 17-27 in 2015

848

For ages 18-29 in 2017 versus ages 17-28 in 2016

759

For ages 18-30 in 2018 versus ages 17-29 in 2017

691

For ages 18-31 in 2019 versus ages 17-30 in 2018

600

For ages 18-32 in 2020 versus ages 17-31 in 2019

521

For ages 18-33 in 2021 versus ages 17-32 in 2020

10,650

TOTAL ‘RESIDUAL’ BULGE OVER 2011 to 2021

This approach has attempted to estimate the area between the 2021 curve and the 2021 curve between the ages of 18 and 33 and the inference to be drawn from this is not necessarily, therefore, that the population forecast is wrong by a total of 10,065 people over the ten year period.  It is that the data need to be tested again having screened out the anomaly of overseas students.

A crude approach to the arithmetic model would be to impose a cap on the population forecast between the ages of eighteen and thirty-three at, say, 2,000 and then to show the same charts and figures as above.

This would show the projection as being restated as below:

Population-Fig20

Both of these approaches has the disadvantage of assuming ALL growth is due to the student population and that there is no background expansion.

Overseas Students

The Higher Education Statistics Authority (HESA) publishes figures showing the numbers of students at institutions and the proportion of overseas students.

For The University of Surrey, the figures for 2000/1 and 2010/11 (incorporating the census years) show there was an increase of 4,664 in the numbers of students between the two periods of which the increase in overseas students accounted for 3,145.

Population-Fig21

The 2001 census (year 2000 in the chart above) had the lowest student numbers and the smallest cohort of overseas students, whereas the 2011 census (year 2010) had the highest number of overseas students. Reflecting this between censuses as a trend is to misunderstand the data.

In 2010, there were 2,607 homes that were exempt from Council Tax, a reasonable proportion of which will have been as a result of student exemptions, which, if accommodating, say, four students each in 2,000 of them, could account for the student numbers not able to be accommodated in the University Courts and some of the residual students of other Guildford institutions.

It should be noted that anomalies within the 2011 census will allow domestic students to be recorded at their (parental) home rather than at university, whereas overseas students are probably recorded at their university address.  It seems reasonable to screen out this student anomaly when assessing the figures.

Crude Arithmetical Model

In the absence of the necessary skills and expertise to conduct a full statistical reappraisal of the figures, the very basic arithmetical model would take the total erroneous population growth in the table above (assessed as 20,034) and deduce that this would adjust the projected 2021 population figure from 156,291 to 136,257, reflecting a slight reduction from the 2011 census figure of 137,580.

This does not reflect reality either of the demographic growth or of the appropriate 2011 baseline number.

Clearly there needs to be a more discerning assessment and, in order to model an approach which emulates the national model but without the complexity of a full demographic model, we have considered how the application of a notional population cap within the key cohorts might impact the projections.

Taking the adjustments made above, where the area beyond the curve was estimated at 10,650 people, and assuming this expansion beyond the typical university town bulge (based on the 2011 profile) is entirely down to the student anomaly, this would suggest a population in 2021 of 145,649 (growth of 8,069 over ten years, which at 2.42 people per household would require 334 homes per year)

The following two charts show the indexed data for Guildford against the indexed England data (where the cohort aged 0 is set as 100 and each cohort is shown relative to that baseline).

Population-Fig22

The first chart (above) shows the data from ONS indexed for both Guildford and England based on their respective populations at aged under one year old set to 100.

The second chart (below) shows the same data but adjusted by the crude arithmetical model (table shown above) where the population between seventeen and thirty-three is restricted to 2,000:

Population-Fig23

This analysis shows that such a cap (statistically applied) would seem to be a realistic approach – although we should caution against its application in such a crude way without an underlying assessment both of the effect of the student population and of background migration into Guildford.

The implication on the housing numbers (again using crude arithmetical analysis) shows the following:

2011 CENSUS DATA        Population 137,580

2011 CENSUS (capped)    Population 135,461
(suggests, crudely, around 2,000 overseas students may have stayed in Guildford over the census count)

2021 POPULATION PROJECTION              156,299

2021 CAPPED PROJECTION                     148,253

(removes the cumulative anomaly identified across the projection years)

This suggests (at 2.42 people per household – as per the 2011 census) that the housing need on the basis of demographic trends is likely to be 12,792 over the ten year period (the capped 2021 projection LESS the 2011 capped census data), requiring 5,286 homes at 529 homes per year (compared to 774 homes per year suggested by the unadjusted data).

NB: Applying a notional cap of 1,900 to the key cohorts in 2011 to 2021 makes very little difference to the assumed population growth (just under 12,000 instead of 12,792).

Normalised Data Mapped by England Indexation

In order to consider alternative normalization processes, the Guildford data for those aged below 1 year old were multiplied by the respective England indices for each successive cohort.

These annual data provided the following summary:

2011 CENSUS DATA        Population 137,580

2011 INDEXED CENSUS    Population 133,156

2021 POPULATION PROJECTION              156,299

2021 INDEXED PROJECTION                    143,691

This analysis is still rather crude but has the benefit of overlaying the England aggregate indexed profile over the Guildford population according to the number of infants under one year old.

This demonstrates a projected population increase of 10,535 between 2011 and 2021, translating to 435 homes per year.

Further analysis of other sources is being carried out to enable us to understand whether there are other flaws which might require a reassessment of the core data.

A further simplistic approach to dealing with the anomaly in the data is to take the problematic years in each cohort as 19-28, which as we have demonstrated is broadly where the population bulges.

If the average forecast population growth for the remaining population (11% vs. 26%) is applied to these years it provides a very simple estimate of the adjustment required to remove this bulge with the added advantage that years 19-28 would then show a growth rate that is consistent with the remaining populations.

Taking this approach would give a revised demand level at 2.42 people per household of 641. See the tables below.

Actual data

Population-Fig24

 

Adjusted data

Population-Fig25

There remains a further challenge and that is that, if there is an unexplained anomaly, the complex CLG housing formation modelling, based on a complex ONS forecast including fertility as well as migration, could also be inflating estimates elsewhere in the system.  In this last method, for example, adopting the same percentage average increase for our 19-28 cohort, would probably overstate the population as a result of the impact on expected fertility within the target age range.

Housing Based Adjustment

The CLG household projection (based on ONS SNPP(2011)) highlighted above suggests that 663 new homes per year will need to be built over the period from 2011 to 2021.

Adjusting the 15 to 24 and 25 to 34 age-groups to the stated current Guildford average, the projected required rise in households falls to 507 per year from 2011 to 2021.

Again this shows that the impact of the anomaly, is to substantially inflate the housing need figures and it would not, therefore, be safe to rely upon the data as provided without significant further research.

CONCLUSION

The premise for the housing data in the Draft SHMA published by GL Hearn 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.

IT SHOULD BE EMPHASISED THAT NONE OF THESE SIMPLISTIC APPROACHES IS CORRECT, NOR DO THEY ARRIVE AT THE RIGHT ANSWER, THEY MERELY INDICATE THAT, UNEXPLAINED, THE VISUAL ANOMALY IN THE DATA WILL BE A BONE OF CONTENTION IN THE LOCAL PLAN PROCESS AND COULD LEAD TO A SUBSTANTIAL OVERSTATEMENT OF NEED.

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.

Thoughts on Demographics and the SHMA

In response to the Draft SHMA (which can be found here) it seems appropriate to consider two approaches:

1.  Look at the SHMA itself

2. Look at the data behind the SHMA

There are, therefore, two strands that follow from this.

POPULATION ANALYSIS

FEEDBACK ON THE DRAFT SHMA

I have provided links to both lines of analysis (by clicking on the capitalised headings respectively)

 

The Guildford Society Submission

Here is a sneak preview of the final version of the Guildford Society submission to Guildford Borough Council on the Local Plan Issues and Options Consultation:

20131128_GSoc_LOCALPLAN_Submission

(circa 20Mb)

or in lower resolution:

20131128_GSoc_LOCALPLAN_Submission_LowRes

(circa 7Mb)

Also here is a summary document which should be read in conjunction with the main submission document:

20131128_GSoc_LOCALPLAN_Submission_SummaryNote

…and now time for a lie down!

New Draft Submission

I have updated the submission from Draft 4 based on comments received and am sharing this here in two versions:

20131121_Questionnaire_JL_Dft5-Public_Clean-Watermark (without mark-ups) – this file is around 19MB and includes most of the Appendices where available.

20131121_Questionnaire_JL_Dft5-Public_Redline (showing the changes from Draft 4) – this file is around 10MB including most appendices where available.

SUBMISSION OF THE FINAL VERSION WILL NEED TO BE NEXT FRIDAY SO I WOULD WELCOME FEEDBACK BY CLOSE OF BUSINESS ON WEDNESDAY. Please reference your feedback to the paragraph number in these versions OR at least to the Question to which your comments relate.