West Surrey SHMA keeps numbers high

On 18th December the Strategic Housing Market Assessment (SHMA) for the West Surrey Housing Market Area (HMA) was published.

Summary Report:

20141218_West_Surrey_SHMA_Summary-FINAL

Full Report:

20141218_DraftSHMA_HMA

IT IS WORTH REMEMBERING THAT THIS IS A CONSULTANT’S OPINION and whilst this will be adopted by the three local authorities (Guildford, Waverley and Woking) it is merely GL Hearn’s version of an Objective Assessment of Need (OAN).

The next stage of the process is to establish whether we can actually provide sufficient supply to meet the need, and this will require us to take a good look at the triangle of forces (housing, economy and infrastructure) restricted by availability of land and the constraints of Surrey Hills Area of Outstanding Natural Beauty (AONB), Thames Basin Special Protection Areas (SPA), Green Belt, Sites of Special Scientific Interest (SSSI), Flood Risk Areas and Cross-Boundary issues to name but a few.

It is not enough to simply say ‘No’ to development because NPPF requires us to plan positively.  Equally, it is not appropriate (based on the previous consultation process) to simply say ‘Yes’ to development which cumulatively meets the target number provided.  These next few months are critical to strike a balance (not necessarily a compromise) between going out, up or maintaining existing constraints.

Two images from the report is consistent with the criticisms of the dataset that have been made on this site and by others:

20141218_SHMA-fig16

and

20141218_SHMA-fig17

These charts show that, despite the Office for National Statistics protesting that their figures screen out students (by using their non-term-time addresses, there is very much a spike at undergraduate student age (Figure 17).

When that is applied to the data behind Figure 16, it seems there is still an expectation that, over a twenty year period those inward migrants have fallen in love, set up homes, and had children – a perfectly natural cycle but one which still seems exaggerated as a phenomenon.  It is also at this age when the gap between earnings and house prices is at its greatest, placing more urgency on providing affordable housing.

It will take much more reading than this to analyse the impact but the long and short of it is that GL Hearn consider there is minimal adjustment to make for the student demographics effect and arrive at a ‘draft conclusion on the overall need for housing’ in Guildford Borough at:

620 to 816 Homes per Year

…that is equivalent to 1.5 to 2 Solums in town every year or a Wisley every there to four years out of town.

It is now time to talk urgently about our CONSTRAINTS because very few people think we could actually cope with growth on this scale without completely changing our character and probably forfeiting a large portion of our quality of life.

 

 

Local Plan Consultation Initial Feedback

The Council has published the first look at the types of comments received in response to the Draft Local Plan.

The sheer volume of responses means that it will take some time to assimilate them all, but the initial summary is available via the link below:

20141024_Initial_feedback_on_the_draft_Local_Plan_consultation

The Local Plan timetable has been reviewed and it is expected that the next iteration will not be available for public review until the second half of 2015.

Guildford 5-yr Housing Strategy

Guildford Borough Council has launched its five-year housing strategy consultation (ends 16th December 2014)

A link to the consultation page is here and the documents are attached below:

Draft_Local_Plan_consultation_questionnaire_and_monitoring_form

Hsg_Strat_2015-20_DRAFT_Appendix_1_-_General_statistics_Nov14

Hsg_Strat_2015-20_DRAFT_Appendix_2_-_Updated_guidance_on_rents_and_affordability_Nov14

Hsg_Strat_2015-20_DRAFT_Appendix_3_-_Affordable_housing_stock_in_the_borough_Nov14

Hsg_Strat_2015-20_DRAFT_Appendix_4_-_Rural_housing_needs_surveys_Nov14

Other documents referred to are:

Housing_Needs_Assessment_Report

Housing_Strategy_Interim_Statement

Homelessness_Strategy_2013_-_2018

There is perhaps some irony that the Lead Member for housing, Cllr Sarah Creedy, sets great store by the ambition to “maximise the proportion of affordable housing” provided, and yet the development company she owns with her husband was apparently unable to provide a commitment to a single affordable unit in a conversion to nine flats of a building in Central Guildford.  It may be we are not in possession  of all of the facts but here was an opportunity for Cllr Creedy to commit to, say, one of the homes being rented out at 80% of market rent or sold on an equity share basis without substantially diluting their return.

Aim 1.8 sets out the following: “Ensure that the mix of new affordable homes on any development is appropriate for the proposed locality taking account of the existing supply and local need

Of signifcant interest in the Local Plan process is the section on HMOs (Houses in Multiple Occupation) on page 36 of the main document:

“Houses in Multiple Occupation
Houses in Multiple Occupation (HMOs) or shared houses provide flexible accommodation for a range of households within the private rented sector. They comprise a significant part of the private rented market in Guildford.
We carried out a mapping exercise in 2011 to identify the extent of HMOs. This indicated that there were approximately 2521 in the borough, of which 1417 were in the Guildford town wards of Friary and St Nicolas, Westborough and Onslow. Moreover, there are likely to be many more HMOs created in the borough since then, due to the introduction of permitted planning rights in 2010. These rights allow a change of use of a house or flat from being occupied by a single household to a HMO for between 2-6 people.
The necessity for HMOs is accepted as an inevitable result of the lack of housing, house prices within the town, and the popular and expanding higher education institutions. While there is often an assumption that HMOs in Guildford are lived in by students, this is often not the case.
Many young professionals who are unable to afford to live in the town without sharing occupy HMOs. For some tenants it is the accommodation of choice. Furthermore, the cost of transport from outside the borough can outweigh rental costs so many people who live in HMOs are working in the Guildford area to avoid commuter journeys, or because of the close proximity to the borough’s rail stations.
The expansion of the private rented sector and HMOs in particular has given rise a number of perceived issues which are affecting residents.
They are the impact of having a high concentration of HMOs in parts of the town can contribute to:
 Poor housing standards in HMOs and non-compliance with housing standards
 Poor neighbourhood relations, including antisocial behaviour
 Nuisance from noise, rubbish and parking

The aspirations in the document (from a cursory read) do not seem misplaced but it is important to recognise that this is a key opportunity to ensure that one of the principal inputs to the Local Plan (demand side) has been reviewed.

As always we welcome comments and feedback.

 

Guildford Society Local Plan Submission

Set out below is the Guildford Society Local Plan Submission made on 19th September 2014.

The full (rather large) submission includes the previous representations made to the earlier consultations:

20140915_GSOC_LPResponse_FINAL-full (ca 55Mb)

This is made up of:

Cover Letter

20140917_LTR_BarryFagg-LPresponse

Submission

20140915_GSOC_Response_to_ConsultationDraftLocalPlan_FINAL

Site by Site Analysis

20140917_Site-by-Site_Response_FINAL

Sustainability Appraisal Responses (Jan 2013)

20130122_ScopingDocument-Response_GVG

Issues and Options Response

20131129_GSoc_LOCALPLAN_CoverLetter

20131128_GSoc_LOCALPLAN_Submission

Strategic Housing Market Assessment

20140220_LTR_CarolHumphrey-SHMA

20140220_SHMA-Response

Guildford Society Population Analysis

20140221_PopulationAnalysis

Guildford Society Analysis of Middle and Lower Super Output Areas

20140904_LandUses-MSOA-LSOA_FINAL

The response is substantial and follows a major consultation exercise by the Guildford Society where six public meetings have been held and the Guildford Society approach and views have been explained.  Not everything in the response is likely to please everyone but the intention is to be as objective as possible whilst trying to ensure the outcome is the best the can be achieved for Guildford.

 

Julian D S Lyon MBA FRICS

18th September 2014

Summary of Local Areas

Having criticised the absence of core data for individual areas in the Borough, here is a summary of the demographics and multiple deprivation indices for each so-called Lower Super Output Area across the Borough.

The file is around 20Mb but it does contain a lot of data!

20140831_LandUses-MSOA-LSOA

The Guildford Society will be including it as part of its response to the Draft Local Plan.

Time running out for comment

The Consultation Period ends on 22nd September and the Guildford Vision Group and Guildford Society talks on Town Centre Vision (3rd September at the Millmead Centre) and Local Plan Submission (15th September at the Trinity Centre) are coming up fast.

The Clock is Ticking – or is it a Time Bomb?

Julian D S Lyon MBA FRICS
 
The Consultation Periods for the Town Centre Vision and the Draft Local Plan both end on 22nd September.
 
Guildford Vision Group and Guildford Society talks on Town Centre Vision (3rd September at the Millmead Centre) and Local Plan Submission (15th September at the Trinity Centre) are coming up fast.
 
The Town Centre Vision is a vital component of the Local Plan – a once in fifty to a hundred year opportunity to reclaim the riverside from traffic and create a fabulous environment in which to live, work, study and play.  The Surrey Advertiser (Friday 29th September) gave a glimpse of the GVG concept plan to reroute the traffic to the west of the town centre and to create pedestrian priority around the river and between the town centre and the station, university and cathedral.
 
A viable and vibrant town centre needs plenty of people living in the town, and yet much of the town centre (believe it or not) scores in the most deprived 3% of local super output areas (‘LSOA‘s) in the country for outdoor living environment! Simply piling more housing into town without comprehensively resolving that issue would simply be wrong.
 
The Local Plan – if you had just arrived here and read the column inches in the media – would seem to be all about the complete devastation of the green belt and the imposition of an astronomic number of homes per year.
 
However much it may feel like that is the case, the reality is different.
 
The amount of green belt (in net terms) proposed for development is quite small and the housing numbers at 652 are high but our run rate to 2011 since 1931 averages 495 homes per year.  Recent press reports emphasise the pressures on our population numbers and the Government is trying to deal with a current housing shortage.
 
The approach has been wrong.  Perhaps some of the sites proposed are wrong.  The mathematics seem to be inexplicably wrong. The evidence base is a poor starting point for some fundamental changes to our spatial planning.  These are all good reasons to respond robustly to the Local Plan Consultation.
 
On the other hand, there are some major spatial planning issues that really need addressing:
 
We have (in this generally wealthy borough) thirteen LSOAs in the poorest 50% in the country and one in the poorest 25% nationally under the Multiple Deprivation Index.  This in itself seems like a small local area to work on but drilling down into details tells a different story. 
 
  • We have several areas in the most deprived 5% in the country for access to housing and services.
  • We have one particular area where, even in this generally well-educated borough, we are in the poorest 2.5% in the county for young person’s education and skills.
  • We have some wild extremes of performance across the borough in many of the other deprivation domains
 
Alongside this challenging set of statistics, we know our infrastructure has lacked meaningful investment for decades.
 
Guildford, as a second tier authority, cannot solve many of these issues alone – there needs to be a shadow unitary authority to actually get things done – but it can lay the groundwork by allocating land for solutions and delivering real vision and leadership through the Local Plan.  
 
There are many other issues that the Local Plan should seek to resolve.  Many of these issues will require major investment and, absent contributions from Government, we will need developments to help finance some of these solutions.
 
My experience tells me that small-scale developments will not fund such deficits and so, from the data I have examined rather than from reading the evidence base, I am persuaded that we need to think bigger than nibbling at the edges or pulling up the drawbridge.
 
Looking at the town centre again, we do need more people living in the town centre but we need them and the current residents to have better access to a great outdoor environment – designed for living in, not requiring a constant fight with traffic to get from A to B, without having to breathe in pollutants from traffic sitting in queues belching exhaust fumes into the air.  Town centre homes can reduce the pressure on the green belt but preserving one environment (green belt) whilst destroying another (Guildford Urban Area) would not be sustainable.
 

I do not think the Local Plan has got it right and the Guildford Society will be responding robustly.

 
Despite the personalisation of the public responses – born out of understandable frustration but, in my view, quite misdirected – I do believe that Cllr Mansbridge is the kind of leader who can make a difference.  We have two specific tasks in the next three weeks and thereafter:
 
  • submit our objective responses to the Draft Plan, the Town Centre Vision (Oh, yes, and the Habitats consultation and the upcoming Surrey County Council Transport consultation); and
  • follow up to ensure our respective comments are noted and reflected in the next iteration.
I hope we will finish up with a Local Plan that gets to grips with the issues, seizes the right opportunities and leaves the majority of the borough intact.  To paraphrase Cllr Mansbridge’s recent statement:
 
IN ORDER FOR MUCH OF THE BOROUGH TO STAY PRETTY MUCH THE SAME, SOME THINGS WILL HAVE TO CHANGE, and the Local Plan is about making those changes in the least impactful way.

Guildford Society Local Plan Talk: 5 – The Draft Local PLan

On 17th July, The Guildford Society presented a summary of the contents of the Local Plan.

20140717_LocalPlanSlides-DELIVERED

There will be a further talk on September 15th when the proposed submission will be summarised and explained.

Look out for details on the Guildford Society Web Site

Draft Local Plan Consultation

It has taken some time to get the Consultation Draft on-line as there have been plenty of late amendments to evidence documents to consider.

The consultation went live on 1st July 2014 and there is a drop in shop at 25, Swan Lane, Guildford in which everyone can inspect documents, make comments and give feedback.

It is worth stepping back from any debate about whether we like the plan and recognising the huge amount of work put in by officers and Councillors (especially Councillor Juneja who has the lead for the Local Plan).  It is easier to criticise the documents than to prepare them.

We have criticised elements of the Evidence Base and some of the shortcomings have led to some issues in the policies and narrative.

Stepping back from the documents and looking afresh, it is evident that the Local Plan may be too general in places and not enough about Guildford and our specific issues.

All of that notwithstanding, we should thank officers and Councillors for their hard work.

Here are the documents (and there are a lot of them).  The Guildford Society slides from the fifth talk in its Local Plan series will be provided on a separate post on this website and at www.guildfordsociety.org.uk.

The Draft Local Plan

Three ‘Topic’ Papers (issued on 17th July 2014)

The Evidence Base (at the Consultation launch on 1st July 2014)

We have grouped these according to our own approach.   There is no such grouping in the Draft Plan nor on the GBC Website: http://www.guildford.gov.uk/evidencebase

The Vision and Priorities

Although the Council’s Corporate Plan (2013-2016) will have run its course when the Plan is due to be adopted, it forms a significant part of the basis of the vision and strategy in the Draft Local Plan:

Constraints (Issues to be addressed AND/OR impacting on Development)

Infrastructure Baseline

Town Centre Vitality and Viability Report

Access & Transport

Guildford Town Movement Strategy

Growth Options and Scenarios

Green Belt & Countryside Reports

Flood Risk Assessments

There are several documents on the Borough’s website (not directly copied here) which will inform constraints but which would require technical assessments of any strategy or proposed development:  I have included the lnk to the GBC web page for any up to date documents

At the time of writing, the Flood Risk Assessment dates from 2010 (pre-dating the major flood event in 2013) and those documents are provided below:

Sites of Nature Conservation Importance

These survey reports date from 2004-2007; there should have been updated versions available in parallel with any review of green field sites and options.

Surface Water Management Plan

This report dates from 2013

Habitats Regulation Assessment

This report dates from 2013

Land Uses

Objectively Assessed Need and Demand

Strategic Housing Market Area Assessment

Affordable Housing Viability

Traveller Accommodation Assessment

Retail and Leisure Study

Updated from 2006 reports which themselves were based on 2004 data

Economic and Employment Need

no specific papers in the evidence base

Land Availability Assessments

Strategic Housing Land Availability Assessment

Traveller SHLAA

 Employment Land Availability Assessment

Qualitative and Character Analyses

Sustainability Appraisal

Settlement Profiles and Hierarchy

Landscape Character Assessments (2007)

Conservation Areas Character Assessments

 Open Space and Green Infrastructure (2006)

Public Scrutiny to Begin

Following a long introduction – almost entirely hijacked by Housing Numbers and Green Belt issues, the Guildford Draft Local Plan opens for Public consultation on 1st of July for 12 weeks.

Following a long introduction – almost entirely hijacked by Housing Numbers and Green Belt issues, the Guildford Draft Local Plan opens for Public consultation on 1st of July for 12 weeks.

The Guildford Society will be hosting an open meeting on 17th July to introduce its view on the document itself and will follow that by a further session in September to present its proposed representation.  You can find out more about these and other GSoc meetings at http://www.guildfordsociety.org.uk.

There are some very key issues in the draft document – all of these need thorough examination along with the associated evidence base (which will be reproduced on this site at the launch of the consultation so that we can assess the report against the evidence base at the time and not be hoodwinked as the evidence evolves.

The Green Belt and Countryside Report (with its thousand or so page addendum) will energise many and as a starting point, it is disappointing that this report – flawed in its conception prior to the 2012 NPPF and in its failure fully to capture the options and its pejorative treatment by the planning department.  That is a legitimate target for analysis and representation in responses to the Local Plan.

My own (Julian Lyon) view is that the Green Belt report and its treatment in the draft Local Plan is half-baked and therefore not ready to form a key plank of this significant planning policy document.  The Green Belt, in my clear opinion, remains a constraint as far as the capacity of the Borough for development is concerned.  This should, therefore, inform the housing target.

Please do not confuse this assessment with an absolute rejection of the principle of realigning the green belt or allowing some development in the green belt.  It is not.  If the case were proven that real harm would be inflicted on Guildford and the Borough, the remedying of which would outweigh the harm to the Green Belt of releasing some strategic sites, this would be legitimate grounds for advancing each case on its merits.  What it is, however, is the recognition that the debate over the relaxation of a legitimate constraint risks scuppering or substantially emasculating the entire Local Plan.

It is also the case that the evidence is not yet so overwhelming and emphatic as to demonstrate an absolute imperative to realign the green belt.

My recommendation is to treat the Green Belt as a constraint for the purposes of the Local Plan, anticipate that we will fall short of the Objectively Assessed Housing Need (unconstrained) and plan for an early review of the Green Belt as a separate exercise undertaken with neighbouring Local Authorities (ideally on a Surrey-wide basis) to ensure the integrity and long-term protection of the Green Belt is maintained.

Such a twin-track approach has been undertaken elsewhere (Dacorum’s Local Plan was found sound because, despite selecting a target number below Objectively Assessed Need, they committed to an early review within five years.

This leads on to the Housing Numbers which have caused much angst.  On this site I have tried to provide an objective analysis of the data and the reasoned assessment of the reports.  I find it very difficult to reconcile the outputs provided by GL Hearn in their Strategic Housing Market Assessment (SHMA) and the response a group of local experts received when we challenged them.

The key point to note – before the detailed analysis takes over – is that the draft Local Plan number of 652 (which may yet change between now and 1st July) was derived from data before the Office for National Statistics adjusted the population projection downwards (see elsewhere on this site for details).  We can expect robust arguments to the effect that this number should be significantly reduced.

There is a policy in the Draft Local Plan (Policy 4) which sets out to fix a problem of the affordability of homes for those on the housing list (about 3,500 – remaining resolutely constant year on year) and for key workers who currently have to commute large distances to their places of employment.  Fixing this is a reasonable aspiration, nobly led by Councillor Creedy, and so the policy sets a level of 40% (45%) of new brownfield (Green Belt) homes to be affordable.

In the Surrey Advertiser (20th June) page 4, are two development proposals which together total 58 units.  The schemes are being brought forward under the 2003 Local Plan which has as its target 30% affordable homes.  There is a get out for developers who do not have to provide this level of affordable housing if it is not viable.  The Surrey Advertiser reports that “affordable housing was judged by applicants to not be viable on either site” and this at 30%.  One has to question, therefore, whether a policy based on self-assessment by the applicants and which would have determined the amount the applicants paid for the land (to the extent that if the policy is weak the highest bidder for the land might assume minimal affordable housing) could ever deliver the numbers of affordable homes Guildford needs irrespective of the housing target.

GL Hearn stated clearly that their assessment of the housing need was substantially driven by the non-affordability of homes in Guildford.

There are three further topics for consideration at this point which are worthy of greater scrutiny:

  • Employment Land and Employment Growth
  • Infrastructure and the historic Infrastructure Deficit
  • The Town Centre Vision

I do not propose to go into detail on these except to highlight that the Town Centre should be regarded as key infrastructure for the Borough as a whole – albeit it contains and requires its own infrastructure.

There are no clear links between Employment, Infrastructure constraints and Housing numbers.  The NPPF is clear in its call for Local Plans to show clearly that these aspects are integrated.  This Draft Local Plan is based on some very poor evidence (shortcomings identified here on this site and elsewhere) although there may be a flood of new evidence documents published as the consultation goes out.

There is no real attempt to establish the CAPACITY of Guildford for growth and there is no clearly set out strategy for increasing that capacity through the Local Plan to meet the objectives of the Local Plan itself.

For this reason I spoke at the Joint Scrutiny Committee meeting several weeks ago to say the plan is not yet ready for consultation.  At the Full Council meeting on 19th June fourteen of the forty-one Councillors to vote one way or the other agreed with me.

Twenty-seven did not and so the consultation begins and we have to tackle both the shortcomings of the document itself as well as its content.

As an aside, I would be surprised if we do not see applications from several land owners in the Green Belt come forward with Outline Planning Applications over the next several weeks.  Pandora’s box is open and the responses we give to the Local Plan process may well need to be replicated to the extent the applications are premature, inadequately provided with infrastructure due to the historic deficit or that the harm done to the Green Belt outweighs any Very Special Circumstances they may argue as mitigation for their proposals.

The ball is in play, the game is in progress and we are told that every view will count so, whatever you do, do not rely on someone else to make your points for you.  Respond for yourself and help to shape responses of groups like The Guildford Society.

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