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.


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.


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.  



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.



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)


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


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.


First Look at Draft Local Plan

Guildford Borough Council has published its Draft Local Plan for acceptance as a draft by the Joint Scrutiny Committee which meets on Thursday 15th May.

The full committee papers can be found here: http://www.guildford.gov.uk/article/12360/Joint-Scrutiny-Committee—15-May-2014


The draft plan and annexes are available on that site or via the links below:





20140515_Report2JtScrutiny 20140515_


The four thousand pages or so of evidence and plan published over a three week period mean there is much to digest and will be the subject of the next Guildford Society Local Plan open meeting in July.


Revised SHMA Published

Guildford Borough Council has published its revised SHMA report.

On the face of it, this is likely to cause almost as much consternation as the previous incarnation – the numbers are not much changed after all.

Here are the documents – another 800 pages or so to plough through.  Spare a thought, I guess, therefore, for the Councillors who also have to go through these documents and who, unlike officers, are not paid for the task.








As always the documents can be found on the Council’s website: www.guildford.gov.uk/shma


Supplementary Green Belt Study

Guildford Borough Council has today (30th April 2014) published an addendum to Volume 2 and a new Volume 5.

Together these documents add a further 485 pages to the Evidence Base.

Clearly this will take some time to digest and so I have provided them below – in two large files incorporating all of the appendices.

20140430_GreenBelt-Vol2_Addendum (176Mb) and 20140430_GreenBelt-Vol5 (316Mb).

Unfortunately, the plans in the appendices have not been optimised for web viewing which is why the files are so large.

If you would prefer to download them in smaller doses, the Guildford Borough Council link is: http://www.guildford.gov.uk/gbcs

As we will soon be expecting the Draft Local Plan to be issued for consultation, the opportunity may be short to study these documents in great detail.  If it can be done it will be done, and you will be able to read any comments on this site in due course.


GBC Publishes its Strategic Housing Market Assessment (SHMA)

The latest (long-awaited) document in the suite of Evidence Base documents has been published.

The SHMA provides (or is meant to provide) a clearer insight into the need for housing and the market conditions in the Strategic Housing Market.

The SHMA website is live or the documents can be found at the links below:





Analysis of this document is available HERE with a view to responding to the Council on or before 21st February.

initial thoughts from first reading are set out below:

a) too much reliance is placed on data for Guildford instead of the entire Market Area;

b) the Waverley and Woking housing numbers seem to be taken as read (and GL Hearn seem to have a conflict of interest between their representation of Waverley’s housing need and their preparation of Guildford’s SHMA); and, perhaps most importantly

c) perhaps as evidence of that conflict, GL Hearn seem to be preparing Guildford to increase its housing ‘need’ figure threefold while recommending to Waverley a disproportionately lower figure.

d) the SHMA is very confused in its approach to NEED (objectively assessed) and DEMAND

e) the SHMA pays lip service to influences from Rushmoor and Surrey Heath and (despite Guildford Borough’s 12 railway stations) does not regard commuting as sustainable!

The document will take some careful analysis to interrogate its assumptions and conclusions and to draw inferences.

PLEASE NOTE: the questions signposted as the Council’s consultation (as reported in the Guildford Dragon) are not particularly balanced or helpful:

• Should we be seeking to maximise housing delivery to meet the need for housing that has been identified?
• Should we be trying to reduce the cost of housing by boosting housebuilding?
• Should we try to deliver more affordable housing?
• What are the implications of not building enough homes?

In commenting on the Draft SHMA (which, for some reason my predictive text system seems to keep rewriting as SHAM!) I will endeavour to indicate my responses to these four questions.

Always remember that to have a say, you need to register your own comments and not to rely on someone else (even if you whole-heartedly agree with their point of view).

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:


(circa 20Mb)

or in lower resolution:


(circa 7Mb)

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


…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.