Guildford Society Hearing Statement

The Guildford Society has submitted its Hearing Statement to the Inspector’s Programme Officer ahead of the Guildford Local Plan Examination in Public which begins on 5th June.

Here is a full set of the GSoc documents:

0_20180510_GSoc-EIP-Submission-LETTER
(cover letter)

1_20180510_GSoc-EIP-Submission-MAIN
(main document)

2_20180510_GSoc-EIP-Submission-APPENDIX1
(GSoc SANG Paper by Alderman Bridger)

3_20180510_GSoc-EIP-Submission-APPENDIX2
(GSoc Infrastructure Topic Paper by the Transport Group)

4_20180510_GSoc-EIP-Submission-APPENDIX3a
(Correspondence requesting confirmation from GBC on which if any groups were excluded from interacting with officers at the Council)

5_20180510_GSoc-EIP-Submission-APPENDIX3b
(copy of internal email instruction to officers to not engage with the Guildford Vision Group)

6_20180510_GSoc-EIP-Submission-APPENDIX4a
(Correspondence requesting explanation from GBC about the £5m contribution agreed with the Dunsfold developers to mitigate against impact of development on Guildford)

7_20180510_GSoc-EIP-Submission-APPENDIX4b
(Guildford Borough Council response on Dunsfold showing an increase of traffic on the gyratory of circa 300 cars over the three peak hours)

8_20180510_GSoc-EIP-Submission-APPENDIX5
(Agreed Statement of Common Ground with the Guildford Vision Group – highlighting GSoc’s support for the GVG Master Plan)

9_20180510_GSoc-EIP-Submission-APPENDIX5-1
(file 9 is a large (160mB) document containing the GVG Master Plan)

Representations were limited to 5,000 words and (headings apart) the GSoc response keeps to that restriction, albeit many comments the Society would have wished to make were omitted.

This submission follows the previous responses to the earlier consultations on this draft Local Plan which can all be found on this website (referenced below):

The Guildford Society Submission
(response to the Issues and Options consultation 2013)

Guildford Society Local Plan Submission
(response to Local Plan Regulation 18 consultation 2014)

GSoc Local Plan Reg19 Consultation Submission
(response to Local Plan Regulation 19 consultation 2016)

GSoc Response to 2017 R19 Consultation
(response to Local Plan Regulation 19 consultation 2017)

Finally, here is a personal commentary written by the Chair of the Guildford Society, Julian Lyon, at the end of March, following comments by the Inspector on the submission draft local plan:

20180331_LocalPLanCommentary_FINAL

 

 

Local Plan – comments on Inspector’s Feedback to GBC

As I understand it, GBC has had a QC and a Planning Inspector on its team to try to navigate its course through the Local Plan process.

The report by HM Planning Inspector (Jonathan Bore) dated 23rd March seems to suggest some basic flaws in the draft plan “many of which will require the council to produce Main Modifications to the plan’s policies and text”.

Let’s take a look at the report and Mr Bore’s comments along with some context from the Guildford Society’s comments in respect of the most recent consultation.

Mr Bore begins by challenging the SHMA (Strategic Housing Market Assessment). He questions why there is no analysis of the deterioration of affordability ratios between 2014 and 2016. He highlights the approach taken by GLHearn to adjust the OAN (Objective Assessment of Need) to reflect household formation rates amongst the 25-34 age group and pointed to his (Mr Bore’s) rejection of a similar approach (by GL Hearn) in Waverley.

Mr Bore notes that “the level of identified affordable housing need is exceptionally high“ and requests a paper be produced by the Council to identify the required uplift to the OAN that would be “expected to improve market housing affordability and deliver as many as possible affordable homes”. Mr Bore states that this should be a “policy off” analysis.

It should be noted that one of the criticisms the Guildford Society has consistently made throughout the Local Plan process has been that the Evidence Base has followed the plan rather than the policies being based on the evidence (the latter being a “policy off” approach).

There is a duty to co-operate baked into the NPPF (National Planning Policy Framework) and this should have meant including in the OAN the unmet needs of surrounding boroughs (the majority of whose local plans are more recent and settled). Mr Bore requests a paper from Guildford Borough Council to demonstrate how unmet housing need in the Housing Market Area will be accommodated.

Mr Bore expresses his concern about the Council’s proposed stepped housing trajectory (however sensible that may be under the circumstances) and says “this appears to be an unacceptable aspect of the plan and the Council needs to consider the steps that should be taken to improve housing delivery in the earlier years of the plan.” He requests a paper from the Council with an amended trajectory and in particular the relationship between improvements to the A3 and other infrastructure projects and that trajectory.

The Guildford Society expressed concern about the stepped trajectory because, in each of the first five years of the Local Plan period, Guildford would not be able to demonstrate it can meet its 5-year housing land supply target and all and any development proposal (in line with the plan or not) would be fair game – the very antithesis of positive plan-making.

Another consistent Guildford Society criticism of the Evidence Base has been the woeful, flawed, and to-date-unamended Settlement Profiles Report. Mr Bore highlights that the Spatial Development Strategy shows no indication of “the numerical balance of housing development between different settlements”. The Council has been hamstrung by its poor Evidence Base in this regard which neither indicates what development might be required in each settlement nor establishes the basis on which the provision might be achieved – and neither does it establish any quantum that might be taken on by any neighbourhood plan. Again he requests a paper to show how this might look in practice.

Mr Bore’s fifth point is straight out of the Guildford Society list of criticisms. Mr Bore identifies that, with so much identified unmet housing need, the Council persists in favouring alternative uses to protect other uses. This approach was demonstrated by the choice to build a Waitrose supermarket on an unsuitable site in the town centre over and above using the site for housing (a broadly similar land value) which could have accommodated 250 homes at a similar density to the nearby Printing House Square.

The Guildford Society questions the need for the quantity of retail space on the North Street development and also supports the principles of the Guildford Vision Group in seeking to regenerate the riverside in such a way that many of the inefficient land uses can be replaced by residential units.

The Guildford Vision Group has highlighted that the Council’s failings in planning the town centre has led to additional pressures on the Green Belt. Mr Bore agrees.

It is interesting to note that Guildford Borough Council has a Town Centre Regeneration Strategy (TCRS) that is in several respects non-compliant with the Local Plan because of its repurposing of designated employment land for residential development. The Council did not adopt the TCRS because it would undermine its Local Plan process, and yet, the Inspector is saying that this was precisely what was needed to help deliver unmet housing need.

The Guildford Vision Group approach looks highly coherent in this regard against the Council’s “same old” approach to spatial planning.

Mr Bore questions the strategy for student housing – and the Local Plan draft for simply setting a campus-based rule without applying a land allocation and quantum to the plan to deliver it.

The Guildford Society has been critical since 2013 of the Green Belt Evidence Base which failed to make the case for (a) any development in the Green Belt; and (b) for the exceptional or very special circumstances in each case for incursions into the Green Belt or the redrawing of the Green Belt boundaries. The Society has not taken the one-size-fits-all approach of arguing that no adjustment of the Green Belt need be made. Rather we have argued that any adjustment needs to be well argued, permanent and sustainable. The Society has also argued that, as part of redrawing the Green Belt boundaries, the Council needs to have identified how it will provide land for future Plan periods so that its policies are sustainable in the long term.

The Inspector has agreed that the Green Belt policies lack clear explanation of exceptional circumstances (strategic and local – back to the settlement profiles again).

The Guildford Society and the Guildford Vision Group have both consistently criticised the draft plan for its failure to require good urban design. Mr Bore has agreed. He says “there is nothing about the masterplanning of large sites” and goes on to note another bugbear of both groups as to “how the public can engage in the overall masterplanning process or how overall masterplans and the different components of the larger schemes are to be subject to design review – essential parts of the urban design process”. Mr Bore goes on to say that “the Council should take advice on the techniques available for reviewing both the quality of existing places (such as Place Check) and on the quality of the design of emerging schemes (for example through public comment on 3D modelling)”. This could have been written to express the issues with Solum and similar schemes, but equally the stand-offish behaviour of the Council with regard to the Guildford Vision Group’s excellent strategic views (whether one agrees with them or not).

Mr Bore makes various other points which I will not cover here, but he is very clear in his condemnation of the proposed indicators (most of the negative) scattered through the plan.

The comments on Employment demonstrate that Guildford Borough Council is failing businesses. We already know that three major corporations with their headquarters located in Guildford in about 200,000 square feet are planning to move away from Guildford with the principal reasons being traffic congestion and poor transport connectivity, and the lack of homes in the borough that employees can afford.

The Inspector’s comments also seem to suggest that he finds the draft Local Plan to be incoherent in its land use allocations, and that is exactly what this Local Plan is meant to be for, and it does not plan positively (particularly in its monitoring indicators). In many of the places Guildford Borough Council has sought to include behavioural or sustainability controls, Mr Bore has found them to be unduly onerous and requires them to reflect the NPPF.

Mr Bore comments relatively little on infrastructure but does hold out an olive branch to the Council’s attempts to restrict development before infrastructure is in place. He suggests that there should be allowance for a so-called ‘Grampian’ condition which could achieve this. It is not clear how this would sit with the requirement to retain a 5-year housing land supply at all times as it would almost certainly lead to uncontrollable development or a meaningless housing target. This seems to be inconsistent with Mr Bore’s earlier dismissal of Guildford Borough Council’s proposed stepped housing target. It does, however, echo what many respondents to every consultation since 2013 have said about housing and infrastructure.

The Council’s approach to the town centre – singularly lacking in the Local Plan – is predicated on modal shift. The inspector dismisses as “unlawful” one of the main planks for reducing town centre traffic, namely, the denial of access by residents, through planning restrictions, to parking permits.

This response by Mr Bore may be the beginning of the unravelling of the Council’s unrealistic approach to town centre land-use planning, infrastructure and masterplanning. It certainly makes the Guildford Vision Group look to be a much more coherent force in planning the town than the Local Planning Authority.

It is not ‘back to the drawing board’ for the Council but it does seem an awful lot of time and money has been wasted – perhaps a lot of this could have been prevented had the Local Plan Forum not been quietly dispensed with in the post-Mansbridge era.

It does now seem unlikely that the Council can meet its own proposed timetable for the Local Plan and it seems inevitable that it will need to undergo further consultation. This would give plenty of opportunity for inserting a positive plan for the Town Centre, and it would seem appropriate to incorporate the well-considered Vision Group plan, in large part of not in full, within the body of the Local Plan – as had been argued back in 2014 when the leaders of the Council (at the time) were arguing that to include the town centre masterplan would delay the urgently needed Local Plan.

GSoc Response to 2017 R19 Consultation

After a six week period to review literally thousands of pages of plan and evidence base, here is the response from the Guildford Society:

20170724_GSOC_RESPONSE_R19-LOCALPLAN_FINAL-redactedsignature

This document has been prepared as a record of the concerns the Guildford Society has about the plan as drafted, but not with the aim of killing or delaying the adoption of a sound local plan for Guildford, which the Society agrees is very important.

A file with a hard copy of this response was delivered by hand to Guildford Borough Council at 08.15 am on 24th June 2017 before the 12.00 noon deadline.

——————————————————————————————————————————–

An addendum was provided by email to Tracey Coleman at Guildford Borough Council at 11.18 with some further comment from the Guildford Society Local Economy Group:

20170724_Addendum-and-Corrigendum

——————————————————————————————————————————–

Here is a complete version with the Addendum inserted at the appropriate paragraphs:

20170724_GSOC_RESPONSE_R19-LOCALPLAN_FINAL_revised_Redacted

 

 

Reg 19 Local Plan Consultation 2017

Guildford Borough Council’s consultation website with all of the documents can be found here.

The consultation ends at 12.00pm (noon) on 24th July 2017.

The consultation documents as they stand at 12.37pm on 17th June 2017 are set out below:

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_and_Appendices_A-G

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_Appendix_H_Maps_A-G

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_Appendix_H_Maps_H-P

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_Appendix_H_Maps_R-W

ERRATA_for_Proposed_Submission_Local_Plan_June_2017

Continue reading “Reg 19 Local Plan Consultation 2017”

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.

 

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.

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

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