Office of National Statistics data show Guildford Borough Council’s housing numbers are too high

The Office of National Statistics (ONS) has just published new population projection data for the whole country (yesterday, 27/2/2015), which can be found here:

http://www.ons.gov.uk/ons/publications/re-reference-tables.html?edition=tcm%3A77-335242

National Planning Policy Guidance was updated yesterday too, to reflect the fact that this ONS projection, as the most up to date assessment of future housing growth, should be the basis of assessment of housing need – see the new guidelines here:

http://planningguidance.planningportal.gov.uk/revisions/2a/016/

The Office of National Statistics estimates that the population in Guildford borough will grow by a total of 21,600 people between 2012 and 2031.

We have reviewed housing need, taking into account outstanding planning permissions, because these clearly affect the number of homes that will be needed.

Our provisional calculation suggests that an annual housing provision below 400 homes per annum would meet Guildford’s housing needs, including that of any incoming population.  This number is before any adjustment for constraints, such as Green Belt, infrastructure, congestion and air quality.

Why is Guildford Borough suggesting that we need 816 new homes per annum- more than double this?

 

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Guildford Borough Council joint SHMA published

Guildford Borough Council has today (18 December 2014) published the West Surrey joint SHMA (Strategic Housing Market Assessment) prepared jointly for them and the boroughs of Woking and Waverley, by the consultants GL Hearn.

GL Hearn prepared a draft SHMA for Guildford borough council in January 2014, with headline housing numbers in a range from 670-800 dwellings per annum. This generated a storm of protest from the community.     After public criticism, that draft SHMA was subjected to a review by Edge Analytics, who said that for some matters they could only give the report “an amber tick”.

A revised draft SHMA was prepared by GL Hearn in May 2014, with revised numbers in a range from 652- 780 homes per year (not a wholesale adjustment).  This was then adopted by Guildford Borough Council in their draft plan without any application of constraints (despite the fact that they could have chosen to apply significant constraints because 89% of the borough is Greenbelt, as stressed by ministerial guidance). GBC also proposed to backdate that housing target to 2011 to generate a housing target for Guildford borough, by 2031, of 13040.  It was pointed out by community members that Guildford had met its objectively assessed housing need to date, so no backdating was required.

It was also pointed out by a number of commentators -including the Office of National Statistics -that the draft SHMA still contained a number of errors, and if the errors were corrected, the calculation of objectively assessed housing need could be shown to be overstated, possibly by as much as 200 homes per annum.  It was also pointed out that Guildford Borough Council – under the previous administration – had gone to the High Court in 2010 to campaign for an interim housing number of 322 homes per year, because the “top down target” of 422 homes per year was judged unsustainable.  That battle was won – the High Court agreed that Guildford could not support 422 homes per year and imposed an interim target of 322 homes.

A number of commentators asked for the calculations and the computer model underlying the GL Hearn analysis to be provided. This request (prepared formally under a freedom of information request, and followed up with an appeal to the Information Commissioner) was refused.

The full combined SHMA has now been published.

GL Hearn have now produced a revised SHMA on a combined basis for the housing market area of Woking Waverley and Guildford.  The numbers for Guildford are now 620-816 homes per year, doubling the previous target (and more), and supporting GL Hearn’s calculations prepared in January 2014.

Guildford Greenbelt Group will study the new SHMA and will prepare detailed comments on the document. The SHMA is available on this link:

http://www.guildford.gov.uk/shma

 

Guildford Greenbelt Group approved as a political party

Guildford Greenbelt Group has been approved by the Electoral Commission as a political party.

The press announcement about this is here:

Guildford Greenbelt Group (GGG)

Press announcement 11 November 2014

GUILDFORD GREENBELT GROUP (GGG) APPROVED AS AN INDEPENDENT POLITICAL PARTY

Guildford Greenbelt Group (GGG) is delighted to announce that the Electoral Commission has given permission for it to stand in future elections.

Political party status means that GGG can campaign, endorse candidates and will not be prevented from commenting on political matters in the run up to an election. GGG has a local emphasis, and is not a national party.  It is not affiliated with any other party. While many of the issues that are faced in the borough of Guildford and in the surrounding areas are being experienced by other communities across the country, GGG’s focus is on helping to resolve these issues from a local perspective and is completely committed to the borough of Guildford and its people.

 The GGG constitution states that:

  • Brownfield land should be used for building before any green fields
  • Housing numbers must reflect real local need, not developers’ wishes
  • Existing legal protection for the Green Belt and the AONB should stand
  • Green fields matter – they are not just building land
  • The Metropolitan Green Belt is for the benefit of all

GGG is supported by many individuals and a large number of campaigning groups, residents’ associations and some parish councils across the whole borough of Guildford, in both the rural and the urban area.

GGG was formed in December 2013 in response to the Issues and Options document prepared by Guildford Borough Council. It has led the most coherent and vocal protest against the draft Local Plan and has led a number of public petitions resulting in public debates in the council chamber. These have varied from topics relating to the protection of the Greenbelt, discussion of the council’s strategy, consideration of specific sites, traveller housing and elements of the local plan, including the Strategic Housing Market Assessment (SHMA) and the housing number proposed for the borough. These petitions have led to a more informed level of debate both among existing councillors and in the wider public domain.

Since its foundation GGG has campaigned against the basis on which the SHMA was constructed (the terms of reference included prior consultation with house builders but not local communities) and the conclusions of that report (which inflated the calculations of need beyond the national statistics for growth). GGG has complained, in conjunction with other local groups, about a number of errors in calculation within the SHMA, and these complaints were confirmed by written comments by the Office of National Statistics which recommended adjustment. This resulted in an undertaking to correct the errors from Guildford Borough Council. It appears from recent GBC publications that the housing numbers are almost unchanged and those errors remain uncorrected.

GGG has also campaigned about other flawed areas within the evidence base of the local plan, including the Greenbelt and Countryside Study, which the consultants concerned have stated was for the purposes of “rolling back the Green Belt” and which indicated that the “openness” of the Green Belt was limited by the presence of trees. GGG has presented detailed criticism of the Settlement Hierarchy and the Sustainability Analysis, neither of which are fit for purpose.

GGG campaigned for Guildford Borough Council to withdraw and correct its draft local plan (subject to consultation over summer 2014) prior to its issue, on the basis that it was in breach of the National Planning Policy Framework (NPPF) and ministerial guidelines, based upon inadequate evidence, and had not met the duty to cooperate. The Executive ignored the Council’s own scrutiny committee which recommended revision of the housing number prior to issue of the plan. Despite this, the full Council voted to proceed with a consultation on the inadequate and flawed first draft, at very considerable public cost and consequential delay.

GGG encouraged members to write to comment on the local plan, provided information to assist members of the public to consider the issues, and is delighted to learn that the draft local plan over the summer had over 19500 responses . Guildford Borough Council noted the level and quality of these responses and it has now withdrawn that draft of the local plan, with a proposed reissue date of June 2015, after the next election.

However, Stephen Mansbridge, the Leader of Guildford Borough Council, has made public statements, after withdrawal of the local plan draft, noting that the “trajectory” of the local plan is unchanged.

Members of GGG have formed the view that it is necessary to stand as a party at the next local council elections because it is only the political process that will allow GGG to participate in decision-making, present detailed views within the council chamber and influence the preparation of the local plan. A formal application to stand as a political party was submitted in July 2014 and has now been approved.

Because the current political structure allows for the Executive model of local council management, overall control being held by the largest party. GGG considers that it is more democratic for all councillors, from all parties to have equal voting rights on decision making, and has started a petition for a referendum, run by a separate company Local Democracy Ltd, for a return to the committee system. If 5243 local voters sign this petition then there will be such a referendum, and it is likely to be most cost-effective and administratively convenient to hold this at the next election (and it appears that Guildford Borough Council are starting to plan for this). GGG have been informed that this petition must be presented in paper form and members of the public, whatever their views on GGG, are invited to sign this petition in order to support more democratic accountability. A copy of the petition can be downloaded from the website or is attached to this press release.

It is important to stress that GGG does consider that there is a need for local affordable housing, to meet local needs.  GGG supports the building of a number of homes in the Borough (including affordable housing). GGG would consider that around 300-325 homes per annum for the life of the Plan (ie until 2031) might be sustainable (this is comparable with the number approved by Guildford Borough Council’s High Court action against the Labour Government’s regional plan in 2010). The plans proposed by GBC, which seem to be still in place, are for 652 homes per annum (or indeed more, since that figure is being backdated by GBC to 2011). This proposal would ruin the rural nature of Guildford borough’s Green Belt and countryside irrevocably. The more moderate housing target for which GGG is campaigning (comparable with other areas in the home counties) will satisfy local housing need whilst protecting the Borough from being overwhelmed by development pressure and unchecked demand.

However, the view of the membership is that there is definitely sufficient brownfield land to meet all genuine local need. The draft plan has inflated demand assumptions in order to create pre-determined justification for greenfield building, which would generate profits for developers in the local area. GBC have commented that there is indeed considerable brownfield land, especially in the urban area – and this is sufficient to meet even its own inflated housing target. GGG doesn’t want to build so many homes, but the point is that GBC’s housing target does not create any justification under current guidelines and law that will permit it to use Greenbelt land. However, GBC submits that the available brownfield cannot be used as part of the five year supply (although their own consultants disagree) and therefore that Greenbelt land needs to be used. GGG considers that this is unjustifiable.

GGG has members and supporters throughout the borough. GGG will now start the process of considering candidates who will stand in the elections in May 2015. New members will be able to put themselves forward for candidacy provided that they support GGG’s aims and values. New members are welcome and more information on GGG can be found on its website, and information for new members is also available at GGG’s public meetings.  The intention is to field candidates in all wards where existing councillors do not already have a history of acting and voting to protect our countryside and where councillors have supported the discredited draft local plan.

The very recent by-election in Lovelace ward, held towards the end of the consultation on the draft plan, shows the strength of public feeling on the Greenbelt.   This was won by a significant margin by Colin Cross, overturning a historical Conservative majority; and his campaigning stressed that he was a GGG supporter; clearly he has not yet had an opportunity to vote on or influence the drafting of the Local Plan.

Guildford Borough Council have announced that a new local plan will be issued in June 2015. It is unclear that this will be substantially different (see notes to editors).   Unless we see a radically different draft soon, with a substantially reduced housing number, that Local Plan constitutes a silent manifesto for all existing councillors. Any councillor that did not oppose that plan is implicated by its proposals.

GGG argues that it is necessary to change the local political framework so that local councillors listen to local people.

Voting for GGG will enable voters to get:

  • Local interests represented
  • Protection of our countryside
  • Probity in planning
  • High quality rational analysis by councillors
  • Better decision making in the council chamber
  • Realistic appraisal of infrastructure (including roads and schools) in planning
  • Recognition of the importance of the environment in decision making

Susan Parker, GGG leader, commented:

“We are delighted that we can now stand for election as GGG candidates.

 “We believe in protection of our countryside. This will benefit all members of society, whether they live in the town or countryside, or in the London metropolitan area. The beautiful countryside in which Guildford is set makes it one of the best places to live in South East England, and it is a wonderful place to visit and for those in the urban area to come to for relaxation. But it is subject to enormous development pressures. In all our interests we need to protect our countryside.

 “Very few existing local councillors or elected representatives have spoken up for the countryside, and none have done so effectively.

 “We need to stand up for our countryside and so we will be standing at the next election.”

 

 

Notes for editors 

  1. Further information on GGG is available on the GGG website http://guildfordgreenbeltgroup.co.uk

Or on its facebook page:

https://www.facebook.com/Guildfordgreenbelt

  1. GGG public meetings, open to all members of the public, will be held as follows:
  • 17 November 2014 -Send Social Club -7.30pm
  • 9 December 2014 -St Albans Hall Wood Street Village -7.30pm
  • 28 January 2015 -Fairlands Community Hall -7pm
  1. For details on the current housing numbers proposed by GBC see documents published in November 2015, after supposed withdrawal of the draft Local Plan. However, this document only refers to the Local Plan being in draft, not subject to complete revision:

http://www.guildford.gov.uk/media/18112/Draft-Guildford-Borough-Housing-Strategy-2015-20/pdf/HOUSING_STRAT_2015-20_DRAFT_STRATEGY_Nov14.pdf

In particular see p10 which refers to proposed development per the Local Plan of 652 homes per annum

See also Appendix 1 to that housing strategy:

http://www.guildford.gov.uk/media/18113/Draft-Guildford-Borough-Housing-Strategy-2015-20—Appendix-1/pdf/Hsg_Strat_2015-20_DRAFT_Appendix_1_-_General_statistics_Nov14.pdf

this states that the objectively assessed housing need is for between 650 and 780 homes per year

 

 

 

 

 

 

Brownfield first is now government policy

We have had a major change in government policy – for which we should be grateful, I think – but we need to make sure that this is not just tokenism.

George Osborne gave a major speech at the Mansion House – full text is here:

https://www.gov.uk/government/speeches/mansion-house-2014-speech-by-the-chancellor-of-the-exchequer

Scroll down the speech to find this:

“We’ve got the biggest programme of new social housing in a generation; we’re regenerating the worst of our housing estates; and we’ve got the first garden city for almost a century underway in Ebbsfleet.

Now we need to do more. Much more.

We have beautiful landscapes, and they too are part of the inheritance of the next generation. To preserve them, we must make other compromises.

If we want to limit development on important green spaces, we have to remove all the obstacles that remain to development on brown field sites.

Today we do that with these radical steps.

Councils will be required to put local development orders on over 90% of brownfield sites that are suitable for housing.

This urban planning revolution will mean that in effect development on these sites will be pre-approved – local authorities will be able to specify the type of housing, not whether there is housing.

And it will mean planning permission for up to 200,000 new homes – while at the same time protecting our green spaces.

Tomorrow, Boris Johnson and I will jointly set out plans for new housing zones across London backed by new infrastructure, so that we see thousands of new homes for London families.

And we’ll take the same approach in the rest of the country; with almost half a billion pounds of financial assistance in total set aside to make it work.

Now I suspect there will be people who object to new building, even on the brownfields of our cities.”

This is good news. It was followed by a statement by Eric Pickles, Secretary of State, who gave this press announcement:

https://www.gov.uk/government/news/government-initiatives-to-help-build-more-new-homes-on-brownfield-land

Communities Secretary Eric Pickles said:

“We’re determined to make the very best use of derelict land and former industrial sites to provide the homes this country desperately needs in a way that protects our valued countryside. By ensuring commitments to housing development are in place early and having dedicated housing zones, building becomes, quicker and easier for homebuilders, businesses and councils.”

He also was quoted in the Daily Telegraph on 14 June 2014 as saying “We’ve always been a green and pleasant land and we must stay that way, prerving the best of our countryside  and other green spaces…we’ve also been facing a serious housing shortage in this country, and we’ve got to increase supply in line with demand.  I’m determined that we rise to that challenge without building unnecessarily on undeveloped land.  The way to do that is to use brownfield better”.

Master Vision for Guildford

The Master Vision document – commissioned from planners Allies & Morrison – has now been published and you can read it here:

http://www.guildford.gov.uk/media/17154/Item-7—Guildford-Town-Centre-Vision-2014/pdf/Guildford_Town_Centre_Vision_2014.pdf

This sets out a number of issues including proposing housing in the Walnut Tree Close area, protecting the green surroundings of the town, and some issues concerning road traffic, the planning of the Gyratory in Guildford Town Centre etc.

The vision for increased residential housing on brownfield in the town centre is excellent and warmly welcomed.  This document was approved as a draft by the Scrutiny Committee on Wednesday 11 June, so this document will go to consultation to be included within the Local Plan, and it is of course possible to comment on this separately too.

There were 7 public speakers at the Scrutiny Committee.  All but one thought that the Walnut Tree Close area should be used for primarily residential development and was a potentially very sustainable site for medium density housing, which could present a very exciting opportunity for  Guildford both as a town (more cohesive, less poor quality land in the centre of town) and as a borough (the potential use of previously developed land in the town centre could allow protection of the Green Belt).  Even the spokesman for the business community, who wanted office usage near the station, agreed that it was a poor site for industrial units and that there should be HGVs going along Walnut Tree Close, and that those existing industrial units could constructively be moved. So the public response was unanimous in agreeing that industrial units should be moved from Walnut Tree Close.

 

 

Full steam ahead

Last night (4/6/14) the Executive Committee at Guildford Borough Council voted unanimously  to approve the draft Local Plan.

The draft local plan still contains the housing number of 652 homes per annum, which, backdated to 2011 (why?) gives a total until 2031 of 13040 homes to be built – which represents approximately one quarter of the existing number of homes in the borough.

It seems that the Scrutiny Committee requirement to revise the housing number has been disregarded.  At the Executive Committee, Cllr Phillips, who proposed that revision as a recommendation, said:  “I was pleased that the joint Scrutiny Committee accepted my suggestion… to have another look at the housing numbers. We have in here in Appendix A the detail of how you arrive at the housing numbers and [that].. a meeting has been arranged..between the lead councillor, the head of planning services, the managing director.. [etc] and members of the policy team and appointed advisers such as GL Hearn and Edge Analytics to review the housing numbers. It was hoped that we would have an answer by today. Can you tell me, has this happened? Have you looked at this yet? If you have, what is the housing number and has it reduced as we were hoping it would be?”. It was confirmed that the meeting had not yet taken place,. Cllr Juneja, the lead member for planning, noted that the number had not been reduced at present but would be “challenged” by the Executive.

A private meeting was held on 6 June 2014 to review the housing number.  Anne Milton MP arranged for some of her constituents to meet with GL Hearn, the consultants who prepared the report; but those who are not Mrs Milton’s constituents were not been invited to that meeting.  (Mrs Milton seems not to have realised that the parliamentary constituency of Guildford, and the borough of Guildford, have different boundaries, and other MPs’ constituents are not included in that consultation.)

The numbers may change – but they will not change before the draft that goes to public consultation. And, at a guess, substantive change may be unlikely thereafter.

We were also told  at the Executive  Committee meeting by Cllr Mansbridge and others that:

  • electrification of the North Downs line is possible (or maybe probable)
  • brownfield land is being considered, and that there will be a parallel document to consider the brownfield land “by the river” (this may be the Walnut Tree Close area, or perhaps Slyfield) as a master vision document, to be consulted on possibly in parallel with the Local Plan
  • there may be prospects from the Highways Agency for new and improved roads (location unspecified – and actually that doesn’t excite me at all; roadbuilding is not an enticing prospect)

You can view the webcast of the meeting here:

http://www.guildford.public-i.tv/core/portal/webcast_interactive/137661

GGG open letter to councillors 29 May 2014

Dear Councillor

You may have seen the summary of the agenda for the Executive Committee on 4th June. If you are not on the Executive Committee, you may not have seen this, or yet taken the time to read it. GGG feels that it merits serious criticism, and actually represents a serious failure of the democratic process.

We would therefore ask you to challenge it, as it requires reconsideration.

You will be aware that planning is a matter of major concern nationally, with many people terrified about an apparent assault on the countryside and apparent reluctance among house builders to consider the prioritisation of brownfield land. This has been a topic that has led to comment by a number of significant experts, including Sir Simon Jenkins, Dame Helen Ghosh, Shaun Spiers, Sir Andrew Motion, Sir Richard Rodgers and others. Civic Voice has expressed concern regarding a democratic deficit in the planning process. Greg Mulholland MP has a private member’s bill requesting a revision of the NPPF, with a second reading on 6 June 2014 (GGG has asked all 4 MPs to vote in favour). There is a parliamentary select committee currently reviewing the efficient operations of the NPPF. You may also be aware that there is much comment about a housing bubble in London and the South East, likely to be near the top of the market at present and that mortgage approvals are currently falling; house building is at a periodic high, where the current constraint on the number of homes being built is the national supply of bricks. Not all those homes will be lived in: 18% of homes built in London are sold to non-resident buyers and stay empty; this too calls into question the real need, national or local. Further there are, nationally, 1 million empty homes (not 2nd homes).

This situation is currently fluid and there is scope for political decision-making as part of this process, as the Scrutiny Committee noted. It is arguable that the impact of concern about this issue has already affected elections, both locally and the European elections. As you may be aware, both the Green Party and UKIP are staunch supporters of the countryside and, from different standpoints, oppose greenfield building; and the impact on the recent elections of this matter has perhaps not yet been fully considered by the main political parties. This is not a simple and straightforward procedural planning matter. It requires your judgement.

For your information, we are including a note on the use of brownfield land in Guildford prepared by GGG, which we consider indicates that there is substantial brownfield land within the borough that could be utilised for the purposes of development. It is an illustrative brief document, but we are in the process of preparing a more detailed work. We do not consider that there is a need to consider greenfield sites in preference. Conversely, there is precedent that Local Plans have been subjected to judicial review if there has not been a proper review of the alternatives to use of the Green Belt. We would also note, if you were not aware, that Mole Valley initially considered that it needed to plan to use 2% of its Green Belt for housing, but MVDC is now implementing its Local Plan well in excess of its housing target using only brownfield areas.

If you are not on the Scrutiny Committee, you may not have seen the results of that Scrutiny Committee, and so for your information we are attaching a GGG press announcement summarising the conclusions of that meeting.

The draft local plan report is here: http://www.guildford.gov.uk/media/17112/Item-3—Draft-Local-Plan-Reportpdf/pdf/pdf46.pdf

Scrutiny Committee decision disregarded
We note that agenda item 8 reiterates the conclusion of the Scrutiny Committee:
“To express concern over the housing number as set out in the Draft Local Plan and to ask the Head of Planning and the Lead Councillor for Planning to review the housing number before going to Executive for consideration on 4 June and Council on 19 June 2014″.

The officer response does not indicate that such a review has been carried out, but states: ” A meeting is being arranged [ie has not yet taken place] between the Lead Councillor, the Head of Planning Services, the Executive Head of Development, the Head of Housing Advice, the Managing Director, members of the Policy Team and appointed advisers such as GL Hearn and Edge Analytics to review the housing number for inclusion in the draft Local Plan. A full and detailed explanation of how the housing number was arrived at is attached to this note as Sub Appendix A”.

The Scrutiny Committee required review of the planning number. That has not taken place and there has not even been a preliminary meeting. It is not clear how the Local Plan can be processed for approval by the Full Council without the revision of the housing number as required by the Scrutiny Committee. We would question what the function of the Scrutiny Committee is when its conclusions can be wholly disregarded by the Executive Committee. Far from being revised and reviewed, the number is unchanged, with an intention to hold a meeting at a future date and a series of apparently spurious justifications given for not revising the number as the Scrutiny Committee required.

No constraints applied, with no justification given
In Appendix A it is stated, as if a matter of fact, that
“If it can be demonstrated that we can meet our objectively assessed housing need over the plan period, using suitable and deliverable land, then a housing number lower than our objectively assessed housing need will not be found sound at examination.” This assertion is not demonstrable from the evidence of other areas and is not necessarily valid. No evidence is adduced for this statement. It would appear to contradict ministerial advice and the letters sent to our MPs by Nick Boles and the written advice from Nick Boles to the Planning Inspectorate in relation to the application of constraints arising from the Green Belt. It is a further demonstration that there has been no attempt made to apply any constraints whatsoever to the planning process. No such constraints have been applied relative to the number generated by the revised SHMA.

Conversely, there is precedent that Local Plans have been subject to judicial review if there has not been a proper review of the alternatives to use of the Green Belt.

It would appear from ministerial advice that there is not a requirement to meet objectively assessed housing need in full if Green Belt constraints apply (see letters from Nick Boles previously circulated). There is no suggestion in those letters that these requirements are just transferred into an adjacent area, but that Green Belt is a justification for actual reduction of objectively assessed housing need. This might arguably seem to be a grey area in terms of ministerial advice, but is certainly not merely a process of reallocation to adjacent authorities as the officer’s report would seem to suggest. This, like other remarks made on an advisory basis by the planning department, does not seem wholly accurate. Councillors should note that there is a precedent for judicial review of a Local Plan on the basis of poor advice by a planning department, if that advice is not demonstrably accurate and impartial. It is not clear that this advice is accurate.

Objectively assessed need was inflated, but has not been revised
In any event, it had been extensively argued at the Scrutiny Committee meeting, by councillors, that the objectively assessed housing need as arrived at in the SHMA is overstated. The numbers use an inflated trend – if necessary we can reiterate these arguments. This conclusion has been disregarded. The ONS data has been revised and the preliminary conclusions from The Guildford Society on their website indicate that this would give rise to an even lower estimate of housing need than should have been considered. However, this is not taken into account in the documents, which were published on the same day as the ONS data and therefore presumably have not yet taken these into account. Case law differentiates between housing need (the core data), housing requirement and housing targets. Constraints apply to the housing requirement (as generated by the SHMA) to arrive at the housing target (lower than the SHMA almost everywhere, but not here- the numbers are the same; the applicable constraints are not applied). The preliminary view that housing need can be justified at a SHMA number of around 470 should fall therefore, and with the application of constraints the combined residents’ view that the housing target numbers should be 300-345 remains constant.

5 year supply of housing land not in place
It has also been argued to the Council that there is in fact a 5 year supply of housing land and the arguments set out in relation to this matter have been ignored. Existing planning permissions are, by definition, available, suitable and achievable (with some small exceptions). When these are added to student housing permissions, there is already a very substantial supply of housing, before any new sites are considered. If the available brownfield sites within the town are included, even taking into account only those available within the initial 5 years, then there is a 5 year supply.

Existing planning permissions total 1480 (source: revised SHLAA). Student housing permissions total 2121 (source: UniS planning officer) (these specifically count towards the housing total, per Nick Boles’ letter to Sir Paul Beresford). The total is therefore 3601 (1480+2121=3601). Using the SHMA number (itself overstated) of 652, with a 5% uplift, gives a total of 3423 (652 x 5 x 105% =3423). It is therefore demonstrable that existing permissions exceed even the high objective assessment of need (3601>3423). Why, therefore, is it repeatedly stated that there no 5 year supply? Even if some of the existing planning permissions should be deferred (which must in itself imply that the developers are engaged in land banking which will distort the planning process) there is surely some land that is available so that a 5 year supply can be recognised? This is clearly the case.

The reiteration that this supply does not exist as if it is a given fact seems to imply a predetermined choice of course of action, and seems to suggest some desire to uplift the requirement by 20% to distort the decision making process, which is not acceptable.

In addition, there has been an elaborate game of double and negative circular counting to demonstrate that the current estimate of need should be backdated to 2011 to create a shortfall that could never have been anticipated. This is patently ridiculous, and throws the whole assessment and calculation into disrepute. Who are the numbers designed to persuade?

It is clear that using the previous local plan numbers and then the agreed interim measure of 322 – as agreed by the High Court – means that for the 10 year period to 2011 (or, if you prefer, the 10 year period to 2013) there was no historic shortfall. These numbers too can be supplied again if you wish.

Lack of revision as required by Scrutiny Committee
As we have seen previously, both in relation to the proposed involvement of the public in the scrutiny of the evidence base and the revision of the SHMA, the later drafts of parts of the Local Plan documentation seem to be revised remarkably little from the initial drafts, and the process of consultation and review, either with councillors or members of the public, does not appear to result in any modification.

This is unacceptable. It has been repeatedly stated by council officers that planning is not a referendum. Neither, however, is it the preserve of the planning department alone. The Localism Act enjoins a duty of consultation, and the right of communities to be heard. This does not mean that consultation with those communities should be an empty process.

Furthermore, and even more significantly, the choices of elected representatives should not be ignored. The decisions made by the Council should not just be set aside as if merely consultative.

It is not clear whether this failure to respond to the decision of the Scrutiny Committee is an abuse of Executive Committee power within the council, or whether the Planning Department are acting independently without the Executive Committee’s remit. In either event, we consider that the formal decisions made by councillors at the Scrutiny Committee should be followed and respected. As accepted by the Chief Planning Officer at that committee, political decisions are a matter for elected councillors, but, once made, they must be carried out and not ignored.

If there are areas within this document that you would like to discuss further, do please contact us.

With regards

Guildford Greenbelt Group