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:

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:

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?



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:

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:

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”.

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:

GGG open letter to councillors on 15 May 2014

This open letter was sent to all councillors just before the Scrutiny Committee on 15 May 2014

Guildford Greenbelt Group




15 May 2014


Dear Councillor


Scrutiny committee


Susan Parker will be speaking on behalf of GGG at the Scrutiny Committee this evening. Various concerns will be raised.


However, as background, this letter deals with some of the numerical concerns that GGG have with the current draft Local Plan. As a 3 minute presentation is not the best format for delving into figures, it may be helpful to run through some of those numbers in advance of tonight’s committee meeting so that you are all informed of the detail.


The Local Plan draft that you will be considering has, in the foreword, the comment that “The plan has to take into account our persistent under-delivery of housing and the almost complete absence of a 5 year land supply.”


We feel that both these statements are fundamental to your understanding of the proposals and the decisions that you will be making. We also feel that both are factually incorrect.

We would like to demonstrate both points – for those of you who are more comfortable with Excel, we are attaching an Excel spreadsheet with the source analysis included so that you can review the calculations.

Persistent under-delivery of housing

GGG does not believe that this statement is true or fair.

We consider (as noted below) that the draft SHMA has many faults. However, it is useful for some base data, and we would note that the consultancy employed by GBC to prepare this document, GL Hearn, comment in paragraph 2.44 on page 27 of the draft SHMA

“Over the 2001-11 decade housing delivery totalled 3187 homes in the Borough (net) relative to planned housing delivery of 3180 homes. The planned housing provision was based on the former RSS housing target which was capacity driven. In the period preceding the demographic projections in this report (which start from 2011) there was thus no net shortfall in housing provision”.

Further, GL Hearn comment in paragraph 2.46 on page 28

“Guildford Borough.. did meet its housing target for the 2001-11 decade as a whole”.

There is a reference to undersupply for the 12 year period to 2013. But this doesn’t arise, since the plan is for the 20 year period to 2031, backdated to 2011. So it is wrong to take the incremental period 2011-13 into account here.

Just to clarify that statement more fully: the draft Local plan suggests a housing need of 652 (this number is not accepted, and more discussion on this later). This translates in the introduction to the draft Local Plan to a total housing requirement of 13040 (which is derived as 20 x 652 = 13040). The plan runs until 2031. So the 20 year period concluding in 2031 must start in 2011. As a result, the supply that needs to be appraised in terms of historic underperformance prior to the plan period must be the supply until 2011.

There is an alternative scenario, where we stop pretending that the plan should run from 1 January 2012. If the inspectors and you as councillors are only looking forward, and not backdating the plan then the supply that we will need to consider will only relate to 16 years, not 20 years. As a result the total would not be 13040 (20 x 652) but would be 16 x 652 = 10432.

We have accepted the backdating as a principle, since this is proposed by the Council, but this principle, if accepted, must be consistently followed. You cannot backdate the requirement, but ignore the historic supply which relates to that requirement, and have a series of mismatched time periods. It must therefore be accepted that there is no historic undersupply, as confirmed by GBC’s own consultants.

Furthermore, you could not assert that the historic housing needs should be backdated, and that because it is now higher, you failed to deliver against a hypothetical, unrecognised housing target. This is an exercise in the ridiculous. No authority in the country can supply against hypothetical retrospective targets – are we supposed to build now on a wholly unrestricted basis in case someone at some stage in the future might possibly apply some higher hypothetical target? Why should you even assume that targets will continually rise? What if some targets, in the future, were perhaps to restrict housing supply or fine you for excessive use of agricultural land – might you then be penalised retrospectively for oversupply or excessive land use now? Clearly, this would be wholly unreasonable, and obviously ridiculous. So, how, in 2011, could you decide that the housing target in 2014 would in fact be retrospectively applied to 2011 and so you needed to build double the amount the High Court agreed?  You cannot assume the impact of future targets when making decisions. You have to compare against actual targets at the time. Compared to actual targets in place there was no undersupply, as confirmed by your own consultants.

And, with all due respect to the planning department, the fact that they assert a thing does not demonstrate the fact. You as Councillors need to interrogate them and require that they prove assertions; because if you do not, an Inspector will.

GGG would prefer not to backdate the requirement, and only to look at the plan going forward. We would prefer to recognise that the date is 15 May 2014 and that we are looking at actual supply for the future, not historic supply. We would prefer a total housing target on the basis of 16 years supply, not 20 years, which is the consequence of that recognition. (16 x 652 = 10432 – ie a reduction from 13040). The Council want to backdate the plan instead, and we have accepted this. But consistency must be applied. If you want to backdate the requirement, then you have to look at historic supply up to the date of that requirement.




Absence of a 5 year land supply

Again, this statement does not seem confirmed by the documents prepared on behalf of Guildford Borough Council.

The SHLAA (current draft) notes (page 9) that existing planning permissions include

Guildford urban area 1480
Ash, Tongham and villages 830
Subtotal 2310
Disputed permission re Ash & Tongham 400
Revised subtotal 1910


As previously noted, this plan is backdated to 2011. We are therefore in a position where we are including (in the forward plan) the housing requirement for the years 2011-13. We are effectively pretending that we are in 2011. As a result, looking forward, we should also deduct the actual completions in that period, since these are also relevant to the calculation.

If we cease to pretend we are in 2011, three years’ housing requirement fall away, and the total housing required falls to a total of 10432 by 2031. (16 x652 =10432)

Historic completions are:

2011/12 source – SHMA draft p26 261
2012/13 source – SHMA draft p 26 230
2013/14 tbc 0
Total historic completions (plus 2013/14) 491


These can either be deducted from the requirement or added to the “5 year supply”.

Added in there should also be the number in relation to student housing which has been confirmed as applicable to the calculation by Nick Boles in his letter to Paul Beresford (copy letter attached).

This gives the following subtotals:

Historic completions 491
Existing planning permissions 1910
Student planning permissions 2121
Current housing supply 4522


This is before any new sites are taken into account at all. This is just existing planning permission and existing completions.

The SHLAA seems to adjust existing permissions in order to suggest that many will not be completed within a five year period. However, since these are in the control of the local authority this should not be acceptable. The University, for example, has suggested that they may choose not to build until 2017; but all these homes could be built tomorrow if the builders so decided. Why should the local authority, and the community, be held to ransom by builders deciding not to build when they have existing permissions? The permissions exist; they must be taken into account.

If there is no shortfall, it is necessary to provide a 5 year buffer of 5%. If there is a shortfall, then the buffer becomes 20%. However, there seem to be sufficient existing planning permissions. The five year housing supply may be calculated – using the disputed SHMA number – as follows:

5 years x 652 homes per year x 105% = 3413

It will be noted that 4522 exceeds 3413. Just to nail the sum

4522-3413 = 1109.

In other words, 1109 of the existing planning permissions would have to be unavailable in the five year period, and there have to be would be NO available extra land on which planning permission is being sought, before there is any question of a failure to provide a 5 year housing supply.

It is therefore demonstrable that before any additional sites are taken into account, the borough does have a 5 year housing supply.

This matter is particularly fundamental. Where local plans are not finalised, the existence of a sufficient 5 year housing supply provides protection against the prospect of planning by appeal, which we have repeatedly been told is of major concern to councillors. We consider that it can be demonstrated that (even on the basis of the draft SHMA, itself open to question) a 5 year supply is in existence. As a result, there should be a sufficient defence against possible appeal by developers in relation to prospective planning proposals being rejected prior to the implementation of the Local Plan.

SHMA basis

It has been noted by many commentators that the SHMA numbers are incorrect and overstated. They rely on 5 year demographics rather than 10 year demographics, and this results in an exaggeration of the blip from boom years when the university has grown. While this is no doubt to be applauded, the regression trend cannot be extrapolated from one year’s blip – it distorts a total. There are a number of other anomalies and errors.

This has been picked up by Edge Analytics in the review commissioned by Guildford Borough Council and included on the evidence base, which notes that it can only give “an amber tick” to the statement that “assumptions, judgments and findings are fully justified and presented in an open and transparent manner”. It further notes that this arises because the choice of scenario assumptions has an important bearing on the housing numbers.

So the housing numbers only have an “amber” tick, and the 10 year comparables that Edge suggest (see page 17 of their report) would show a range of alternatives. We would propose that the “migration led” scenario of 470 is most appropriate. This is of course comparable to the 652 number that is generated by GL Hearn.

However, note also that the GL Hearn number is that generated by the SHMA. As noted in the press by GGG, that number should then be subject to constraints (as noted also in the letter from Nick Boles to the planning inspectorate). No constraints have been applied; it is unclear why this decision has been made.

It has been asserted by the planning department that constraints have indeed been applied. If so, no reduction has been made, so the constraints do not appear to have constrained anything. The number generated by the SHMA is the unadjusted housing need number from the SHMA. If constraints have indeed been applied, why is the number unchanged?

The NPPG envisages that a SHMA number will be generated to demonstrate housing need; that the SHMA will then be subject to review and constraint due to local circumstances; and that this will result in a housing target. This process is neatly discussed, with useful definitions of the various categories, in the recent legal case Gallagher Homes v Solihull. The SHMA result, and the actual housing target, should be different in almost all cases. Why, for Guildford, which has an exceptionally high anomalous number in the draft SHMA (disproportionate to that of adjoining authorities), is there no constraint applied? Is it that the planning department want to find the highest possible housing number? Why?

We would suggest that taking constraints arising from capacity into account would generate a number in the region 300-345.

NB if the 345 housing requirement number were to be used, this would generate a consequential 5 year supply number of 1811 homes (including the 5 per cent.uplift).

5 years x 345 homes per year x 105% = 1811

Duty to cooperate

GGG have noted that GBC has a duty to cooperate and has made this point repeatedly since formation last year, in its letters to Councillors (including our first letter, in December 2013) and in its formal submissions and press announcements, together with a concern that this duty is not being properly fulfilled.

We do have much sympathy with the administrative difficulties of managing a duty to cooperate in the context of a timing mismatch in plan preparation with neighbouring authorities. GGG has noted in the context of our submission to the parliamentary committee reviewing the NPPF that this is effectively almost unworkable.

Notwithstanding this, inspectors are likely to pay particular attention to this requirement, and we would note that Runnymede has now joined Waverley as an authority that has failed in its duty to cooperate. As we have repeatedly stated, not in a spirit of delaying this process but in the spirit of seeking to facilitate the best possible local plan, it is important to get it right, and a rushed plan is a plan that might fail.

We would note that if councillors had listened to GGG in relation to this in December 2013, rather than dismissing our point, the Local Plan would have been somewhat more advanced at this stage. We would urge you to listen to our concerns, and those of other residents’ groups, rather than to press on regardless with a plan that has so many flaws.


We consider that the Local Plan has a number of failing elements, which must be tested and challenged by councillors, not merely accepted.

We consider that councillors have not been well advised, and that they have placed too much reliance on the unsupported statements made by the planning department, some of which have proved unreliable.

We also consider that it is the responsibility of the Scrutiny Committee to make those challenges (and consequent corrections) at this time, with the utmost speed, rather than to proceed with a failing plan now.

These include:

  1. The assumption that the SHMA number is correct (we know it is not)
  2. The failure to apply constraints to the SHMA number (this must be constrained)
  3. The failure to meet the duty to cooperate (this must be done or the plan will fail)
  4. The belief that we do not have a 5 year land supply (we do and this is demonstrable)
  5. The belief that we have had persistent under-delivery of housing (no underdelivery)

Please make these corrections before the draft Local Plan is put forward as part of the consultation exercise.

Yours faithfully,


Guildford Greenbelt Group


Appendix 1

Letter from Nick Boles MP to Sir Paul Beresford MP 7 February 2014

Letter attached in full but note in particular:

Can student housing be included in a local authority’s Local Plan housing numbers?

Yes. Student housing makes a significant contribution towards housing supply by taking pressure off housing stock. The Government has clarified guidelines to make it clear that local authorities can include student housing in the calculation of, and the monitoring toward, housing needs regardless of whether they are communal or sited on a university campus.”


GGG open letter to councillors dated 4 April 2014

Dear Councillor

I feel I need to write to express my view on some specific advice you were given by the planning department yesterday evening, since I was not permitted to express this view in the council chamber.

St Albans

It was stated yesterday evening that the St Albans (Hunston) decision only relates to a specific planning decision.

This is correct, but its interpretation of the law relates also to local plans. So that you can read the Appeal Court decision in full and form your own view, I am sending this to you again.

See in particular paragraph 6 (my highlighting):

“6. There is no doubt, that in proceeding their local plans, local planning authorities are required to ensure that the “full objectively assessed needs” for housing are to be met, “as far as is consistent with the policies set out in this Framework”. Those policies include the protection of Green Belt land. Indeed, a whole section of the Framework, Section 9, is devoted to that topic, a section which begins by saying “The Government attaches great importance to Green Belts”: Paragraph 79. The Framework seems to envisage some review in detail of Green Belt boundaries through the new Local Plan process, but states that “the general extent of Green Belts across the country is already established.” It seems clear, and is not in dispute in this appeal, that such a Local Plan could properly fall short of meeting the “full objectively assessed needs” for housing in its area because of the conflict which would otherwise arise with policies on the Green Belt or indeed on other designations hostile to development, such as those on Areas of Outstanding Natural Beauty or National Parks. What is likely to be significant in the preparation of this Local Plan for the district of St Albans is that virtually all the undeveloped land in the district outside the built up areas forms part of the Metropolitan Green Belt.”

Further I would note that paragraphs 27-33 are relevant, especially paragraph 29, which notes that the objectively assessed housing need is what should be considered, but that this should be considered in the context of the geographical area:

“29. But there may be other factors as well. One of those is the planning context in which that shortfall is to be seen. The context may be that the district in question is subject on a considerable scale to policies protecting much or most of the undeveloped land from development except in exceptional or very special circumstances, whether because such land is an Area of Outstanding Natural Beauty, National Park or Green Belt. If that is the case, then it may be wholly unsurprising that there is not a five year supply of housing land when measured simply against the unvarnished figures of household projections. A decision-maker would then be entitled to conclude, if such were the planning judgment, that some degree of shortfall in housing land supply, as measured simply by household formation rates, was inevitable. That may well affect the weight to be attached to the shortfall.”

As a result I think that the assertion made by Carol Humphrey (Head of Planning Services) that St Albans has no relevance in the context of the Local Plan is not correct. Furthermore I think that recent case law and recent Secretary of State decisions demonstrate that the shortfall in housing supply does not provide a sufficient justification to override the protection of the Green Belt not only in relation to specific planning appeals, but also in relation to any review of boundaries too.

Nick Boles letters

It was stated this evening by Carol Humphrey that the most important letter from Nick Boles was that on 13 March. It was implied that in some way this undermined any advice given in the first letter (which I have sent to you previously, which states “the Framework makes clear that a Green Belt boundary may be altered only in exceptional circumstances” ). You have all been sent all three letters, but I am sending the two letters from Nick Boles to you again. The first letter was clear advice specifically given to planning inspectors. The letter from planning inspectors queried this, and then Nick Boles stated that the advice given was a clarification of existing rulings. You wouldn’t expect a politician to admit to a U-turn in writing, I presume?

Nothing in the second letter undermines the clarification in the first. The first letter states that Green Belt is a policy that indicates development should be restricted. To quote again:

“local authorities should meet objectively assessed needs unless specific policies in the Framework indicate development should be restricted. Crucially, Green Belt is identified as one such policy”

As noted in my open letter to you, this is a word for word quotation from paragraph 14 of the NPPF. So Nick Boles is right, it is clarification not change. The second letter from Nick Boles confirms that the NPPG “provides useful clarity on the practical application of policy. It should provide helpful support for Inspectors and should not normally be considered a reason for extending examinations.” I don’t see that this is a withdrawal of the original advice. He is stating that it isn’t the policy but the Inspectors’ interpretation of that policy that has been wrong. The fact that Nick Boles is suggesting that the rules were always as they are now doesn’t mean that his guidance on the current rules should be ignored.

The extremely clear statement about the Green Belt in these letters are that Green Belt is a policy which restricts development – and, as Nick Boles rightly notes, that policy is stated in the NPPF. You should be entitled to rely on this guidance from the Secretary of State, which he put out as an open letter with a view to its influencing local plans and the inspection process.

With kind regards

Susan Parker