Letter: Over 1,000 Have Signed My Petition to Disclose SHMA Workings

Published on: 14 May, 2016
Updated on: 14 May, 2016

From Ben Paton

I have started a petition to ask Guildford Borough Council (GBC) to disclose the arithmetic models and assumptions underlying the Guildford and West Surrey SHMAs [Strategic Housing Market Assessments].

Over one thousand people have now signed that petition which I created because when I asked for a copy of model and assumptions underlying the Guildford SHMA I received this reply:

“…the model was produced for Guildford Borough Council by a third party and is not held by the council. The model is the intellectual property of that third party and is commercially sensitive. They do not want to make the model publicly available. On that basis, the information is exempt under the EIR [Environmental Regulations Information]”.

When the West Surrey SHMA was produced I asked to see the arithmetic demographic model underlying that SHMA. I was told by GBC that it did not hold a copy. I was told by both Waverley and Woking councils that they did not have a copy because they had delegated the matter to Guildford.

The terms and conditions of the contract with GL Hearn, which wrote both reports, state that the work may not be subcontracted, that the copyright in any work belongs to the council, and that the contractor must assist the council to respond to freedom of information requests.

The House of Commons Committee on Local Plans wrote: “Communities need to have confidence that the figures on which their local plans are based are accurate.”

The Local Plan Expert Group report stated: “Establishing a demographic starting point is the first step in the calculation of housing need. The demographic starting point should be calculated using a credible demographic modelling tool,of which a number are commercially available.

“The model needs to be capable of applying the relevant ONS [Office of National Statistics] and DCLG [Department for Communities and Local Government] demographic assumptions to generate results that are replicable by others.”

Without a copy of the assumptions the results are not “replicable by others”. If a figure cannot be replicated by others it cannot be objective.

The NPPF [National Planning Policy Framework] states, at para 159, that “Local planning authorities should have a clear understanding of housing needs in their area.”

The contractor’s website states: “All inputs to the model are readily ‘user-defined’ allowing council officers to test different scenarios or update the model as new information become available”

How can GBC be said to have done its job properly if it has not even received a copy of the model for which it has paid? We the public in Guildford, Woking and Waverley have paid for this model. We are entitled to see it. There are no good reasons for keeping it a secret.

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