Letter: The SHMA Contains Many Holes and Shortfalls

Published on: 12 Jul, 2016
Updated on: 12 Jul, 2016

From Peter Shaw

“Nearly all men can stand adversity, but if you want to test a man’s character, give him power.” – Abraham Lincoln

Council leader Paul Spooner and GBC councillors cannot and should not hide behind terminology and statements like “was commissioned appropriately from the same company that has produced numerous SHMAs” [Strategic Housing Market Assessments].

I am just one person living in this borough with no political power or influence, yet even I was able to send a letter to the Office of National Statistics highlighting future forecasting errors in the population demographic, a letter the ONS acknowledged that they had made a mistake and in due course updated their predictions.

I’m not a professional statistician yet I made a difference. I realise councillors and the Executive are not professional statisticians but if they wanted to delve deeper into the SHMA and correct the mistakes within they could make a difference. But they won’t and they don’t. Is it no wonder people are so upset and angry when the Executive defends such a flawed document as gospel.

There are many technical holes and shortfalls identified in this SHMA that is produced by a one size fits all approach. Guildford is not a carbon cut out, copy and paste town. The formulas for this SHMA have been applied to 80 odd other SHMAs, but it is exactly this approach that has led to significant errors in the assessment.

A housing market assessment needs to take into account real local factors and effects. For example, a generalised formula based on employment statistics for the South East region as a whole were applied to boost up the employment stats when localised available data (from the same source), showed a lower level. This additional 10,000 odd job opportunities (which do not exist) was then used to justify a higher housing need than that is required. This is one of several technical errors found in the SHMA.

People like Cllr David Reeve are doing an excellent job trying to highlight these issues in the SHMA but Mr Paul Spooner and his Executive refuses to listen to reasoned voices. Why? Because central Government want houses in the South East and they use people like Paul Spooner to bludgeon it through, using the Local Plan and planning system.

Paul Spooner has the power but I personally find his character very wanting.

Responses to Letter: The SHMA Contains Many Holes and Shortfalls

D Fassom Reply

July 12, 2016 at 3:23 pm

Perhaps the following explains why GL Hearn are so reluctant to publish their calculations but it does not explain why the Executive at the GBC have not scrutinised the work themselves, on our behalf.

The following is an extract from GL Hearn’s website: “GL Hearn is one of the UK’s leading property consultancies providing trusted commercial property advice to the public sector, developers, investors and occupiers.

“We offer an integrated service from site assembly and CPO, through planning and development appraisals, affordable housing to project monitoring and end disposal. We act for many of the leading developers and are currently advising on schemes totalling over 3million sq ft. We have a team of over 100 people directly involved in the development sector”

and

22/10/2015 “‘MegaPlan for a MegaCity’ selected as a top idea to solve London’s housing crisis.

“The concept is to create an ambitious MegaPlan to match the ambition of our future MegaCity, as the population of London will rise to 10 million within the next 20 years. The MegaPlan would maximise the potential contribution of Edge Land (up to the M25) to provide a long term strategy to 2050 to look beyond the immediate housing crisis and get ahead of the curve. This approach would be underpinned by a strategic Green Belt review, to positively plan for a sustainable pattern of growth…”

Guildford Borough Council appear to have put the fox in charge of the hen house and boy have they gone to town. I rest my case.
Paul Bishop Reply

July 15, 2016 at 11:06 am

I don’t think the right approach is tearing into the SHMA [Strategic Housing Market Assessment], it should be ensuring the output of the SHMA is used as per its own recommendations.

Below is an extract from Paragraph 1.2 of the SHMA: “The SHMA does not set housing targets. It provides an assessment of the need for housing, making no judgements regarding future policy decisions which the councils may take. Housing targets will be set in local plans.

“The SHMA provides an important input into setting targets for housing provision, but the housing targets as set out in local plans will also take into account factors such as the supply of land for new development, green belt, local infrastructure capacity and environmental constraints. These factors may limit the amount of development which can be sustainably accommodated.”
Adrian Atkinson Reply

July 17, 2016 at 7:07 pm

Mr Shaw’s ONS story reminds me of a similar situation I had. When I was 22 my parents were burgled and as ever the insurance company tried to get out of paying out the full amount. The insurance company my parents used was a blue chip company, a household name. The policy had some sort of Retail Price Index linking to update the value of the contents. I proved, at 22, the whole company was index linking incorrectly. It can be done, people and companies make mistakes.

Why are Guildford Borough Council and its officers ignoring the issues? This is a c.£10-12 billion decision, ignoring infrastructure and town centre. I would have thought the council run the risk of being negligent if so many people have put them on notice that there are flaws in the SHMA.
Adrian Atkinson Reply

July 19, 2016 at 11:17 am

As I understand it, a significant proportion of the proposed jobs within the Local Plan, which are used to justify the “need”, are for construction jobs of those hired build the additional houses in the plan. This is double counting and a circular argument.

I agree entirely with Mr Shaw with reference to the one size fits all model GL Hearn claims to be robust. It’s like a barrister saying to a judge, “Our client is innocent as I have got 80 others accused off in the past.” Surely it would be down to the particular case and the evidence in front of the court? Should the jury or judge take things on trust? No, and neither should Guildford Borough Council – so why do they?
- John Perkins Reply
  
  July 20, 2016 at 11:36 am
  
  If it is true that some of the jobs are for those needed to construct houses for construction workers then that’s certainly a circular argument and should not be tolerated. However, it is not double counting, but recursive – something far worse.
  
  The problem is that if the model used is not published then it cannot be countered in this way. Of course, it can’t be defended either.
  
  Not only that, but one implication is that there are no local construction workers available. Really?
Adrian Atkinson Reply

July 20, 2016 at 1:25 pm

The source economic growth data used to justify driving an increase in the OAN [Objectively Assessed Need] above “base” shows that the proportion of Guildford’s growth arising from the construction was assessed at 12.3%, 26.3% and 35.9% respectively for the assessments from Oxford Economics, Experian and Cambridge Econometrics.

The direction of the plan is that Guildford is going to become a building site for the next 17 years to create economic growth driving an inflated OAN number for more house to be built than would normally be needed. This is not a smart or sustainable economic platform to base the prosperity of the borough, even if one forgets about Local Plans and OANs.

As Mr Perkins implies, the SHMA is a SHAM.