Fringe Box



Letter: The Council Leader’s Letter is Inaccurate

Published on: 1 Jun, 2017
Updated on: 1 Jun, 2017

From David Reeve

Guildford Greenbelt Group borough councillor for Clandon & Horsley

in response to: It Is A Myth That Cllr Reeve’s Housing Numbers Are Wildly Different

It is inaccurate of Cllr Spooner to say that I have “agreed that [my] methodology and the Guildford Borough Council (GBC)  Strategic Housing Market Assessment (SHMA)  methodology were broadly aligned. There is no big mismatch at all.”  Either Cllr Spooner is being disingenuous, or he has failed to understand the issues.

He is also on record as saying much the same in an interview on December 14 2016, posted on the Get Surrey website, when he said that “A GGG councillor, David Reeve has pretty much worked out the SHMA.  The interesting thing from that process is that he has demonstrated in fact that the numbers are broadly correct.  His number, that he has generated by going through the whole exercise himself (and that must have taken him a considerable amount of time) is that in fact broadly speaking the SHMA is correct in terms of the GBC published SHMA.”

Let me make the situation very clear.  The work that I published in July 2016 did not support the housing numbers that appeared in the SHMA.  It did confirm to my satisfaction that the methodology employed in the GL Hearn/Gardner demographic projection was capable of producing numbers that were consistent with the published Department of Communities and Local Government (DCLG) data.

However, the final result depends on the data that was used as well as on the calculation method that was used to process that data.  I said in my report: “…it should be noted that both DCLG and the SHMA based their projections on the underlying ONS [Office of National Statistics] data, and that there are two considerations that are likely to influence the population and household estimates for 2033 … ”.  Those two considerations were the likely effects of Brexit, and the problem of Unattributable Population Change (UPC).

Since I wrote my report, ONS has revised its projections to take account of Brexit, but the problem of UPC remains.  When the 2011 census was analysed, it was found that ONS’s year-by-year population assessments for Guildford for the period 2001 to 2011 overstated the annual inward migrants to Guildford by 717 per year, but the specific source(s) of the error could not be established – hence the use of the term “unattributable”.

It is true that ONS have taken steps to address this large error (and took some of them before the 2011 census), and it is reasonable to assume that the error is now smaller than it was in 2011.  However, until reliable confirmation is obtained from analysis of the 2021 census, nobody (including ONS) really knows how large the UPC error is at present.

GL Hearn has assumed that the error is now zero – presumably on the false basis that absence of evidence of the current size of the error justifies an assumption that there is no error.

My position is that GL Hearn’s assumption cannot be sustained, indeed I stated in my report that: “…in the absence of further information, a sensible judgement (on up-to-date data from ONS if possible) will have to be made and be explicitly publicised in order to gain the support of the local community.

“In this regard, NPPF paragraph 155 states that ‘Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential.  A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made’ “.

An assessment of the true current value of the UPC is very important, because if it has been reduced from an overstatement of 717 inward migrants per year down to, say, 250 (which would represent a substantial achievement by ONS), this would translate to a population overstatement of 4,250 (250 x 17) over the 17 years between now and the end of the Local Plan period, in 2034.  At a typical headship rate of 2.4 people per dwelling, this in turn translates to 1,771 dwellings.  This error could therefore quite easily be at the scale of one of the proposed strategic sites.

That is why I do not in any way accept Cllr Spooner’s characterisation of my work as supporting the current housing figure that appears in the draft Local Plan, and why I described him as being disingenuous or as having failed to understand the issues.

There is also an issue of potentially similar magnitude arising from what I believe to be errors in the assessment of housing need arising from economic growth.  However, this particular issue is considerably more complex than the simple demographic numbers that I have discussed above, and is not appropriate here.

If someone wants to arrange a public workshop to examine these issues in more detail I would be prepared to participate in the interests of generating an informed public debate in the spirit of NPPF paragraph 155.

Notwithstanding my comments above, I can confirm that Cllr Spooner is right in two respects:

  1. As a councillor I did have access to data that was not available to the general public, namely the economic forecasts provided to GBC by Oxford Economics, Experian and Cambridge Econometrics.  However, it should be noted that the overwhelming majority of the work that I reported last year was based on a detailed examination of the published SHMA and data from ONS and DCLG that is readily available to the public.  Also a meeting took place at the end of March this year (2017) between Cllr Spooner, Planning Officers, representatives of GL Hearn and Justin Gardner, and myself to discuss my conclusions.
  2. I did erroneously misquote Experian’s estimate of the number of jobs in Guildford in 2013 and 2033, and it is the case that GL Hearn identified this error.  However, this error fed through to only one of the ten conclusions that I published in my report (conclusion number 6), and has no effect whatsoever on the discussion above.  For the avoidance of doubt, I am happy to withdraw that particular conclusion.

If anyone would like a copy of my report I would be happy to provide one if they email me at:

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Responses to Letter: The Council Leader’s Letter is Inaccurate

  1. Peter Shaw Reply

    June 1, 2017 at 3:26 pm

    I wish to publicly thank Cllr Reeve for his hard work and effort. This type of scrutiny and analysis is exactly what is needed at the council. It is a shame though that fellow councillors have not listened to your advice. To show that at least one strategic sites worth of houses can be discounted because of overestimating figures in the SHMA is exactly why we need transparency to show how these figures are calculated. It is troubling that a similar magnitude of error could be waiting in hiding in the economic growth predictions as well.

    Surely this is clear evidence why we need open and honest transparency from the GBC Executive. Potentially two strategic sites worth of houses can be explained away by errors in the SHMA. How are we as the public supposed to have faith in our Local Plan and arrive at an informed opinion on where we need to build new homes if, at its core, the Local Plan still has significant issues?

  2. A Atkinson Reply

    June 1, 2017 at 5:43 pm

    And we need to remember that the SHMA only comes up with an assessed need (OAN) upon which constraints within the NPPF should be applied to come up to a housing target. So not only is the need overstated but the council leader has decided not to apply to considerable physical, ecological and environmental constraints of the borough in taking the SHMA OAN in full.

  3. Ben Paton Reply

    June 1, 2017 at 9:29 pm

    Cllr Reeve deserves the highest commendation for taking the trouble to undertake a proper examination and analysis. It puts the rest of the council to shame that it refused to ask for and scrutinise the Justin Gardner model underlying the SHMA figures. What on earth was Cllr Spooner thinking when he misrepresented Cllr Reeve’s findings?

  4. David Reeve Reply

    June 4, 2017 at 6:10 pm

    A word of caution is required in respect of Mr Shaw’s comment about a second error in the economic growth predictions.

    The SHMA’s [Strategic Housing Market Assessment] measure of the borough’s housing requirement is based on in two separate calculations, namely: (a) the housing demand arising from forecast demographic growth, ie. net population growth from the combined effects of births, deaths and migration (inwards and outwards), and (b) the housing demand arising from the labour required to support the forecast economic growth (taking into account workers who travel into and out of the borough to reach their places of work).

    For the purposes of the SHMA, the larger of these two housing requirements is taken as the binding condition. This means that errors in the demographic and economic forecasts are not additive.

    So, for example, if each of the two different forecasts were reduced by x dwellings per year, the overall OAN [objectively assessed need] would only reduce by x. This is because the reduction in the smaller forecast would always be masked by the reduction in the larger one.

    David Reeve is the GGG borough councillor for Clandon & Horsley.

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