Letter: Guildford’s Assessment Of Housing Need ‘Falls Far Short Of Any Acceptable Standard’

Published on: 8 Mar, 2016
Updated on: 7 Mar, 2016

From Ben Paton

The National Planning Policy Framework (NPPF) states that ‘objectively assessed housing need’ must be set out and analysed in a Strategic Housing Market Assessment (SHMA). A SHMA is so fundamental to a Local Plan that it forms a specific chapter in the review of the National Planning Policy Framework carried out by a committee of the House of Commons.

This is what the committee said: “We encountered much disquiet, especially from local residents and community groups, about the figures emerging from the SHMA process, which many considered to be inflated or otherwise inaccurate.

“We are concerned about the widespread unease surrounding the results of SHMAs. Communities need to have confidence that the figures on which their local plans are based are accurate.

“We recommend that the Government work with local government and the house building industry to revise its guidance on strategic housing market assessments and produce an agreed methodology. Inspectors should then be required to test SHMAs against this methodology.”

Guildford Borough Council has subcontracted the work of assessing its ‘objectively assessed housing need’. It forms part of the West Surrey SHMA which the council commissioned from G L Hearn.

I requested a copy of the arithmetic demographic model which is the basis for the West Surrey SHMA from each of Guildford, Woking and Waverley Borough Councils.  Guildford replied that it did not have a copy of the arithmetic model.

Woking responded: “The West Surrey SHMA was commissioned by Guildford Borough Council on behalf of Woking Borough Council and Waverley Borough Council. The three authorities form a Housing Market Area. The contracts that you refer to in your request were entered into by Guildford B.C. Consequently, I am unable to provide a copy of the document as we do not hold a copy.”

Waverley Borough Council, whilst acknowledging the request made on January 9 this year, has yet to provide any response at all despite an obligation to respond within 20 days under Freedom of Information rules.

The arithmetic basis for the ‘objectively assessed housing need’ in Guildford, Woking and Waverley is therefore unknown to these councils. If we cannot see the model we cannot evaluate the methodology. So neither the civil servants nor the elected representatives have analysed or tested or scrutinised the model. Yet this model is the main justification for building tens of thousands of houses and changing the face of large parts of these boroughs for ever.

• Not one of these councils has carried out its own assessment of the objectively assessed housing need
• Two of these councils have subcontracted the assessment to Guildford Borough Council.
• Guildford Borough Council has subcontracted the assessment to a commercial consultant called G L Hearn.
• G L Hearn could not supply Guildford with the model because it had subcontracted it to another consultancy called Justin Gardner Consulting (JGC). Guildford states that JGC has refused to give it the formulae and assumptions in the model because it has ‘intellectual property’ in the model.

We hear complaints of inefficiency and passing the buck at the European Commission. Surely the example of our own Local Plan is every bit as bad. We have three borough councils, three planning departments and, between them, some 150 elected representatives – collectively being paid and spending on our behalf very large sums of tax payers’ money – duty bound to follow national planning rules to assess publicly available ONS statistics for the public purpose of assessing housing need. And not a single one of them, not one single, solitary individual among all these public servants has ever seen this model, let alone examined it critically.

Is this not a dereliction of public duty, a shabby passing the buck to a sub-sub-contractor, and a complete failure to oversee or evaluate the contractors’ work? Surely this is contrary to the Local Authority Procurement Rules and the NPPF? This is the antithesis of ‘accountability’. Instead of being ‘open’ with the information, they have buried it.

All of these people are bound by the Nolan Committee Principles of Openness and Accountability. None of them appear to pay more than lip-service to them. What on earth are borough councillors for if not to get and examine these sorts of important projections?

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