Letter: The Housing Assessment Report Is Objective

Published on: 26 Mar, 2016
Updated on: 26 Mar, 2016

From Phillip Scott

This letter is in response to the Opinion Piece: This Crucial Decision on Housing Must Be Scrutinised.

The Strategic Housing Market Assessment (SHMA) and Objectively Assessed Need (OAN) figures are objectively and independently assessed. The results are not debated as such because they are independent of political input.

The housing need is what the need is. There is no absolute requirement for a local planning authority to adopt the OAN because it is factored outside of policy and landscape constraints.

The constraints are then applied and a Local Planning Authority will adopt a housing land supply policy and associated target which is examined at Local Plan Examination (an inquiry) at which anyone can submit representations and make objections.

The fact that the OAN has risen so alarmingly since the 2003 Local Plan (saved in 2007) is due to the fact that housing hasn’t been delivered in the numbers that is required in Guildford Borough.

Housing supply targets are akin to a debt. If you don’t pay in the figure your accrued debt rises – simple.

For those that say ‘the figure is too high’ or ‘we have to keep our green belt’ they are sticking their heads in the sand. Every borough, every district, and every parish needs to ‘take their share’ of housing land supply.

It’s no longer tenable for large areas of England to say ‘we have lots of green belt so someone else, anyone else, has to take all the housing’. NIMBYism or BANANAS (Build Absolutely Nothing Anywhere Near Me) just won’t wash anymore.

Welcome to the real 21st century people – suck it up and take your share.

Responses to Letter: The Housing Assessment Report Is Objective

A Atkinson Reply

March 26, 2016 at 1:47 pm

1. How can a property consultancy and development business, GL Hearn, which is owned by a real esate business Capita Real Estate be called independent. A third party yes, which sourced it out to a fourth party, but never independent.

2. The assumptions and models produced by such a business will never be “objective” – by definition they are subjective, so the “Objectively Assessed Need” or “OAN” – is a misnomer.

3. “Political” influence is not the same as looking at the calculations and understanding the assumptions.
Jim Allen Reply

March 26, 2016 at 4:58 pm

So if we didn’t build the number of houses estimated as necessary from 2003, then the shortfall should be added to the new 2015 estimate to decide the new estimate – of the number needed. To me that is an irrational argument.

It is like saying I’ve estimated I need five loaves of bread for every month since May 2003, as I haven’t needed them, because I was fed elsewhere – I have to buy 10 loaves next month and every month until 2032 to make up for my poor estimate of food requirement 13 years ago.

The number should be forward looking not retrospective of past failures. I understand that after the Napoleonic wars thousands of soldiers returned homeless. Have we factored this in?
Ben Paton Reply

March 26, 2016 at 5:04 pm

How can a computation which no one has seen be ‘objective’? How can a result be ‘objective’ if no one can scrutinise it?

Guildford Borough Council (GBC) officials and borough councillors have not seen the arithmetic model because GBC claims never to have received a copy of the model.

Why hasn’t GBC received the model? Apparently because its contractor, GL Hearn, subcontracted the arithmetic to Justin Gardner Consulting. And we are told JGC will not release the model – despite its website stating that its models can be tested.

What is objective about any of that? This is a public process using public figures for a public purpose. What is there to hide?

The raw ONS statistics tell a different story from the GL Hearn report. The 2012 Based Sub National Population Projections can be downloaded on the internet. In the period to 2031 births (32k) less deaths (19k) increase the population by 13,000. Net internal migration (that’s movement within the UK) is a negative 14,800.

If you only consider natural causes (births and deaths) and movement within the UK (internal migration) the population of Guildford is projected to fall by 1,800 by the year 2031. Therefore the entire projected increase in the population of Guildford to the year 2031 is due to net international migration.

Given that the national government has made election pledges in the last two general elections to reduce net international immigration what is the justification for Guildford’s ‘objectively’ assessed housing need?

Let those who believe that there is a shortage of houses in the UK present their statistics. ONS figures show that the number of houses and the numbers of households move together closely over many decades. The statistics do not show a material divergence of the two.

Why does Mr Scott wish think it unnecessary for the public to be able to see the figures?

Why should the 21st century put aside centuries of democratic scrutiny? Why should the ’21st century’ oblige us to take more than our share?

There is no factual basis for Mr Scott’s notion that housing is debt which must be shared around.
Tom Stevens Reply

March 26, 2016 at 8:14 pm

BANANAS is a bit forced. This and the rather pathetic charge of nimbyism misses the point, many people object to developers building over the countryside and the resulting destruction of our environment.

Planning at a national rather than a local level could make much better use of existing housing stock and brownfield land across the country and help develop economies outside the South East.

A SHMA, which drives more people into the South East, would only seem to benefit developers and landowners in this area, not the country as a whole and certainly not future generations, who would question how we allowed this to happen.

If we are reduced to name calling, perhaps there should be an acronym for someone wanting to concrete over countryside.
- Harry Eve Reply
  
  March 28, 2016 at 8:55 am
  
  Tarmac Over Everything Rural And Green ?
  
  or,
  
  Concrete Over Wild Places And Tourism Sites (One for the Newlands Corner issue).
  
  I doubt whether these will make the development industry go bananas but their arguments have been seen through and close scrutiny of all “evidence” is the way to go.
  
  Thanks. I think that’s enough of the alternative acronym’s now. Ed
Jim Allen Reply

March 27, 2016 at 9:10 am

How about “TOEPET”?

Tarmac Over Everywhere Profit Every Time!
- Harry Eve Reply
  
  March 27, 2016 at 12:48 pm
  
  Or GRUBBIES – Greed Rules Under Big Business In Every State. A bit contrived but I started with a word that best describes what is going on.
  
  I have thought of others but they would never pass scrutiny by The Dragon – and rightly so.
Garry Walton Reply

March 27, 2016 at 9:41 am

There is a lack of logic in Mr Phillip Scotts’s argument.

Green belt land is a national asset similar to national parks. It benefits all. It is not a NIMBY (not in my back yard) issue. The green belt is London’s backyard. It isn’t there to have concrete poured on it, it is there to provide recreation space and a lung for London into the 21st century and beyond.
Neville Bryan Reply

March 28, 2016 at 8:15 am

For me, simply “Greed Belt” works. Every developer wants a piece.

However a few comments for Mr Scott.

The SHMA produced in this way is not independent or objective. It is produced by a member of the developer community. It also contains assumptions, where we (the public) cannot see what they are or who made them.

The current Guildford build number of 322 per year was fought for in 2009/2010 and won by Guildford Borough council against the South East Plan which wanted 422 per year. The only thing which has changed since is the opportunity presented by the NPPF (National Planning Policy Framework) to the house builders, and GBC now being told in the future they can keep any business rates. Greed perhaps?

I am not against your point on building houses. That is what we need to use the brownfield land for; not acres of new retail. This is an approach which has not worked, defies common sense and bucks current trends toward online shopping.

I understand a draft of the Local Plan will be published in the next week or so. I sincerely hope all the input from last time has been taken on board and we start recycling land rather than bulldozing farms and fields.
Colin Cross Reply

April 9, 2016 at 10:03 am

I agree with a lot of Ben Paton’s arguments but am surprised he omits to mention the Pegasus Green Belt and Countryside Study (GBCS) report from 2014 which Guildford Borough Council (GBC) insist on retaining as an integral element in its Local Plan structure.

The report is deeply flawed and amounts to a fatuous concoction of wild assertions and irrelevant examples from non-comparable sources.

Until GBC see the light and abandon the GBCS we will never get the balanced and proportional approach that is a pre-requisite to all sound Local Plans.

I also agree with Mr Scott’s assertion that every ward and parish should take its fair share of new housing but that is a long way from GBC’s approach wherein the town centre, which accounts for half the boroughs population, is only currently being allocated around 25% of the new LP target. Is that fair and proportionate?

Lovelace Ward, with less than 1,000 properties is being hit with over 2,500.

GBC must go back to the drawing board and get some new calculators surely?

Colin Cross is the Lib Dem ward councillor for Lovelace (Ripley, Wisley and Ockham.)