Letter: The Way Our Housing Numbers Have Been Calculated Should Be Revealed

Published on: 7 Nov, 2015
Updated on: 7 Nov, 2015

From Ben Paton

What is the most important task entrusted to Guildford Borough Council (GBC) at the moment; the task which will have the greatest impact on the environment and the quality of life of its residents?

Many people would say it was the next Local Plan. And what is the most important element of the Local Plan? The regulations state that the starting point and foundation of any Local Plan must be an assessment of housing need.

How has the council gone about assessing housing need? Has it complied with the principles it avows, openness and transparency?

The regulations state that to assess housing need the council must make a Strategic Housing Market Assessment (SHMA). It can use its own employees and resources to prepare this or it can engage a third party. GBC chose to use a consultant called GL Hearn. GL Hearn’s first SHMA covered only the borough of Guildford.

After valid criticisms, led by Guildford Greenbelt Group, a new SHMA has been prepared drawing in the neighbouring boroughs.

The SHMA is built upon an arithmetic model which projects changes in population and other drivers of housing need. Most of the numbers in the SHMA and most of the critical judgements derive from that arithmetic model and the data and assumptions which underlie that model.

You might therefore think that councillors would have scrutinised this model and dissected and debated its data and assumptions. Since there was no evidence of any effective scrutiny of this model, since we were all in effect being told to take the numbers on trust, I put in a request to see the model, under the Freedom of Information rules, on 9 July 2014.

On 12 September 2014 I received a response attaching a spreadsheet. Someone had taken the trouble to copy all the cells of the spreadsheet as ‘values only’. In other words all the formulae from which the numbers derived were deliberately omitted.

To me this was extraordinary. Whoever copied the spreadsheet values must have had access to the underlying spreadsheet with its formulae. Yet they had gone to the trouble of deliberately omitting the formulae. So I wrote again and explained that my request expressly asked, “Please ensure that all assumptions are explicitly stated” and that the response therefore fell short of a proper answer.

In response the executive head of organisational development wrote back as follows:

“As you are aware, the model was prepared for GBC 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 that model publicly available. On that basis the information is exempt under the EIR [Environmental Information Regulations]…”

This seemed even more extraordinary. GBC was fulfilling a public duty, for a public purpose, using, for the most part, publicly available information. And yet it was not in possession of the model on which its conclusions depended. I explained that GL Hearn was GBC’s subcontractor and that it was presumably contractually obliged to hand over the work for which GBC had paid it.

The response that came back was that yes, GBC did indeed own the copyright to GL Hearn’s report but that I was mistaken. The model had not in fact been prepared by GL Hearn at all. It had been prepared by a small firm called Justin Gardner Consulting (JGC) for GL Hearn.

The reason for non-disclosure was apparently that JGC had ‘intellectual property’ in the model which it was not prepared to divulge to its clients GL Hearn/GBC.

This seemed to me to be ridiculous. According to its website JGC specialises in demographic analyses and integrating these into SHMAs. It has 250 public sector clients and has built models for the SHMAs of a very large proportion of all the local authorities in England. The idea that it should have some novel method of analysing demographic data which is somehow novel, patentable, and non disclosable seems to me to be ridiculous.

I therefore complained to the Information Commissioners’ Office. (Click here for full response.)

The nub of the matter is that:

1) The Information Commissioner has determined that “on the basis of the available evidence” GBC has never received a copy of the Justin Gardner arithmetic model

2) “The council has explicitly stated to the commissioner that there is no business need for the council to hold the formulae in question and that the information is not held by the consultant on the council’s behalf.”

Is this satisfactory? Can it really be said, with a straight face, that the council has “no business need” to hold the formulae in question? Does it not need the formulae to understand the model and to justify the housing need?

Or is it content, for whatever reason, to comply with an assessment that might be exaggerated because it depends on formula that have not been disclosed or understood.

It has taken care never to receive a copy of that model or to enquire into how the assumptions and formulae have been put together. The consultant in question has declined to disclose the formulae and GBC has apparently taken no steps to insist that the formulae are fully divulged to it.

Whatever hypothesis one may have for how this has come about, why would not the council insist on having full, transparent and open disclosure of the model on which its housing need assessment is based?

How can the council do its public duty if it does not obtain, disclose and debate the model and its data and assumptions? When it is known that there have been errors and distortions in the demographic projections caused by the presence of a university in the borough, is it not essential that the assumptions are set out?

One assumes that borough councillors are elected to scrutinise important matters such as the Local Plan, the demographic projections, and the work of the council’s employees and contractors. But presumably not one councillor has been able to see the housing model – because GBC professes not to have a copy?

How can they do their jobs without seeing it? How is this possible? Is it because all the big decisions are made by the Executive?

In my three minute speech to the council in relation to the Issues and Options Paper I said, ‘Councillors have failed the public.’

The failure to scrutinise transparently the housing need figures is a good example. The failure to disclose the housing projections model is extraordinary. The reasons given for non disclosure that 1) GBC does not and has never held a copy and 2) it has no business need to hold a copy, in my opinion, beggar belief.

Responses to Letter: The Way Our Housing Numbers Have Been Calculated Should Be Revealed

Lisa Wright Reply

November 7, 2015 at 10:16 pm

Before we get to the modelling, how was the data that was used in the model chosen and who made those choices?
Andrew Procter Reply

November 8, 2015 at 9:40 am

Ben Paton’s letter raises an important issue. If the SHMA is built upon an arithmetic model which projects changes in population and other drivers of housing need it follows that the core ingredient of the SHMA consultancy project is indeed the model.

It is of concern that the consultants chosen and employed, G L Hearn, in preparing the SHMA do not have the competence or resources themselves to build the model required. They have in effect sub-contracted the core component to a small independent consultancy practice and to have done so in a way that would appear to deny them or the client (GBC) the opportunity of interrogating the accuracy of the model.

It follows that the consultants will not therefore be able to warrant that the model has been carried out accurately because they are denied the opportunity to validate or test key components. I do not believe this represents value for money or good practice in terms of competent procurement by GBC.
Jim Allen Reply

November 8, 2015 at 1:27 pm

Actually the claim “no business need” is strictly correct – they are not a business so have no business need. They have mixed their, or our, commercial land and property holdings with their public responsibility / dutyto the community.

The council is a public authority and as a public authority they should not deny the public the mathematical justification for their proposed housing number plan.

I personally await their roads plan, also under complaint to the Information Commissioner. I suspect the Information Commissioner has a special and commodious filing cabinet for Guildford Borough Council correspondence.
Valerie Thompson Reply

November 8, 2015 at 2:48 pm

Who paid for this survey?

Presumably GBC used our money, raised through the rates, to pay for something it does not own, does not want to see and has taken no notice of in its planning decisions.

So much for “openness” etc.

GBC must take their responsibilities more seriously.

In fact, because the councillors have not seen or debated this document the whole process of planning for extensive housing in the borough is possibly invalid.

To make decisions on something paid for by GBC residents and kept private, even from the councillors themselves is immoral and maybe illegal.
Fiona Curtis Reply

November 8, 2015 at 8:21 pm

This reminds me of a sketch from the Hitchhiker’s Guide to the Galaxy where the computer said the answer to the ultimate question of life, was ’42’ but know one knew what the ultimate question was?

I completely agree this beggars belief. It was repeated over and over again in the feedback from the consultation that took place last year that the analysis behind the figure (which was at the time 600-800 and was highly criticized as inaccurate, vague and erroneous) should be transparent.

If G L Hearne is unable to produce the analysis having sub-contracted the core part of the job to a third party then my view would be to start again. Produce a watertight brief that doesn’t permit this evasion of responsibility with a company who is willing to provide open, easily understandable information so that we and GBC can make informed decisions.
Jules Cranwell Reply

November 9, 2015 at 9:14 am

Does this smoke and mirrors approach to the SHMA not suit GBC’s highly controversial ‘trajectory?

I challenge the current lead councillor for planning, Cllr. Spooner to give us the model, including its formulae and algorithms, and let us draw our own conclusions. If he will not, we may well conclude that this obfuscation is nothing but deliberate.
Peta Malthouse Reply

November 9, 2015 at 11:54 am

So how can we, or anyone else, rely on the projection figure this model has come up with? It cannot be commercially sensitive as it has to be justifiable. How stupid. How ridiculous. Why am I surprised?

It comes down to plain straightforward use of smoke and mirrors to hide information from us, the voters, the stakeholders, call us what you like. We should know and we are being tricked.
Graham Moore Reply

November 9, 2015 at 4:45 pm

The whole idea of the Strategic Housing Market Assessment [SHMA] is absurd. The demand for housing is dependant on the price at which it can be provided, which of course is a function of supply. No market assessment is valid therefore unless the constraints on supply are properly understood and defined, and an outline plan for providing the necessary infrastructure is sketched.

We need to know how much the demand for houses comes from existing residents of the Borough, how much of this consists of “affordable housing”, how much from the changing profile of household units (due to demographic trends, etc), and how much should be allowed for organic economic growth.

Any additional housing need comes from migration into the borough (mainly from London). This demand, whether for “affordable homes” or “executive housing” will require major improvements in infrastructure and will have to be met by substantial inroads into the green belt and financial contributions from central government.

As far as we know, none of this formed part of G L Hearn’s “objectively assessed” calculations of our (the borough’s?) housing need. Will the new leader of the council continue on the old blind “trajectory” of his predecessor, or will he/she take a more objective assessment of the factors involved – and explain them to the people of this borough?
Adrian Atkinson Reply

November 9, 2015 at 10:25 pm

The assessment of development and housing need in the Strategic Housing Market Assessment (SHMA) is an objective assessment of need based on facts and unbiased evidence. This is clearly set out in the National Planning Policy Framework (NPPF).

Objectivity refers to the elimination of subjective perspectives, a process that is purely based on hard facts and not influenced by external pressures or vested interests. Whatever the output, it can be logically followed by other objective bystanders and reach the same conclusion. Just because it is done by someone else and out of one’s control doesn’t mean it is objective or independent.

Building on Mr Paton’s letter above, I wish to reiterate many submissions in the last consultation and other comments since. The GL Hearn housing need suggestion cannot be seen as objective. Mr Paton puts forward a number of reasons but I would like to add another.

Objectivity is, by its definition, only possible if there is absolutely no vested interests in the particular output. In this case the SHMA and the proposed future housing need.

As Mr Paton and others point out, we just don’t know where the SHMA numbers come from. We, therefore, have to take into consideration other elements to draw a reasonable conclusion which the average person on the Clapham omnibus would draw in the absence of transparency of their model.

GL Hearn have recently been bought by a development conglomerate, Capita. At the time they said: “Capita today announces that it has acquired GL Hearn, a market-leading UK property consultancy business, for a cash consideration of £25m on a cash free, debt free basis, plus a deferred consideration of £5m.”

“GL Hearn provides commercially driven advice to land owners, developers, house builders, investors, retailers and the public sector. Its client list includes some of the UK’s largest retailers and developers, as well as a number of other blue chip companies. “GL Hearn reported an operating profit of £5.8m on turnover of £31.2m in its last financial year up to 31 May 2015. Capita expects to grow the business and achieve a return on capital in excess of 15%.”

“The company is a market leader in planning, development and regeneration. It employs over 250 staff, and has its head office in London. GL Hearn has a strong record of delivery in London, as well as across the rest of the UK – which it serves from seven regional offices, including Glasgow, Manchester and Southampton”

Let the words of Andy Parker, Capita’s chief executive, speak for themselves:”GL Hearn will be a transformative addition to Capita’s property and infrastructure business. Beyond extending and enhancing our existing real estate offer, GL Hearn’s track record and range of expertise will allow us to provide market-leading commercial, technical and strategic advice across the entire development process.

For the wider group, the acquisition of GL Hearn will allow us to develop and offer new and extended propositions to all the sectors and clients we work with. We see a particular opportunity to work with a number of our clients to add value through the commercialisation of their existing asset bases.”

Brian Sloggett, managing director of GL Hearn added: “Following its acquisition by Capita, and over 90 years since it was first founded, GL Hearn has entered into an exciting new phase. It will join forces with Capita‘s real estate business to generate a new and unique powerhouse in the UK property market. Being part of Capita will enable us to accelerate the growth potential of the GL Hearn business and build an even stronger platform for ours and Capita’s public and private sector clients.”

“We are confident that our combined clients and team will derive considerable value and opportunity from this acquisition.”
Adrian Atkinson Reply

November 10, 2015 at 7:22 pm

In answering one of Mr Moore’s questions one of my posts in this thread https://guildford-dragon.com/2015/11/01/opinion-cramming-housing-into-the-town-centre-is-not-the-answer/#comment-151400 shows that existing residents of the borough (births minus deaths) accounts for about half of it. Immigration offsets a net outward migration from the borough creating the other 50% of the forecast population growth forecast.
Michael Bruton Reply

November 11, 2015 at 4:31 pm

The new Local Plan will of course be examined, in due course, by a planning inspector in public. It will be interesting to see how Guildford Tories answer the question “You accepted a housing figure based on a formula paid for by taxpayers. You have failed to verify that formula. The company behind the formula refuses to reveal that formula. So how do you know whether the formula has any validity whatsoever?”
Richard Edwin Reply

January 28, 2016 at 5:12 am

Ben Paton has reinforced my view that Guildford Borough Council is not presently fit for purpose.

Notwithstanding the recent change in the leadership, the fundamental responsibility of the council in putting forward a new Local Plan, particularly in light of the last Draft Plan being so severely criticised and undermined, is to ensure that the entire basis on which a new Local Plan will be founded is sound.

There appears to be no evidence that either the council, or GL Hearn on its behalf, have sought to review and/or satisfy themselves that the assumptions and calculations applied in developing the new SHMA are correct.

I suggest therefore that GBC has opened itself to yet another legal challenge regarding the validity of the new SHMA and Local Plan, as and when it is published, on the grounds that this is a fundamental breach of planning policy!