Letter: There Is ‘Robust Evidence’ That Our Local Plan’s Housing Figures Are Wrong

Published on: 3 Nov, 2021
Updated on: 3 Nov, 2021

From Niels Laub

Following the Report by the Office for Statistics Regulation (OSR) in which they raised some significant concerns particularly that the population estimates for some university cities such as Coventry and Guildford did indeed seem to be inconsistent with, and potentially higher than local evidence would suggest, the GBC has now undertaken to carry out a review of the Guildford Local Plan which will include a full update and reassessment of the relevant evidence base used for the current Local Plan including the ONS population projections.

In my view, the following six issues alone give sufficient reason to question the Local Plan with its aim to build 562 dwellings per year and release 1,200 hectares of the green belt for development.

(1) The housing targets adopted in the Local Plan are based on population projections which, according to the OSR Report released in July, are likely to be overstated. In a letter to the council, Ed Humpherson, Director-General for Regulation at the OSR, said that “we found that the population estimates for some cities, such as Guildford, did seem to be inconsistent with, and potentially higher than local evidence would suggest”. The most likely explanation for this inconsistency is:

(a) that the ONS counts students as resident at their term-time address rather than their home address and;

(b) that the ONS is unable to accurately count overseas students returning home on completion of their studies.

(2) Some people argue that a review of the housing target will only result in a much higher figure because current legislation requires local authorities to assess their housing need by using the “Standard Method for calculating Housing and Economic Need Assessment”.

But the NPPF states “that the use of the Standard Method to calculate housing need is not mandatory but where an alternative approach results in a lower housing need figure than that identified using the standard method, the strategic policy-making authority will need to demonstrate, using robust evidence, that the figure is based on realistic assumptions of demographic growth”. (See SNPP Paragraph: 015 Reference ID: 2a-015-20190220).

The latest Household Projections released from the ONS predict a need for only 94 dwellings per annum in Guildford over the next 20 years – not 562 dwellings per annum in the adopted Local Plan. In my opinion, the latest official Household Projections would certainly be regarded as “robust evidence”.

(3) The proposed housing target of 562 dwellings per annum represents an uplift of 80 per cent over the demographically led housing need of only 313 dwellings per annum. This is because the demographically led need is boosted by factors to allow for economic growth and growth in student numbers.

In addition, the total site allocations in the Local Plan have the potential to deliver 14,602 homes over the life of the plan. This contrasts with the total housing requirement of only 10,678 homes over the life of the plan.

This represents a very substantial oversupply of land for development and questions whether there are sufficient “exceptional circumstances” to justify building on so much of the green belt.

(4) Highways England no longer has any plans to improve or upgrade the A3 as it runs through Guildford which was a stated condition of the Strategic Sites at Blackwell Farm and Gosden Hill Farm. With the unlikelihood of the new railway stations at Park Barn and Merrow now going ahead, there would appear to be insufficient infrastructure to support these developments.

(5) The A3 as it passes through Guildford is one of the most congested and polluted A roads in the whole of the UK. Highways England have conducted a series of pollution surveys which show that that pollution on the A3 as it passes through Guildford appears to be the highest in the country by some margin and twice the median level of the thirty worst places.

This has the potential to undermine the health and wellbeing of the people served by this corridor. Developing Blackwell Farm and Gosden Hill Farm without any improvements to the A3 will only increase traffic congestion and illegally intensify air pollution.

(6) Global warming is an issue to be taken very seriously indeed by all of us. The very act of building on the green belt, by destroying natural habitat and forcing more people to commute, does more harm than good.

According to the Royal Institute of Chartered Surveyors, about 50% of the whole life carbon emissions of a typical domestic dwelling are expended during the manufacture of the materials used in its construction like bricks and cement.

Bearing in mind that many scientists now believe that green fields and meadows are an even more resilient carbon sink than forests, building on the green belt only serves to intensify carbon emissions while reducing carbon sinks.

Rather than endlessly developing greenfield sites, we should be doing our utmost to repurpose buildings and preserve natural habitat and biodiversity.

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