Fringe Box



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

  1. Lisa Wright Reply

    November 3, 2021 at 1:33 pm

    The council may wish to take note of the UN Sustainable Development Goals, particularly goal 15 “halt and reverse land degradation and halt biodiversity loss” and Goal 11 “Make cities and human settlements inclusive, safe, resilient and sustainable”
    More info;

    Additionally, there’s been quite a few changes in some of our local housing which is now being sold/rented to locals as opposed to being filled with students. I wonder if there’s been a drop in students at the University this year?

  2. Jim Allen Reply

    November 3, 2021 at 2:40 pm

    A well-written argument which definitely undermines my housing number calculation of 2015 by over 50% which was 50% of the 562.

    If only the 80,000 comments on the Local Plan had been read and acted on.

    We could have had an upgraded sewage treatment works 10 years ago, reducing storm spillage into the Wey. The allotments would not still be under threat, and the Wey Navigation tree and towpath loss would never have occurred, the Weirs would not have been undermined.

    All because of the ignored 80,000. The number should be branded on the forehead of all who chose to ignore them.

  3. D Harmiss Reply

    November 5, 2021 at 9:13 am

    An excellent letter, made even sharper by the ludicrous Weyside Urban Village project approved last week, placing micro homes on contaminated land while destroying a greenfield site and generating vast polluting by forcing council service vehicles to do thousands of extra diesel miles a year through urban areas. At the same time, they are bulldozing incredible community and social resources like Bike Project Surrey, at a time when promoting sustainable transport should be at the very top of the council’s aims.

    A graphic illustration of yet another abject failure of Guildford’s utterly appalling governance; its population deserve so, so much better.

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