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Opinion: Changes to Flawed Local Plan Will Decide Guildford’s Destiny

Published on: 14 May, 2021
Updated on: 16 May, 2021

By David Roberts

In The Times on May 11, the head of the UK’s statistics watchdog confirmed official projections for future population growth in Guildford were overstated, after an investigation of calculations by the Office for National Statistics, on which local planners heavily rely.

An Office for Statistics Regulation report said in university towns, including Guildford and Coventry, ONS projections were inflated by student numbers and were “inconsistent with, and potentially higher” than those suggested by local evidence, such as the number of young women, infants and school enrolments.

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. This also appeared to be the case in a number of smaller cities with large student populations. Ed Humpherson, Director General for Regulation, OSR

The ONS has been told to re-do its sums. In one sense, this error confirms what residents, including the Guildford Greenbelt Group, have been saying since the first draft of the Local Plan appeared in 2013. Most students move away after graduating and do not add to permanent local housing need.

But in another sense, the report is dynamite.

If, according to Britain’s highest statistical authority, Guildford’s future population has been exaggerated, so too have the housing targets in the Plan, throwing into doubt the conclusion of the government’s inspector, confirmed by three judicial reviews, that it is technically “sound”.

This means a technocratic review of the Local Plan, limited to questions such as whether supporting infrastructure gets built, is no longer tenable. Instead, it needs to reconsider the Plan’s fundamental housing-need assessment, and adjust its targets to lower population growth.

A whitewash review, for which developers and their political friends may have been hoping, could result merely in a judicial review defeat.

The OSR report has not come out of the blue. With the support of our R4GV council leader, Guildford was included on the initiative of GGG who participated with other residents in the investigation and provided detailed evidence.

Extract from Guildford Plan showing the projected population growth on which the plan was based.

An analysis by former GGG councillor David Reeve demonstrates the error in the ONS population estimate could amount to 12,000 over the 15-year Plan period, meaning an inflated housing requirement of about 5,000 dwellings with an excess, even in the first four years, of roughly 666 dwellings.

Population growth from 2015-34 would be 9,000 rather than the 21,000 predicted, implying the Plan’s housing target should fall from nearly 11,000 to 6,000, or from almost 15,000 to under 10,000 if total supply is counted.

This drop is huge enough to invalidate the Plan, stripping the need for all three giant “strategic” greenfield developments (Three Farms Meadows [former Wisley Airfield], Blackwell Farm and Gosden Hill), which look undeliverable anyway in the Plan period, and discrediting the rationale for removing most (15) of Guildford’s villages from the green belt.

So what needs to happen next?

  • All councillors, especially urban ones, should recognise over-development has already started to wreck communities such as West Horsley and urban regeneration is impossible without redirecting development away from our countryside;
  • The Planning Committee must immediately find a way to take account of the new population doubts in determining planning applications;
  • The Local Plan review needs to be meaningful, with an explicit objective to cut the housing target, rather than to secure government money for infrastructure as the Conservatives seem to prefer;
  • To restore public trust, all relevant terms of reference and consultancy contracts should be open to scrutiny before being approved. Strategic decision-making is a full-council competence and should not be made behind closed doors;
  • Consultants and council officers committed to the Plan as it stands should be reminded of councillors’ manifesto promises. Legal arguments to kick the matter into touch should be dismissed; and
  • GBC should press for the early release of 2021 census figures on Guildford’s population and engage whole-heartedly in the national statistical follow-up work necessary to correct the data and revise local housing targets, including removing the 20% buffer no longer required by a shortfall in Guildford’s five-year housing supply.

This is a moment of destiny for Guildford, not one for fudging or fence-sitting. If our ruling R4GV/LibDem coalition do not respond, they will go the same way as the Tories in 2019.

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Responses to Opinion: Changes to Flawed Local Plan Will Decide Guildford’s Destiny

  1. Jim Allen Reply

    May 14, 2021 at 8:10 pm

    A Pandora’s box of statistics, legality and common sense.

    Perhaps the NSO should finance and mount a judicial review, on the Guildford Local plan?

  2. Linda Parker Picken Reply

    May 15, 2021 at 11:49 am

    This is really good news given how long people, especially GGG councillors, have clamoured for the flawed ONS figures to be revised. One is reminded of how long it took for Monica Juneja to be outed as an imposter “barrister” while GBC Conservatives stood firmly behind her.

    For the full report by David Reeves see

  3. Adam Aaronson Reply

    May 16, 2021 at 9:56 am

    It is excellent news to learn that the ONS has been taking David Reeve’s research seriously.

    The last time former Councillor Reeve published some serious meticulous research on the housing numbers, the previous iteration of GBC, under the leadership of Cllr Spooner, supported by Cllr Caroline Reeves were so affronted by his daring to disagree with their consultant’s figures that they spent a great deal of their time trying to discredit him, rather than paying any attention to the accuracy of his research and in so doing wasted a huge amount of council time.

    I hope that the current leader of the Lib Dems, Cllr Julia McShane will have more sense than her predecessor and that she will steer clear of Cllr Spooner if he were to attempt to focus his energies on trying to discredit David Reeve again.

  4. Ben Paton Reply

    May 16, 2021 at 3:26 pm

    When will elected Councillors take responsibility for the Local Plan, roll up their sleeves, and actually examine the statistics that so many people have pointed out are flawed?

    We are where we are because the elected Conservative councillors in the last administration blindly followed their “leadership” which, in turn, predetermined the outcome by paying expensive consultants to calculate the housing need.

    The council should have done the calculation itself. But it was too lazy. It did not want to “own” the analysis itself. It was easier to be “unknowers”, to rely on a consultant, and to ignore the fact that ONS population projections are not reliable – as so many people pointed out on so many occasions.

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