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Opinion: This Crucial Decision on Housing Must Be Scrutinised

Published on: 24 Mar, 2016
Updated on: 29 Mar, 2016

Screen Shot 2016-03-24 at 21.27.22By Susan Parker

Leader of the Guildford Greenbelt Group at Guildford Borough Council

Setting a housing target for our borough is probably the most important decision Guildford Borough Council will take over the next decade.  How many homes should we build?

The decision will affect how our borough looks and what it will be like to live in for the foreseeable future. There will be no going back.

At the council’s Overview and Scrutiny Committee, last week, I proposed that the committee should scrutinize the assessment of housing need as set out in the the  Strategic Housing Market Assessment or “SHMA” and the derived housing target.

Opinion Logo 2That housing target will be used in the Local Plan. The next version, incorporating that target, will be published in draft form in April.

I believe that we review the housing target. It is crucial. A major role of councillors is to scrutinise decisions. We have a moral responsibility, and right, to examine that number.

The proposed target for new homes will affect living in or around Guildford.

GBC has handed over responsibility for the SHMA to consultants GL Hearn. Their calculation of Guildford’s “need” is 693 homes per annum. This may well also be the possible target or requirement for the next 20 years covered by the Local Plan.

Some members of the Executive have indicated, in public meetings, that constraints, such as 89 per cent of our borough being designated green belt, won’t be applied to housing need to give the target…

The first draft of the Local Plan is due to be published in a few weeks. 693 homes every year. If the plan runs 20 years from approval, it would mean a total of 13,860 homes.

This is an increase in housing compared to current homes of more than 25 per cent.

To add 25 per cent to the stock of houses in the borough without any meaningful increase in existing infrastructure will result in more traffic jams and more pressure on school and health resources.

The target will not be just an aspiration but a binding commitment. Such an increase will change our area completely: any decision must be subject to proper scrutiny.

The numbers are not being debated publicly.  No members of the public are allowed to review the GL Hearn model used to calculate the housing number, despite Freedom of Information requests taken to the Information Commissioner. My request to run sensitivity analyses on the model has been rejected.

The previous draft SHMA, in 2014, gave rise to a target of 652 dwellings per annum, that number caused concern at the time. If we re-calculated the number on roughly the same basis as 2014, we would now have an “Objectively Assessed Need” (OAN) number of 517 dwellings per annum.

But the housing target has not gone down because the basis of computation has been changed. It now includes an extensive component for “growth”, generating a revised number which we are told we have to consider “objective’.

How do we know GL Hearn’s calculation of the OAN is correct? Many questions remain:

Are the assumptions valid and what are the assumptions?

Why has extra growth been added in to the calculations?

Why has the number gone up, when it would be lower if you used the same methodology as last time?

Why has there been no consideration of the SHMA in any council meeting, despite publication in October? Why was my proposed scrutiny rejected by all the other parties? What are they scared of?

Why should we not apply green belt and infrastructure constraints as legally allowed?

What will be the implications for our borough?

Why are we not debating this in public? Why are we not even debating this within the council?

I wanted to consider the assumptions, the mechanism, and look at some sensitivity analysis so we could have a democratic decision as to whether these numbers were right.

The scrutiny committee is the only part of the council that can legally scrutinise or challenge the decisions of the Executive. If it does not debate this important issue it will have failed, failed the people of Guildford Borough.

What do you think? Should the number of houses that are to be built in Guildford be subject to further scrutiny within the council or should we trust the professional consultants’ report and their objective assessment? Please use the Leave a Reply feature below to have your say.

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Responses to Opinion: This Crucial Decision on Housing Must Be Scrutinised

  1. Harry Eve Reply

    March 25, 2016 at 11:25 am

    Among the appalling excuses given for not scrutinising the figure were incompetence and that it is too late. This begs the question, why was scrutiny not undertaken much earlier in the process?

    Did the Executive suppress scrutiny and, if so, why? It appears that most of the councillors do what they are told to do by their party leaders. Abstention is as far as any of the majority party dare to go. If they speak out they are accused of stupidity.

    Another excuse given was that, as GL Hearn had done so many SHMAs, they must be right. But GL Hearn are connected with the property development industry, a SHMA calculation requires many assumptions and calculations to be made and, apparently, they refuse to reveal the details.

    What are the scrutiny committee afraid of and why do they seem incapable of scrutinising?

  2. Neville Bryan Reply

    March 25, 2016 at 1:49 pm

    Where is our representation in the local plan process?

    I could not believe what I heard at the scrutiny committee last week. Guildford Borough Council (GBC) will now not be scrutinising at all the Strategic Housing Market Assessment (SHMA), one of the most important parts of the Local Plan evidence base.

    Guildford are now likely now to have a proposed house assessed need the Objectively Assessed Need or OAN of a whopping 693 new houses per year, 115% higher than GBC themselves fought for and agreed in 2010.

    It also seems likely this will be applied without constraints and consequently most houses will be built on green belt land, something many of us want to protect.

    This SHMA is authored by GL Hearn who make their money through the house building industry. Yet still the Guildford area SHMA will not be checked or questioned.

    Take the personalities and party politics out of this, and the pattern shows a well funded assault on our green fields in the pursuit of profit. But not just by the house builders.

    – Local Planning Authorities (LPAs) appear to want to avoid justifying high numbers. Why? The move of the last two governments is away from central local authority funding, towards business rates going directly to LPAs. It provides a strong motivation for Guildford to turn brownfield land (much of it in Guildford’s case owned by Guildford) into business areas, from which the income will be kept by Guildford, good for its coffers. But of course, this leaves most new houses to be built on the green fields.

    – The land owners want high numbers. Why? Profit. Many fields previously dedicated to agriculture, will now be built on and when £8K an acre for farmland turns to £1 million per acre overnight who would argue?

    What’s in it for us the public? Probably just green belt land erosion and traffic congestion. There will be no cheap housing and certainly no affordable housing to the average man in the street. The “right to buy”, so popular in the 1980’s, has developed into a housing system dependent on expensive private rentals, with an ever decreasing council stock, and suspiciously high housing waiting lists. Only the housing associations have been building in large numbers in recent years, and even their stock is now at risk for the next generation.

    Are we to be forced to defend our green and pleasant land by ourselves? It appears so.

    Our elected councillors are there to question and to scrutinise on our behalf, yet even after a direct request by Sue Parker of the Guildford Greenbelt Group, most councillors in this GBC committee failed to grasp or even question even the basic rational of the SHMA.

    To me this is a basic and total failure of the local government system (whatever the housing number) and a failure of most councillors to represent the people who elected them.

    It also, as Sue Parker outlines above, exposes Guildford to massive building in green belt areas where infrastructure cannot support it.

    Welcome to the new Croydon everybody.

  3. David Raison Reply

    March 25, 2016 at 2:18 pm

    Such decisions must be subject to scrutiny. The council is wrong to block Freedom of Information requests on this matter.

  4. Mary Bedforth Reply

    March 25, 2016 at 8:28 pm

    G L Hearn are now owned by Capita whose name is often misspelt on the internet. [Capita Chief Executive Andy Parker said at the time of acquisition: “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.”]

    Many of this country’s functions are now outsourced to Capita, more so under the current government.

  5. Andrew Procter Reply

    March 26, 2016 at 1:08 pm

    I am disappointed but not altogether surprised that Guildford Borough Council has refused the reasonable and well intentioned request of Cllr Parker to scrutinise the housing need number that has been prepared by GL Hearn for three reasons:

    1. She is quite correct to assert that “a major role of councillors is to scrutinise decisions”. The whole point of “scrutiny” in the local government process is to ensure that major and important decisions and the data supporting those decisions is carefully checked out and made clear and transparent.

    2. GBC has stated publicly that the SHMA (Strategic Housing Market Assessment) and the data used in support “as an evidence based document is by definition not subject to debate”. However, GBC has failed to realise that they have a clear responsibility under Para 159 of the NPPF (the National Planning Policy Framework) to “have a clear understanding of housing needs in their area” since in my view defensiveness and the absence of debate concerning the reliability of data is very far from a “clear understanding”.

    3. On a number of occasions GBC has refused reasonable Freedom of Information requests by members of the public to reveal details of the arithmetical model which supports the SHMA data. The reason they have given is that the sub-contractor employed by GL Hearn to run the model is claiming intellectual property rights to his model.
    GBC has already spent many millions of our pounds in procuring consultancy advice for the new Local Plan and is now showing potential incompetence in terms of consultancy procurement if it has managed to choose a consultant without the core competency and ability to construct their own demographic model.
    Even worse, the council appears to have failed to ensure that the main contractor is able to provide, through proper due diligence, that the workings of the model are demonstrably transparent and correct because they are prevented from doing by their own sub-contractor claiming intellectual property rights to the model used.
    I am afraid that GBC’s failure to respond to these arguments appears to be obfuscation. I would also suggest that the absence of a transparent model that provides supporting data is also very far from a “clear understanding”. My worry is that if the council cannot give the public a “clear understanding”, do they, themselves, have a ”clear understanding”?

    I am of the opinion that GBC needs to markedly improve on its performance as a council and a planning authority if the electorate can be confident that it is acting wisely and responsibly and in a transparent and democratic way in planning the future of Guildford Borough for the next 20 years covered by the Local Plan.

  6. David Burnett Reply

    March 30, 2016 at 1:26 pm

    I too would like to see the workings behind the SHMA. I have signed, and would encourage others to sign a petition asking for full disclosure:

  7. F M Robertson Reply

    April 6, 2016 at 4:56 pm

    I agree with the arguments put forward above and would also encourage others to sign this petition asking for full disclosure.

    It is an absurd dereliction of duty by the council not to have scrutinised the methodology used to arrive at this housing requirement figure.

  8. Harry Eve Reply

    April 7, 2016 at 8:19 am

    I wondered how GBC would deal with this petition. It appears that they propose not accepting petitions from organisations like

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