Letter: Population Projections Must Be Transparently Disclosed

Published on: 1 Sep, 2014
Updated on: 1 Sep, 2014

From Ben Paton

Guildford Borough Council has put forward a plan to permit more than 13,000 houses to be built – an increase of some 23 per cent on the present stock of housing in the borough.

Typically that could mean an extra 20,000 cars on our local roads and potentially another 32,000 residents.

This estimated housing ‘need’ is supposed to be justified by evidence. That evidence not been properly disclosed. On 9 July I made the following Freedom of Information request:

“Please supply a copy of the GL Hearn housing projections model. This model has been prepared as part of the evidence base for the new Local Plan and forms part of GL Hearn’s SHMA [Strategic Housing Market Assessment] document. The model is maintained, I expect, in spreadsheet format. Please supply an electronic copy of the model in a conventional spreadsheet format ie Excel or similar.

“Please ensure that all assumptions are explicitly stated. Please ensure that any linked data is also supplied or supplied in hard copy form.”

Since my request in July I have followed up twice, on 15 and 20 August. The rules allow the Council 20 working days to respond and we are now well beyond the allotted interval. To date I have received nothing.

This information goes to the heart of the draft Local Plan. It is often casually stated: ‘but the houses have to go somewhere’. This really means, ‘but the people have to go somewhere’, which in turn begs the question, which people and when?

The facts and assumptions behind the projected housing ‘need’ have not been properly disclosed. The GL Hearn report is inadequate in this respect. Figure 9 in the draft SHMA, for example, shows the changes in the borough’s population between 2001 and 2011.

A substantial proportion of the change is described as ‘unattributable’. About half of the increase is described as ‘net international migration’. Much about these figures is a mystery. The ONS [Office of National Statistics] does not have any category called ‘unattributable’ and GL Hearn’s figures are impossible to reconcile back to official statistics.

I suspect that everyone in the borough would expect that local need for housing should be planned for – in other words the increase driven by the net excess of births over deaths. Many however will have reservations about building houses for people who, it is conjectured on the basis of undisclosed figures and assumptions, might migrate here from within or from outside the UK.

The age profile of the population of Guildford has a pronounced ‘bulge’ in the 18-24 year age range. Ordinarily a statistician would expect the need for housing to grow as this section of the population ages. This is exactly what the housing need projections assumed.

However it is now known that this population bulge is not the harbinger of future population growth – just the reflection of the fact that there is a university in Guildford. The ONS has confirmed in writing that it would be wrong to project population growth on the back of this bulge. We have been promised revised projections. None have been forthcoming.

Projections of population growth are the central justification for the housing ‘need’ that is being planned for. Failure to disclose this information, especially during a public consultation is not accountable, open, or honest.

Ben Paton is the nominated Conservative candidate for Lovelace in the forthcoming by-election on September 25.

Responses to Letter: Population Projections Must Be Transparently Disclosed

Jim Allen Reply

September 1, 2014 at 9:09 am

I too have serious concerns of the final housing figure but approach it from a slightly different angle. The excuses for failing to provide basic data used are many.

I have just received the accident data for the whole of England from pre-2000 to 2012, via the Highways Agency (thank you). There is so much data MS Excel cannot handle it all and it had to be placed in a data base.

This shows that the data/ information needed is available, someone seems to be blocking its supply. The next step is to complain to the Information Commissioner.

My approach to housing numbers is far simpler:

In 2010 a court hearing at the high court found in favour of GBC planning department when they challenged the South East plan number of 440 homes per year, the then current figure was around 350 homes per year. Now, four years on, a figure of 652 is now bandied around as the number

So my question is what has changed? What has happened in the last four years since the courts agreed with a figure less than two thirds of claimed current demand.
Michael Bruton Reply

September 1, 2014 at 11:22 am

Mr Paton’s experience of Guildford Borough Council and the Freedom of Information Act (FoIA) chimes with my own.

Tory Guildford Borough Council (GBC) claims to be open and transparent (all councils do). But it is not.

I have had to approach the Information Commissioner twice this year to get answers to simple questions. As with many public authorities, the nearer one gets to inconvenient truths – the more the public authority clams up. Tony Blair once remarked that the one piece of legislation he regretted passing was the FoIA. I wonder why?

Public Authorities dislike/fear both the FoIA and the Environmental Information Regulations (EIR). The latter can be used for most questions regarding the Local Plan for obvious reasons. The virtue of the EIR is that it is EU legislation – linked to the Habitats Regulations – and one can bypass eventually anything that UK public authorities refuse.

It is worthwhile persisting with FoIA/EIR Requests as the ICO takes a dim view of authorities who keep avoiding their responsibilities and can take enforcement action against persistent recalcitrance.

This should be a subject for investigation by the Guildford councillor responsible for Governance [the lead councillor for Governance at GBC is Cllr Paul Spooner, Con, Ash South & Tongham]. But I do not hold my breath where GBC is concerned.
Tony Edwards Reply

September 1, 2014 at 1:34 pm

The people of Guildford are clearly in a state of despair over the lack of accountability, transparency, and clarity emanating from Guildford Borough Council (GBC).

Michael Bruton’s comment: “I do not hold my breath where GBC is concerned,” is echoed across the borough by residents raising valid concerns and requesting a valid response – but not getting one.

Perhaps the pompous ‘politicians’ at Millmead would do well to remember that they were elected to represent the people and to listen and react to their comments and opinion – not to assume a Stalinesque stance and a mode of secrecy worthy of the KGB during the cold war.
G Moore Reply

September 3, 2014 at 11:38 am

The GBC Draft Local Plan is fundamentally flawed.

1. “Objectively Assessed Need” is not defined. Whose need? Guildford’s or central government’s, or some shadowy band of property developers’? Where does the pressure come from?

If the Executive continue to ignore Freedom of Information requests to explain the housing need, the “consultation” is a farce.

2. The constraints on expansion are not objectively analysed. What are the topographical constraints? How important is the metropolitan green belt? How bad is the present state of traffic congestion? How can this be alleviated?

3. What effect on traffic would any given level of further expansion have (including expansion in neighbouring boroughs such as Woking, Cranleigh, Dunsfold, etc.)? How could this be alleviated, at what cost and how funded?

4. The consequences of expansion for other public services, schools, hospitals, etc also need to be analysed, planned, costed, etc.

If the Plan does not fully describe these constraints, we can hardly complain if the Planning Inspector fails to take them into account when reviewing the plan. The plan is not soundly based.

The leader of the council is “on a trajectory” to bulldoze this draft plan through. The trajectory is however in the wrong direction and evidently opposed by the vast majority of the residents of the borough – whether or not they have had time to wade through the turgid prose and selective statistics of the planners and consultants.

The lead member in charge of planning has already resigned. The leader of the council himself should now accept that this Draft Local Plan is not acceptable to the voters of the borough. He should resign, before any more time is lost on the wrong trajectory.
Adrian Atkinson Reply

September 6, 2014 at 3:56 pm

Having come back from two Draft Local Plan focus events run by the Parish Councils in and around West and East Horsley I came away with two conclusions:

1 Not one person I spoke to was in favour of what was being proposed. Most accepted some development across the borough to meet growth and net increase as a result of births and deaths.

2 More troubling was something confirmed to me by a person close to the proceedings, something which I had very briefly picked in in a webcast of a GBC meeting of some sort, but hasn’t really been made clear in public.

No matter how many errors, miscalculations, lack of green belt/AONB constraints applied, windfalls taken, which ONS data used, how students are dealt with – the proposed annual housing number will not be changed that much.

Why? Is it because this number, whatever it may be, reflects the correct number the borough needs and can cope with? No. When this plan finally goes in front of the inspector, as I understand it, the consultants have to effectively stand shoulder to shoulder with the GBC representatives and agree that this is a sound plan.

If the consultants don’t agree with the number in the plan the, inspector will, as I understand it, deem the plan unsound.

So what does this effectively mean? Even if, as many peoples have done in vast detail on this site and others, show the evidence and calculations and forecasts are flawed and GBC agree with that view they can’t submit a corrected number unless the consultant agree.

So, which consultant is going to agree that they had got it wrong, in public, bringing into question their future viability as a credible business? None, of course. In effect, the only way the number can be reduced is through negotiation with the consultants along the lines of:

“What, Mr Expert, is the maximum level of error are you able to accept and still keep face in public in front of the inspector?”

We might end up with a number which is less wrong than the one before but it will never be correct.

As leading councillors have said to many people before, “You may not agree with the number [PA housing number] but that isn’t to say it is wrong.” However, neither has anybody shown me why the numbers proposed are correct.

I would like the head of planning (whoever that is) to confirm or deny/explain that, unless the consultants agree to saying their number is wrong and others are right [significantly lowering the population forecasts/housing targets in light of overwhelming critique] there is no chance of the plan being passed as sound.

Where is the localism in that? It doesn’t matter what the public say or show or what our elected councillors decide, it is still down to the non-elected consultants who hold our borough to ransom.