ONS Data Flaws!
GGG has long maintained that the data used in the most recent Guildford Local Plan to project housing need was inaccurate. We have received permission to publish the below letter, penned by supporter Niels Laub to various potentially interested Conservative MPs with constituencies local to Guildford. His reaction followed the recent publication of the 2021 Census data. Guildford was estimated to be home to 150,352 people in June 2020 but the census showed it had almost 7,000 fewer the following March.
Niels was also quoted in this item in the Guardian published on 29 June.
The Rt Hon xxxxxxx MP
House of Commons
London SW1A 0AA
The current Local Plan for Guildford which covers the years 2015 – 2034 was adopted in April 2019 and set a housing target of 562 dwellings per annum. When it was adopted local residents had two major concerns (1) that the housing target was inflated well above the demographically led demand and (2) that the supply of development land far exceeded the housing target resulting in the release of 1200 hectares from the green belt. Despite considerable opposition at the time, the Local Plan was forced through one week before the Local Elections.
According to figures from the ONS issued on the 24th May 2018, if you just take natural change (births and deaths) and net internal migration (that is movement within the UK), the population of Guildford was actually projected to decline over the life of the plan. Apparently the entire projected increase in the population of Guildford was due to net international migration of which, according to the ONS, the majority were overseas students attending the University of Surrey.
In my opinion, the West Surrey SHMA, used as evidence to generate the housing target, was unsound in two significant ways because (1) overseas students, who are only here on a temporary basis to study, are included in statistics for international migration which has an inflationary effect on population projections for Guildford and (2) the term time address of students is taken as their permanent place of residence making the population of Guildford appear to have a very high proportion of people in the 18-24 year age bracket who are assumed to have a high probability of forming new households and settling in Guildford when in reality they move away from Guildford on completion of their studies.
To make matters worse, the total site allocations in the Local Plan, which include 1200 hectares of the Green Belt, have the potential to deliver 14,602 homes over the life of the plan, which contrasts markedly with the total housing requirement of 10,678 homes, representing a very substantial oversupply of land for development and questions whether there are sufficient, or indeed any, “exceptional circumstances” to justify the release of so much land from the green belt.
In 2020 it became apparent that residents in Coventry had similar concerns about inflated housing targets leading to the very significant loss of green belt in Warwickshire. A complaint was made to the Office for Statistical Regulation leading to a report that concluded that “there were some strong concerns expressed about the potential bias in the emigration data for some groups, such as international students, that are hard to count” and that “fixes have not done enough to address the overestimation of these groups in some areas. This has led to an over reliance on insufficiently robust data to inform local planning decisions such as the need to build additional schools and housing”, and a letter from Ed Humpherson Director-General for Regulation at the OSR to Guildford Council which stated 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”.
G L Hearn, the consultants employed by Guildford Council to prepare the Strategic Housing Market Assessment (SHMA), based their housing forecasts on the 2014 Sub National Population Projections. These projections forecast a population for Guildford of 154,000 by the year 2021. According to the ONS Census 2021 released on the 28th June, the actual population for Guildford in 2021 was in fact 143,600 which is significantly less than that which was originally forecast and on which the housing target of 562 per annum was based and demonstrates that the ONS methodology must be deficient in some respects.
Local residents are concerned that large areas of the green belt around Guildford have been allocated for development based on inaccurate and misleading statistics. We have brought this to the attention of our Local Council who are reluctant to carry out a review of the Local Plan because they are concerned that the use of the Standard Method for Assessing Housing Need would result in an even higher housing target.
However 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 NPPF Paragraph: 015 Reference ID: 2a-015-20190220).
We are therefore asking you to use your influence to encourage Guildford Borough Council to undertake a review the Local Plan based on the findings of the ONS 2021 Census and the most recent 2018 Based Household Projections for Guildford which estimate a requirement for only 121 dwellings per annum over the life of the Plan. We believe that the Local Plan for Guildford is outdated and no longer fit for purpose and should be reviewed.
Bearing in mind that, according to the Royal Institute of Chartered Surveyors, about 50% of the whole life carbon emissions of a typical domestic dwelling are expended simply in the manufacture of the materials used in its construction like cement, brickwork and steel, and that, according to the latest research, meadows and fields are just as effective a carbon sink as forests and woodland, the very act of building on the green belt does more harm than good - and there is no justification for it – quite the reverse. With the very real threat of global warming, we should be doing our utmost to preserve the environment and protect potential carbon sinks.
The conservatives cannot keep making public statements of support for the greenbelt and then not acting to do so.
Niels Laub Dip Arch R I B A