Inspector backs Guildford's use of 2016-based projections to cut local plan housing target

A planning inspector has approved changes to a Surrey council's local plan after accepting that the latest 2016-based household projections justified a reduction in the local authority's housing target by more than 10 per cent and the removal of four green belt sites from the document.

Guildford: An inspector has concluded his examination of the council's local plan. Image: Flickr / Clive G
Guildford: An inspector has concluded his examination of the council's local plan. Image: Flickr / Clive G

Submitted for examination in December 2017, Guildford Borough Council's draft local plan initially proposed an annual housing target of 654.

In March 2018, inspector Jonathan Bore wrote to the council to say he was "very concerned" about proposed housing delivery in the early years of the plan and said the plan "makes no allowance for meeting unmet housing need" in the housing market area.

The remarks prompted Guildford Council leader Paul Spooner to respond the following month, advising said the council saw no need to increase its objectively assessed housing need and would decline to meet any additional housing overspill from neighbouring Woking.

Nevertheless, Bore went on to advise in June 2018 that the plan should include a target of 671 homes a year, comprising the objectively assessed annual need of 630 homes a year in Guildford plus an unmet need figure of 41 homes per year from Woking, which the inspector said was "not much in excess of the submitted plan’s figure".

In August 2018, Guildford appeared to row back on its earlier stance and proposed main modifications to the plan which included the allocation of four new green belt sites and the delivery of 550 additional homes in the first five years of the plan period.

However, in October, the council issued another statement calling for a reduction in the annual housing target to 562 in light of the Office for National Statistics' 2016-based household projections, which were 24 per cent lower than previous estimates. 

Writing to the inspector, the council advised it would "not be recommending adoption of the new plan with proposed main modifications". Bore replied to say he would give the council’s housing calculations using the new ONS figures "careful thought". 

In February this year, Guildford announced the inspector had verbally endorsed its proposed approach at the end of public hearings held as part of the plan’s examination.

Now, presenting his final report on the draft local plan, Bore said that he accepted that the authority's proposed target of delivering 562 homes a year, or 10,678 homes over the plan period to 2034, "reflects the latest evidence and is based on sound analysis".

Last month, the government confirmed in new Planning Practice Guidance that councils should use the earlier 2014-based household projections when calculating housing need using the new standard method, not last autumn's lower 2016-based projections.

However, Bore points out that the Guildford plan, because it was submitted for examination last year, is subject to the policies of the 2012 NPPF and therefore its housing targets do not have to comply with the standard method.

His report states: "As a transitional plan being examined against the 2012 NPPF, the housing requirement in the Guildford Borough Local Plan is not derived from the standard method.

"Moreover, the plan’s housing requirement ... is based on a methodology that makes a range of significant adjustments to allow for factors such as household formation rates, jobs-related growth and other local issues which are discussed in more detail below.

"As such, the council’s latest housing figure ... is an up to date assessment of housing need based on several inputs, in accordance with the policy framework appropriate for transitional plans. In consequence it does not conflict with the letter or the spirit of the revised NPPF."

Explaining his decision on the four green belt site allocations, Bore said: "The exceptional circumstances for altering green belt boundaries to accommodate them no longer exist."

Bore's report said the plan would be sound subjet to a series of modifications being included.

A full council meeting has been scheduled for 25 April when members will decide whether to adopt the plan.


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