Green Belt / Local Plan Latest : Two Professors, No Report

green info

It is always a pleasure to hear from ‘The Prof’ and here he tells us  :


I just read your ‘A Fear of Green’  piece on Wirral Green Space Alliance attempts to get information out of the council on green belt activities. One of the requests asked for details of the work commissioned by the council from Liverpool University on Wirral housing needs under the local plan. The council answer was that the work is ‘not yet completed’. You might therefore be interested in the reply (dated 08.05.19) of professor Alex Lord of the Dept. of Planning to my own inquiry on this work. As he says clearly, the work was completed and sent to Wirral council ‘several weeks ago’.

This is work we paid for and it should be available for public scrutiny. 

                                                                                                                                                            The Prof. 

And indeed here is the aforementioned response from Professor Alexander Lord (how’s that for a name btw?) :

Dear Professor Gregg,

Thanks for your e-mail.  We (a small group from the University of Liverpool and a colleague from Manchester) were commissioned to carry out a small piece of work for Wirral Metropolitan Borough Council.  One aspect of this related to projected household formation.  As part of this process we took into account the submission that I understand you made along with ONS measures.  Our work was submitted to the local authority several weeks ago now.  As this was a commissioned piece, the details of the report are the property of the local authority and so I am sorry to say that I have been advised that I am not permitted to share it.

I know from discussions with the local authority that they take public consultation very seriously.  I am sure that they would welcome further engagement with you on this question and in relation to the development of the local plan more generally.

Best Wishes,


Professor Alexander Lord

Lever Chair of Town and Regional Planning

Department of Geography and Planning

School of Environmental Sciences

University of Liverpool


L69 7ZT

We’ll leave that there for your delectation.

But before we go a couple of comments from us. First, Prof Lord is the Lever Chair of Town and Regional Planning at the University of Liverpool . So , should any conflicts be declared here? And secondly he appears to have a particularly keen sense of humour. Apparently he thinks Wirral Council take ‘public consultation very seriously’. Might we suggest (like ‘The Prof’) it is as seriously as sharing information which the council tax payers of Wirral have paid for and yet somehow aren’t allowed to read?…

Green confidential

Death By Planning

As the Local Plan/Green Belt debacle continues to be played out in the local media. The latest instalment being the local Labour group advertisement feature wrapped around the Wirral Globe which has been deconstructed on Defend Wirral’s Green Spaces Facebook page.

However today we bring you ‘The Prof’s learned exploration as to why the issues surrounding the Local Plan and the Green Belt are so important.

Yes, it is lengthy but we think you owe it to you and you family to take some time out this Bank Holiday weekend to become better informed about the potential life threatening consequences of not protecting Wirral’s Green Belt.


1. Introduction

The scoping sustainability appraisal document on air quality and health gives a very limited, misleading and complacent assessment of issues in these areas which should in practice a have a significant impact on consideration of development options under the local plan.

A detailed analysis of the health impact of house building on the Green Belt parcels identified for potential release in the Local Plan adjacent to the M53 is in preparation. Specifically it considers the GB parcels east (downwind) of the M53 from Storeton, south past Junction 4, to Raby Mere and those GB parcels near Junction 5 at Eastham. The serious negative effects of air pollution on any future residents and the current residents downwind of the M53 are examined. This note is to give the council early warning, for the record, of the negative health implications of building in these areas and an outline of the formal objections which will therefore be raised if these parcels are proposed for release.

2. Scoping Report Context

The Scoping Report published by Wirral Council discusses ‘Air Quality’ in a very limited way. It does however note the NPPF imperatives such as

‘New and existing developments should be prevented from contributing to [residents], being put at unacceptable risk from, or being adversely affected by, unacceptable levels of air pollution.’

Contrary to the complacent scoping report we will demonstrate from international and national studies and by analysing Wirral geographical health data, that building in the GB parcels identified will put residents at significant risk and cause real, unacceptable health deficits including reduced life expectancy. As traffic increases in coming years, the health impacts of pollutants such as PMs on Wirral will definitely increase, even if the unrealistic government aspirations for replacing diesel vehicles are met.

The scoping report mentions only one pollutant in detail, NO2, nitrogen dioxide. NO2 is allegedly monitored at 31 passive sites and levels are supposedly falling ‘gradually’. Particulate matter, now recognised as extremely dangerous, is mentioned in passing. It is monitored at only one automatic site on Wirral at Tranmere. International air quality standards, which are continually tightening, and the views, for example of the World Health Organisation on health damage, are not explored. We will do so below. In fact the serious health impacts of air pollution on Wirral are not discussed in the ‘Air Quality’ section nor the ‘Health’ section of the scoping report. Given that air pollution is now considered to be ‘the greatest environmental risk to public health’ in the UK (1, 2) this is concerning. We will look at evidence from the literature causally linking PM and NO2 levels to premature mortality, lower life expectancy, COPD, lung cancer, asthma, diabetes, dementia, stroke, heart attack, development deficits in children’s lungs and low birth weight. We will also present in summary, direct evidence of significant correlations between these diseases and PM levels across Wirral which are fully consistent with that extensive literature.


The 16 Green Belt Parcels Proposed for Release in the Local Plan Adjacent to the M53 at Storeton-Clatterbridge-Poulton Lancelyn

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The 11 Green Belt Parcels Adjacent to the M53 between Raby Mere and Eastham

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3. National & International Health Impact Evidence

A good starting source for reviewing the evidence is reference 3: the joint report on Air Quality from DEFRA – Public Health England – Local Government Association in 2017. The report concentrates on PMs and NO2. PM10 includes all particles smaller in diameter than 10 microns. PM2.5 includes all particles smaller than 2.5 microns. PM10 therefore includes the PM2.5 and PM0.1 fractions. Nationally the ratio of PM2.5 to PM10 released into the air is 0.75. Concentration ratios vary depending on local conditions. The smaller particles are considered most dangerous since they can be inhaled deep into the lungs and even pass directly into the blood stream. PMs are known to be carriers for carcinogenic materials and are now classed as carcinogenic agents.

The literature on health impacts of air pollution is now vast and still accelerating in scope. The health implications for the UK are well described in ‘Health Matters: air pollution’ published in 2018, by Public Health England (4). Locally we also have an excellent report by the Wirral Intelligence Service (1). WBC cannot claim that there is a dearth of information on these matters. The PHE report concludes that

‘long term exposure to man-made air pollution in the UK has an annual effect equivalent to 28,000 to 36,000 deaths. Over 18 years a 1 microgram / m cubed reduction in fine PM air pollution could prevent 50,900 cases of CHD; 16,500 strokes; 9,300 cases of chronic asthma; 4,200 lung cancers.’


This gives an indication of the human health value of reducing PM levels since the gains continue to zero levels (3). We will see that Wirral PM levels vary from ~10 to ~16 micrograms / m cubed.

PHE notes that the cumulative disease burden to 2035 associated with PMs includes 348,878 CHD cases; 246,916 COPD cases; 273,767 diabetes cases; 173,886 low birth weight children; 133,356 asthma cases; 106,331 strokes; 44,290 lung cancers. Similar analysis for NO2 exposure yields: 573,363 cases of diabetes; 335,491 asthma cases; 102,545 low birth weight children; 86,617 cases of dementia (4).

The international evidence of harm is overwhelming (8, 9). In many large epidemiological studies air pollution impact has been quantified while taking into account potential co- variables such as lifestyle (smoking, alcohol, exercise), income / education, and measures of socio-demographic deprivation (5). In many studies gradient effects have also been identified. That is, disease prevalence has been shown to fall away as a function of distance from pollution sources such as major roads (6, 7, 23). There have been very large, both cross-sectional and longitudinal health studies (6 provides a 78 page review of the health evidence). Such studies constitute a smoking gun and settle the issue of causation.

PHE notes that the Environment Audit Committee of the HOC found evidence that the cost of these health impacts was likely to exceed £8 – £20 billion.

Since the Clean Air Act in 1956 many sources of PMs have been eliminated but now levels have almost stabilised. The easy sources have been tackled (see Figure A). Traffic sources are resistant to reduction as number of vehicles and traffic miles continue to increase. The government claims that eliminating diesel and / or petrol cars will solve the air pollution problem (10). This is untrue. Their own data shows that ~80% of PMs do not come from car exhausts but from bitumen, rubber, organic and other waste matter released by vehicle tyres from road surfaces. ‘Electric’ cars and trucks will still cause high levels of PMs. Eliminating diesel cars will however reduce NOx by ~40% but published diesel vehicle reduction targets to 2040 in the UK and Europe are widely considered to be wildly optimistic (11). Official data for sales growth in Alternative Fuel Vehicles and conventional petrol / diesel vehicles suggest AFVs will be only ~8.3% of new car sales by 2030 versus the government’s ‘ambition’ and ‘illustrative’, 30% to 70%. Note that Figure A also shows that since ~2005 PM pollution from industrial and commercial activities has sharply increased again.

Recommended maximum allowable levels of the various pollutants continue to fall as health evidence emerges. The World Health Organisation published a review of 2,200 studies in 2013 (6) concluding that

‘Annual PM concentrations are associated with all-cause mortality to a high degree of [statistical] confidence. There is no evidence of a safe level of exposure to PM or to a threshold below which no adverse health effects occur.’

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The Air Quality report authors comment that

‘Negative health impacts have been found well below current EU & UK limits.’

Local authorities such as WBC cannot simply say, as they do, we meet the EU or UK legal limits so no further action is needed. The WHO will steadily reduce PM limits in future years

which are currently set at 10 micrograms / metre cubed average levels. In the ‘Clean Growth Strategy 2018’ (12) the government promises to

‘reduce PM levels in order to halve the number of people living in locations where concentrations of PM are above 10 micrograms / meter cubed by 2025.’

Much of the Wirral is above this limit currently and as vehicle numbers and miles travelled increase in the medium term PM levels will increase, not decrease (32). There was a small reduction in vehicle numbers growth during ‘austerity’ for a few years but growth has recovered. Traffic volume flow between J4 and J5 on the M53 is given in Figure B. From 2000 to 2016 traffic increased by 33.5% or 2.1% per annum on average. However before and after the ‘economic shock’ period, during which growth halted, traffic growth rate was ~2.9% per annum. We will show that building in the M53 eastern corridor GB parcels will expose many areas to PM levels well above 10 micrograms / m cubed and this will increase over time.

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The government promises new powers for targeted local action.

This should include not allowing building new housing in Green Belt areas and green spaces adjacent to identified PM and NO2 hotspots by major roads and motorways.

There is extensive literature evidence that significant health deficits are found at distances from motorways of 500 ms and more depending on the air pollutant and the diseases considered (6,7). If local authorities ignore the clear health impact evidence in the scientific literature and allow unnecessary house building in high risk areas they will be guilty of a failure in their duty of care to residents. In the case of Wirral, for the sake of certainty, we now present local evidence that air pollution is ubiquitous and that the prevalence of several diseases is strongly correlated with local PM air pollution levels.


4. Wirral Evidence on Pollution Levels

NO2 and PM measurements at many localities around the country have been used to calibrate government air pollution models by locality (13). These models take into account point (e.g. industrial) and line (road) sources of pollutants and topography. In the case of roads the key data are traffic flow volumes and traffic mix. The models also take into account prevailing wind directions and use well established spacial diffusion models to predict average concentration levels in one kilometre squares as defined on standard OS maps. This averaging means that pollution levels close to the source may be even higher because of gradient effects. Nevertheless the models give a reliable guide to pollution spread and general levels.

The Wirral pollution maps are given in Figure 1 for nitrogen dioxide and particulate matter. The patterns are similar in that the highest pollution levels occur east of the M53 (14). This reflects degree of urbanisation and in particular Birkenhead but also major road distribution. The high pollution levels along the length of the A41 near the Mersey are clear as are the high levels adjacent to the M53 from Eastham to Moreton. In relation to the proposed local plan GB release parcels note the very high PM levels near M53 junction 5 (Eastham) and junction 4 (Clatterbridge). (Note: Junction 2 and the Moreton spur road is also a hotspot).

It is therefore puzzling that the Scoping Report tells us (2.6) that :

‘No hotspots are associated with the Boroughs motorway junctions, nor the toll point of the Kingsway Tunnel, suggesting that the presence of significant strategic road network infrastructure does not currently give rise to notable air quality concerns.’

This is simply untrue. In fact the official air quality models show us pollution levels near the mentioned junctions as high as in the worst polluted areas of Birkenhead. An increase in traffic flows on roads feeding the junctions such as J4, resulting from large numbers of new houses on the GB parcels east of the M53 from Storeton south to Poulton Lancelyn would create a high air pollution nightmare. The roads are already congested at peak times twice a day and are generally very busy. J4 is also already a notorious traffic accident hotspot.

5. Preliminary Wirral Evidence for Air Pollution Health Impacts

Detailed analyses are currently underway exploring the links between the prevalence of several important disease classes across the Wirral and the levels of pollutants such as PMs and NOx . Disease data is available from several official sources at the level of political wards and constituencies. Pollutant exposure levels by ward are calculated from the models of Figure 1 by taking all the kilometre squares in a ward and the location of housing and calculating ward exposure averages. This procedure gives a score in the range of 1 to 4 for pollutant level. Disease prevalence is then plotted against pollution level and simple linear models fitted. In all cases significant correlations were found. These include:

Wirral Life Expectancy by ward versus PM10 (Figure 2) Wirral Mortality Rates (DSRs) versus PM10 (Figure 3)

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Wirral Prevalence of Constrictive – Obstructive Pulmonary Disease versus PM10 (Figure 4). COPD Prevalence versus Indices of Multiple Deprivation (IMD) for closely similar PM10 level wards (Figure 4A)

Wirral Lung Cancer Mortality Rates versus PM10 (Figure 5). Lung cancer versus IMD for closely similar PM10 level wards (Figure 5 A)

Wirral Low Birth Weight Rates versus PM10 (Figure 6)

Analyses are also underway for dementia, diabetes, asthma, Coronary Heart Disease and stroke prevalence. Preliminary work also shows clear correlations with PMs and NO2.

We report the findings below for a selection of diseases. The ongoing analyses are currently addressing the issue of possible co-variables. Many published studies have already dealt with this issue and showed that even after lifestyle (smoking / alcohol / exercise) and so- called deprivation measures (income / service access) are included air pollution impacts are clearly significant (5, 6, 23). The intention here is to demonstrate this with Wirral health data. On the Wirral we can note immediately that smoking prevalence and intensity has been falling for many years yet diseases commonly associated with smoking in the public mind are rising. What is rising on Wirral are vehicle numbers and total miles travelled. We will also show later that constrictive obstructive lung disease (COPD) prevalence, while strongly correlated with PM level, is only weakly correlated with the Wirral ward level Index of Multiple Deprivation (IMD). The same is true for prevalence of low birth weight children.

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It appears that the official habit of simply blaming disease on bad ‘lifestyle choices’ among the poor underclass may be overstated, or indeed a case of ‘blaming the victim’. High air pollution levels for example generally correlate with poor urban housing locations. As more major international multi-factor studies emerge, blaming the victims is becoming harder. To a first approximation, in a country like Britain, we are all air pollution victims now. Similar analyses examining other variables are being prepared for the other disease classes and will be published as soon as possible.


The intention of the detailed analyses will be to quantify the actual disease loading due to current variations of air pollution across the Wirral and to predict future loadings as traffic increases in general and in proposed areas of green belt development. Such increases impact both new residents in areas adjacent to the M53 but also current downwind residents. There is extensive evidence, accepted by government, and local authorities, that open fields, hedgerows and trees near motorways and major roads significantly reduce the levels of some air pollutants (15, 16). It is notable that WBC itself is promoting the growing of hedges for this purpose to protect schools (17) and that the Scoping Report talks of pollution mitigation ‘through green infrastructure provision’ (2.10).

On this ‘official’ logic it is surely wise to preserve not destroy, Wirral green spaces and existing green belt buffers near major roads and motorways.

Removing these green ‘shelterbelts’ by building on them reduces the protection of nearby, current residents and exposes new housing residents to high pollution levels (as is the case in all the GB parcels being considered for release east of the M53).

For now we will simply note some basic disease / air pollution correlations. Figure 2 shows Wirral life expectancy versus ward average PM10 levels. There is a clear correlation here with life expectancy at PM level 1 being around 87 years and PM level 4 around 75 years. This should not be surprising since Reference 1 tells us that : ‘reducing PM by 10 micrograms / m cubed would extend lifespan by three times more than eliminating passive smoking’.

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The Air Quality Strategy for the UK in 2007 noted : ‘PM in the UK would be expected to reduce life expectancy averaged over the whole population by 7 – 8 months’. DEFRA tells us NO2 exposure alone ‘reduces UK life expectancy on average by ~5 months’. But of course excess deaths are concentrated in urban area sub-populations. People here are losing years of life.

In the worst cases the WHO note an average life deficit of ~ 20 months related to PMs.

Figure 3 shows Mortality, age standardised death rates, for the Wirral versus PMs and a linear best fit model (h1). The correlation coefficient is quite high at 0.69. We can say that 48%, roughly half the variability in Wirral mortality rate, is accounted for by PM level differences (while noting there may be several interacting variables in play here. See below).

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Now we examine briefly, particular diseases. Figure 4 shows a best fit linear relationship between constrictive –obstructive pulmonary disease prevalence and PM10 level by Wirral ward (h3). The correlation coefficient is moderately high at 0.73. Taken literally this would imply that 53% of the variation in COPD prevalence is explained by PM variation.

With this data we can make a rough check of the scale of impact on COPD of other possible ‘causative’ variables as we can identify several wards where PM levels are very similar (~3.2 to 3.3). The main official measure which purports to capture the level of deprivation in a population is the Index of Multiple Deprivation. This is a weighted sum of several inputs such as income, access to housing & services, education, health and crime exposure. Health includes ‘lifestyle’ items such as smoking and alcohol prevalence. We might therefore expect IMD to correlate with disease measures such as COPD. IMD is usually adduced to explain various diseases under the short hand terms, ‘poverty’ and ‘lifestyle choices’.

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In Figure 4 A we plot COPD versus IMD for wards with very similar PM levels. A linear fit gives a small positive relationship between COPD and IMD. The correlation coefficient is 0.11 so the slope is uncertain and IMD ‘explains’ very little COPD variation.

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This is notable since other data suggests a strong relationship between smoking prevalence and IMD on Wirral. The intercept implies that even at zero IMD, COPD would be ~2% for this

set of wards. All we can say at this stage is that COPD is strongly related to PM levels but that other variables may also be in play.

Figure 5 plots lung cancer mortality rates (SMRs) versus PM10 levels across Wirral (h4). The scatter band is wide but a significant relationship emerges from a linear best fit. The correlation coefficient is moderate at 0.63. Taken at face value PM level accounts for ~40% of the variation in lung cancer. This is interesting since lung cancer is the canonical disease linked with smoking and high smoking prevalence these days correlates with low income. IMD should capture the low income effect and the direct ‘health’ deprivation / lifestyle effect. We noted earlier a sub-set of wards with very similar PM levels but a scatter of COPD levels. In Figure 5 A we plot lung cancer mortality versus IMD for these wards. There is a positive correlation and the correlation coefficient is again modest at 0.6.

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This implies that IMD ‘explains’ ~ 36% of the variation in lung cancer mortality in this data. We can tentatively conclude that PM air pollution and smoking variation contribute about the same amount to lung cancer mortality locally. Given the strenuous legal and social efforts to reduce smoking dependence over recent decades it seems air pollution deserves the same state attention. We noted that smoking prevalence and intensity is falling on Wirral and across the UK. However fossil fuel vehicle numbers and vehicle miles travelled are increasing and will continue to do so for decades. The proportion of disease like lung cancer due to air pollutants such as PMs will increase over time. Combating this will be very difficult for future governments in existing built up areas. However two actions would be both easy to implement and totally effective :

1. Do not allow building of new housing, whether luxury or social homes, next to motorways and do not destroy green spaces and green belt protective zones.


2. If a council chooses to allow such building it should be required by law to WARN prospective buyers and existing residents downwind of the health dangers involved.

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The government tells us they ‘aspire’ to build 300,000 new homes each year with many on green belt land. By following the above rules hundreds of thousands of families per annum can be protected from dangerous exposure to air pollutants. The real ‘need’ numbers are probably less than 160,000 houses per annum but there is still a huge accessible, potential saving in human distress, national disease burden and cost to the NHS.

The diseases examined so far express themselves mainly in adults. In fact the coronary heart disease, strokes and dementia impacts of PMs largely strike older people. Living in a polluted area can increase dementia risk by up to 40% (23). But we should be equally concerned about the health impacts of air pollution on children and the developing foetus.

There is very worrying evidence that living in high PM areas not only causes acute and chronic asthma but stunts lung development in children permanently (21). ‘Pronounced deficits’ in lung function has been found in 18 year olds who grew up within 500 ms of a motorway. Reference 21 notes

‘the new study found reduced lung growth in [young] people who lived by motorways in otherwise open spaces with relatively clean air.’

It should be noted that this major pioneering study took place in Southern California and only 3.9% of traffic there is diesel powered. In the UK the proportion is 45.9%. Even if the UK government clean air strategy succeeded it would not remove the problem (10, 11).

California state law now prohibits new schools being sited within 500 ft of a highway.

These lung stunting results have recently been confirmed in the UK (22). Of even greater concern is the recent work showing directly that fine PMs can penetrate the placenta of pregnant women (19). Fine PMs are carriers for a range of carcinogenic compounds. What is certain is that the literature proves a strong correlation between low birth weight in babies and PM levels in the air (18). Low birth weight correlates significantly with later childhood problems including cognitive deficits (20). These results should be viewed with alarm by all current and prospective parents and cause UK politicians to put immediate, severe constraints on house or school building near motorways and major roads.

It is of some interest then to see if LBW is connected to air pollution on Wirral. Figure 6 plots low birth weight prevalence for Wirral wards versus PM levels (h5). The correlation is strong at 0.71. This implies that ~50% of LBW variation on Wirral is explained by PM levels. There is also a suggestion in the data that the negative effect of PM accelerates at higher PM levels. We may safely infer that the associated physical and cognitive deficits in children living near major roads and motorways, demonstrated conclusively in national and international pollution-health studies, also apply to Wirral.

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6. Wirral Local Plan : Planning Implications of the Health Deficit Evidence

We have examined a summary of the national and international evidence for the many negative impacts on new and existing residents of building housing estates in the vicinity of motorways and major roads and the positive health value of preserving green buffer zones and green spaces in general. The problem is recognised by government to the extent that Highways England is experimenting with giant poly-tunnels to cover motorways (24).

We also demonstrated by statistical analysis of Wirral health and pollution data, very similar and significant negative health impacts for several disease classes. The evidence for impacts on vulnerable groups such as pregnant women, children and older people is particularly concerning.

We also noted possibly two dozen Green Belt Parcels listed in the initial Local Plan for consideration for release from the green belt for major housing developments, lying adjacent to the M53 motorway. The parcels east of the M53 from Storeton, through Brakenwood (junction 4) and Poulton to Raby Mere and the parcels adjacent to junction 5 at Eastham, are downwind from the motorway and particularly vulnerable to additional pollution impacts. The official government air quality models show levels implying serious health effects.

All this evidence bears no relation to the Wirral Council Sustainability Assessment, Scoping Report in which all is apparently well on the Wirral. To be fair this simply reflects recent WBC documents on air quality (25). WBC sleeps on, apparently unperturbed by wider responses to this health crisis. Curiously this includes the new Air Quality Task Force, just set up for the Liverpool City Region Combined Authority of which Wirral is a part (26). Mayor Rotherham seems clear enough :

‘Poor air quality is a national public health crisis which is shortening the lives of people across our city region…’

WBC should also note the European Court of Justice action which threatens to impose huge fines on six nations including the UK. The northwest is one danger area identified (27). We can also draw WBC attention to the latest NICE Guidance recommendations on local housing and facilities planning (28) in relation to the M53 green belt parcels:

‘When Plan Making consider

  •   Minimising the exposure of vulnerable groups to air pollution by not siting buildings (such as schools, nurseries and care homes) in areas where pollution levels will be high
  •   Siting living accommodations away from roadsides
  •   Avoiding the creation of street and building configurations that encourage pollution tobuild up where people spend time
  •   Including landscape features such as trees and vegetation in open spaces or as‘green’ walls…
  •   Siting and designing new facilities and new estates to reduce the need for motorisedtravel.WBC should also consult ‘Housing & Economic Land Availability Assessment’ (29) on the issue of the ‘suitability of sites and broad locations for development’ and consider :
  •   Physical limitations or problems such as access, ground conditions, flood risk, hazardous risks and pollution or contamination.
  •   Environmental / amenity impacts experienced by would be occupiers and neighbouring areas.
  •   Potential impacts including the effects upon landscape features, nature and heritage conservation.

The extensive evidence presented above indicates the need for an independent, formal evaluation of the air quality health impact of the proposed developments on Wirral. The Institute of Air Quality Management & Environmental Protection’ provides detailed instructions for LAs (30) on what should be taken into account including

  •   The background and future baseline air quality
  •   The presence of a heavily trafficked road, with emissions that could give rise tosufficiently high concentrations of pollutants that would cause unacceptably high exposure for users of the new development.The author is working on these issues. It is also clear that it is necessary to investigate the exposure of new residents of a development to existing pollution sources but also to assess the impact of the new development on existing residents. We have shown that housing east of the M53 would both expose new residents to unacceptable air pollution but also remove the green buffer zone currently giving some protection to existing residents downwind.The new NPPF / guidance (31) is also very clear:
    ‘The planning system should contribute to and enhance the natural and local environment.’ This is to be achieved by:

    ‘preventing both new and existing development from contributing to, or being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability.’

    ‘Opportunities to improve air quality or mitigate impacts should be identified such as…green infrastructure provision and enhancement. So far as is possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. ’

    The Wirral Local Plan must consider properly the health and environment impacts of building on the 50 sites earmarked for release from the Green Belt in the draft Local Plan.

    Specifically, on the evidence, building on the GB parcels we have identified east of the M53 will not provide opportunities to ‘improve air quality’ for new or existing residents nor ‘mitigate impacts’ nor ‘enhance green infrastructure’.

    It will definitely kill people.

    We note from WBC Air Quality documents (25) that

    ‘By being involved in conceptual stages of local planning policy and proposed development before formal planning applications are made, Environmental Health can help scrutinise initial plans…’

    ‘We want all of our residents to have a good quality of life in clean and safe environments.’

    ‘To use the planning system, in accordance with guidance, to effectively promote air quality.’

The latter statement is a ‘key priority’ for the coming year. The current creation of the Local Plan provides a wonderful opportunity for WBC to deliver on all this positive rhetoric and protect current and future Wirral residents. Let us hope that these statements are true. Alas, the report concludes with

‘The principle challenges and barriers to achieving the above mentioned air quality priorities will be maximising the opportunities of the resources we have to maximise influence on air quality in the Borough.’

The author would welcome a coherent interpretation of this.

Professor D P Gregg (retired) Poulton Lancelyn April 2019

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Message from Wirral Green Space Alliance : Extraordinary Wirral Council Meeting 25th February


Please Help save Green Belt … Give One Hour
On Monday, February 25th, there will be an Extraordinary Council
Meeting in Wallasey Town Hall. It’s a FULL council meeting, to discuss and
vote upon threatened development in Wirral’s beautiful Green Belt.
WE URGE EVERY resident caring about the environment and their Green Belt
to attend this meeting from 5pm, to show opposition to unnecessary Council Plans to
release Green Belt for Development – of an unwanted Golf Resort and the wrong
number and type of Housing, built in the wrong places – in beautiful Green Belt
rather than areas requiring rejuvenation, being available and more suitable.
WE URGE EVERY Wirral resident to attend this meeting – it will affect YOU.
WE are: Wirral Green Space Alliance (WGSA), an alliance of 20 Wirral community and environmental groups – see list at end -who came together to fight the threat posed by the Group controlling the Council,arguing for a different, feasible and legal approach having shown that:
There IS another way.
Government is NOT “forcing” the Council to build a huge number of homes –
But Government does insist ALL Councils work out their own Local Need, and
then compare their own assessment of ‘Housing Need’ with that derived from the
‘Standard Formula’, citing any ‘exceptional circumstances’. Other Councils have
succeeded but Wirral won’t try, seeking higher income from Green Belt Housing.
In a recent letter to the Council, James Brokenshire (Secretary of State) also highlighted:

Wirral is one of just 11 councils (out of 338) to be in breach of the Act;
Wirral has “consistently failed” to meet key milestones on at least six occasions;
Wirral is not an area where there is high housing pressure; and
Wirral has made the least progress recently, of any council, in adopting a ‘Local Plan’.

Yet Wirral seems determined, despite recent warm words, to drive forward its policy, andhas appointed the country’s top property Barrister at £135,000 initially and Liverpool
University to discredit the Alliance’s alternative approach which, under ANY scenario, shows that releasing Green Belt is unnecessary. Clearly, the Council think their own Case is so weak as to need such an extreme and expensive defence.
But, we are unlikely to change the Council’s current approach without wider support,
starting with a peaceful show of wishes and determination by people standing together in significant number outside Wallasey Town Hall from 5pm on Monday, 25th February for just one hour whilst the Councillors assemble for this significant Meeting.
Such a peaceful show of ‘People Power’ was highly successful when the same Admin-
istration wished to close most of our local Libraries; and it might just convince enough of the ruling Party’s Councillors to vote against Green Belt release – all other Parties’ Councillors are committed to oppose the release and development of Wirral’s Green Belt.
Please don’t leave it to others, as they may be leaving it to you !!
There is ample car parking in the vicinity of the Town Hall.

For further information about this event or the non-political ‘Alliance’ of Groups working hard together to produce an alternative ‘Local Plan’ which doesn’t include loss of Wirral’s Green Belt, you are welcome to contact representatives of the Groups involved:

WGSA 20 current Member Groups:
The Wirral Society and CPRE (Campaign for the Protection of Rural England, Lancs)

Barnston Conservation Society

Caldy Society CAW (Conservation Areas Wirral)

Defend Wirral Green & Open Spaces (DWGOS)

Eastham Village Preservation Assoc.

Frankby Conservation Assoc. Greasby Community Assoc.

Heswall Society

Irby, Thurstaston & Pensby Amenity Society (ITPAS)

Mountwood & Bebington Assoc.

Saughall Massie Village Conservation Area Soc.

Stop Hoylake Golf Resort Action Group (SHGRAG) Storeton Residents Assoc.

Thornton Hough Community Trust

Wirral Barn Owl Trust

Wirral Footpaths and Open Spaces Preservation Society

Wirral Ramblers

Graham Stevens (Statistician)

Prof. David Gregg (Statistician and Modeller)

Please help us with this next step and copy in your own Contacts.
Many thanks in anticipation.

A Brokenshire System for Wirral’s Green Belt

screen shot 2019-01-28 at 22.48.30

The above ‘leaked’ letter above sent to Wirral Council Conservative Group leader Ian Lewis by James Brokenshire MP,  the Secretary of State for Housing , Communities and Local Government is concerned with the local political debate about how housing need figures are calculated.

As this debate is particularly pertinent to Wirral’s Green Belt issues we thought we’d call upon ‘The Prof’ for comment. Regardless of where you stand on the housing needs debate it’s hard to disagree with his assessment of the people who are supposed to be running the show. Whisper it – they don’t know what they’re bloody doing!

Gents…an interesting letter. We have the usual disingenuous crap from government. The government housing need figure is the MINIMUM a council must meet or suffer a sanction even if the number is crazy. 

That is the situation we have here. Brokenshire mentions ‘availability’ 
but not the first key planning test, ‘suitability’. That is defined by several 
things including the need to protect current residents and the new development 
residents from air pollution effects.
As I told you many of the proposed local plan sites imply serious health risks if built on. Policy also requires the preservation of green belt / spaces except in exceptional circumstances. 
He also fails to mention the last test , ‘viability’. This means that the houses 
must be affordable to customers while giving the developers / builders an 
acceptable profit level. If sites are generally not ‘viable’ it makes no sense 
to sanction local councils where this occurs. We are in the hands of idiots
at central and local level. 
                                                                                   The Prof. 

This Blessed Plot


With rather beautiful synchronicity/serendipity we received the above poignant  Martin Parr-esque photograph from Wirral Leaks very own Weegee and a moving comment upon our Poppy Appeal story from ‘The Prof’ with which we would like to do a bit of a mash-up.

The photograph was once taken in front of yet another another piece of land on the corner of Church Road/Liscard Road in Wallasey that Wirral Council have just sold off to developers. Like our photographer and others we’re having trouble making sense of this frantic off-loading of random pieces of land to developers (be it brownfield or green belt). It seems to us that with Wirral having a declining population it is rapidly turning into buy-to-let heaven but , might we suggest, what better way is there to launder money – other than poor quality ‘care’ homes?

Which brings us on to ‘The Prof’s lament for lost land and a lost land …

Gentlemen this week has been a moving time for the many families whose loved ones fought in WW1 and WW2. My own father fought in Normandy and was severely wounded in the Netherlands. I felt surprisingly moved …to anger…that our council friends could not even manage to raise a poppy at the Town Hall. I looked up again the patriotic deathbed speech of  John of Gaunt in Richard the 2nd. Act 2, Scene 1. Every English school child knows  the famous beginning:

“This royal throne of kings, this sceptred isle…”

But few know of John Of Gaunt’s final,dying despair of his political masters:

‘This land of such dear souls, this dear, dear land
Dear for her reputation through the world,
Is now leased out, I die pronouncing it.
England bound in with the triumphant sea
Is now bound in with shame,
With inky blots and rotten parchment bonds:
That England that was want to conquer others,
Hath made a shameful conquest of itself.
Ah, would the scandal vanish with my life,
How happy then were my ensuing death!’
Why did our heroes die? To bend the knee to a Federalist Europe? To watch this ‘blessed plot’ , ‘this precious stone set in a silver sea’ sink beneath concrete and brick to satisfy the greed of land speculators and the stupidity of ministers and councillors , with no sense of heritage?
                                                                                    The Prof.

Wirral Council playing the ‘Numbers Game’ with the Green Belt

Green Numbers

The turf war political tit-for-tat over the Green Belt continues. The latest instalment comes  courtesy of Wirral Globe giving Conservative group leader Cllr Ian Lewis and then Deputy leader of Wirral Council , Cllr George Davies, a platform to repeat the same empty soundbites about who’s fault it is that Wirral’s Green Belt is under threat (although we did laugh at the suggestion that Cllr George Davies was ‘writing exclusively for The Globe’ .)  We’re sure we all know who the ghost writer was . We wonder whether this could be one of the ‘shadowy figures’ that  Cllr Lewis refers to in his conspiratorial opinion piece? Whatever neither of them seem able to definitively identify how many houses that Wirral needs over the coming years and where they should be built. Of course not having a ‘Local Plan’ in place doesn’t help does it?

Thankfully we have ‘The Prof’ on hand to dig a little deeper than the shallow political rhetoric . We’d like th


Gentlemen …for the (dated) record I have used the best ‘official’ ONS data I can find. I doubt we can do any better until the next census in 2021. The bottom line is I doubt if the population driven housing need will be more than 100 houses per annum or 1,500 over the plan period…a long way from 6,600 and 12,000. This means only a small fraction of the brown field sites already identified by the council and Peel will be needed. I want this latest analysis on the record since I have been told the council has hired someone from Liverpool University to ‘have a go’ at my work.

Should I be flattered do you think ? My contact now tells me that councillors are being told about the Liverpool University ‘critique’of my work. The contact was surprised that the council had not informed me of their intentions as a matter of courtesy. I agree.

Green Belt – Keep calm and listen to ‘The Prof’

Nobody knows

‘The Great Wirral Green Belt Debacle’ shows no sign of abating with Wirral Council and central government playing pass the parcel (of land) and continuing to dispute statistical information which is being used to influence Wirral’s future housing needs . Read more  here

It all gives the impression that politicians and public officials don’t know what they’re doing or that the continuing threat to Wirral’s Green Belt is borne of  ignorance of the facts or from questionable political/financial motives.

Thankfully we have ‘The Prof’ on hand to waft the smoke away from the mirrors . Here’s his take on the latest developments and a copy of a letter he’s written to James Brokenshire ,the  Secretary of State for Housing, Communities and Local Government.

This council never seems to learn. Having cried wolf on the green belt issue before it now does it again, helped along by our crazy central government. Let’s look at the facts, one more time, and leave out the Mickey Mouse stuff. The council says it has identified 91 sites which could host 2,400 houses. Peel Holdings have confirmed to the council that they CAN deliver a minimum of 2,900 houses in the local plan period and up to 6,450 houses subject to assistance with infrastructure costs. At the current rate of recovery (by the council themselves) 3,570 empty houses could be brought back into use over the plan period. This gives us 8,870 to 12,420 houses available on brown field sites. But the 803 houses per annum 2017 government target requires a total of 12,045 houses. So at best WE STILL need NO green belt land. At worst we need GB land for 3,175 houses. But the council plan aims to release 4,900 acres : sufficient at normal densities for 71,000 houses. So AT WORST we would need just 4.5% of the green belt the council wants to release for housing development to their speculator friends.That is 220 acres, NOT 4,900 acres. Yet again Wirral residents are being treated with contempt by this council. If the council decide to release the 50 sites in their green belt plan do not be fooled into thinking it has anything to do with central government. It is to do with council politics and greed. How much longer will Wirral voters put up  with this perfidious mob?

Dear Minister

I am a retired professor of mathematical modelling who has been looking
closely at the old and new housing needs methodology. The new methodology has the merit of simplicity and consistency which I understood was your aim.
I can though, understand your frustration that it gives far lower UK housing needs numbers than you hoped for, for policy reasons. However despite the lobbying you have no doubt received from disappointed developers and house builders the basic methodology may not be at fault. I trust the formal statistical review now underway will look closely at the ONS population projections used.
As you are aware something went badly awry between the 2001 and 2011 censuses resulting in large apparent population discontinuities in many locations.
The ‘corrections’ then made, left ‘fingerprints’ on the historical data later used to make the population projections for the standard method. In my own area of Merseyside this has caused havoc! The forecasts have been very unstable as we moved forward from 2012 to 2014 to 2016.
More importantly, to take my own Wirral LA as an example, the projected net migration into Wirral is at least 3X greater than actually experienced in the recent decade, based on several other ONS data sources and independent local time series such as voter registrations.
Since the Wirral internal, natural population is falling this ‘mythical’ migration greatly inflates the ONS population projections and consequently housing needs. Instead of 800 houses per annum (on the old methodology) and perhaps 440 (on the new) , a more likely number is in the range zero to 200 if we also consider your official, ONS low migration scenarios.
This excludes the need to replace local demolitions and the effects of changing housing mix needs. Now I am sure that in many other local authorities  across the country the census problem has worked in the opposite direction, underestimating actual population growth and transfers between authorities. In conclusion, the UK population projections are suspect and ideally should be checked, local authority by local authority, tedious though this is. We shall be doing this in detail for Wirral to provide statistical evidence for any future investigations by your housing inspectors into local planning intentions. I hope this note is of help.
Best wishes,
Professor D P Gregg (retired)

Green Belt : Do You Want Facts and Figures or Fake News ?

Whilst the Green Belt political panto ploughs on in the local papers , here at Wirral Leaks   we provide you with a special cut out and keep report from ‘The Prof’ which we think is the definitive word on the matter. There is a summary of his findings at the start. But for those who want to be better informed about the Green Belt debate there is a full analysis.


  • The council Green Belt ‘release plan’ covers ~8 square miles or 4,900 acres.
  • This land could support 71,000 homes (at typical NW density of 14.6 dw / acre).
  • But the government / council housing need forecast is for 12,000 houses.
  • So the GB land fraction required is only ~17% of the council ‘release plan’.
  • However based on ACTUAL population and household number changes in
    the last decade and allowing for lower economic growth post Brexit and a slowdown in UK life expectancy improvement, probable new housing need is 200 to 300 houses per annum NOT 800.
  • So the land required would be only ~6% of the GB ‘release plan’ in that case.
  • But the council says it has identified Brown Field sites for 2,400 houses and will build there first. If so the fraction of land required from the GB ‘release plan’ would be only ~3%
  • The council has deliberately exaggerated the ‘Green Belt Problem’ and caused great distress to many Wirral residents for purely political reasons. After the Green Belt review in December 2018 they will claim that they have ‘heroically’ saved most of the land on their GB ‘release plan’… land that was never needed in the first place.
  • Even so some sites listed will draw the short straw since building on Green Belt is more profitable than building on Brown Field sites for the developers. The council will gain from higher rates from Green Belt luxury homes. Very few ‘affordable houses’ will be built because of the ‘viability test’ loophole. The developers gain; the politicians gain; but what about the Wirral residents who elected them who are routinely treated with contempt ?


Wirral Housing Need Forecasts 2014 – 2032 

& Green Belt Land Requirements: Fake News

1 Summary
The government has told Wirral Council that they must build 800 homes per annum or 12,000 in total over the period 2014 to 2032. Despite having granted planning permission already for ~ 16,000 dwellings, mainly on brown field sites, the Council have decided to seek out landowners and developers ready to ‘release’ Green Belt land for housing development. This has led to 50 sites being identified (Figure 4). This land amounts to ~8 square miles of Wirral countryside. Both government and council have ignored the existing ~6,000 empty properties on the Wirral. The government and the ‘land bankers’ such as Peel Holdings have been blamed by the Council for this catastrophic situation. However the Council commissioned Housing Study of 2016 found a housing requirement of 835 to 1,235 units per annum. In fact the same complex methodology underlies both housing estimates. It is at heart still based on guesswork and produces a remarkably wide range of forecasts. The politicians can find almost any number that suits them politically. In the case of the Council this was a desire to promote their miraculous economic growth policies for Wirral.
Given the uncertainties a better approach is to consider actual recent and longer term population and household growth rates and growth rate ranges and base forecasts on these with possible adjustments for general economic growth prospects e.g Brexit effects. We do that below and find housing build rates of 200 to 300 per annum, not 800. At this level the amount of Green Belt needed (ignoring the brown belt land available) would be only ~6% of the land targeted by the Council for development release. At 800 homes per annum the fraction of Green Belt needed would only be ~17% of the Council plan. Wirral residents are being fed highly distressing fake news and alternative facts by the Council. We should all be asking why? Quo bono? Who benefits? It is certainly not Wirral residents.
2 The Wirral SHMA and Housing Needs Study 2016

This study was commissioned by Wirral Council and completed by the Nathan Litchfield Consultancy. It is 263 pages long. It uses approved data from government sources and approved analysis methods commonly used by other local authorities. It freely references work by other groups which is commendable. It fully reports its assumptions and considers over a dozen alternative scenarios. It is a comprehensive, workman-like job. Sadly government departments and councils do not always fully report or understand what their consultants tell them about the uncertainties in modelling and forecasting. Quite often the politician can take almost any number that suits him from such a report. Let’s start with the report output and the 13 scenarios shown in Figure 1.

We see that the forecast of houses needed by 2032 varies from 3,400 to 22,200 (the most extreme scenario of building 46,530 ‘affordable’ houses has not been considered here as the report drops it). This range covers a factor of 6.6 X. The dotted line is the 800 houses per annum target imposed by government (but also compatible with Litchfield’s final proposal to the council). The thick line shows the result using the actual Wirral annual delivery of 383 houses per annum in the recent decade.



Screen Shot 2018-08-15 at 14.49.59

The 383 figure reflects recent reality in terms of Wirral demographics, economic migration and the state of the house building market. If forecasters, councils and governments insist on very different numbers for housing growth they should be required to show cause…particularly if the forecast impacts negatively on the quality of life of large numbers of Wirral residents and threatens the loss of irreplaceable high quality farm land and core biodiversity refuges in the Green Belt. Despite the fancy talk of ‘evidence based’ planning by governments the fact is much of what passes for analysis is guess work often based on unstable base data as we will see. Forecasts are often politics based not evidence based.

3 Wirral Population & Household Numbers History
The starting point of the ‘official’ methodologies used for housing needs forecasting are the future demographics of the area population. If these are wrong then all that follows in terms of ‘economic policy uplifts’ and the rest, is pointless. The official government (ONS) historic data on Wirral population changes from 1990 onwards has been remarkably unstable and subject to regular ‘adjustments’. This does not give confidence in the official data nor in forecasts based on it even before imaginative economic scenarios are appended to the basic demographics. Figure 2 shows the population history from 1991 to 2011 before ‘adjustments’ were made to make some consistent sense of the data. In 1990 the population was about 336,000. By 2010 population had apparently fallen to around 309,000 a decline of ~0.45 % per annum overall. Decline slowed to -0.31 % after 2005. By contrast the ONS forecasts for 2012 to 2035 projected a growth of +0.15% per annum.


Screen Shot 2018-08-15 at 14.50.12

At the 2011 census the embarrassing historical numbers were ‘uplifted’ to reconcile with those of the census. The varying ONS forecasts from various, almost successive years are concerning. Looking at 2008 base data is interesting. 2008 to 2012 we are told was a period of ‘national recession and economic stagnation’. On that basis population was projected to fall long term! Later the 2010 base rate was adjusted to correct for the census gap. By 2012 the base numbers were adjusted upwards but the end point in 2032 was the same! These are a remarkable set of estimates and forecasts for all the wrong reasons. Here are the various ‘adjustments’ made after 2010.

Start year Population 2032 Population
ONS 2008 base 2008 309,000 304,000
ONS 2010 base 2010 310,000 329,000
ONS 2012 base 2012 320,000 330,000
The reader should note the apparent sensitivity of the Wirral population to economic conditions. Current UK growth is still very modest. Borrowing and debt levels are very high. Interest rates are very low but beginning to increase. A possibly hard Brexit will further dampen growth as the government acknowledges. Please note: none of this is built into the current forecasts of Wirral housing demand and the forecasts used for job growth and so on in the 2016 report were already optimistic. They assume that Wirral Council’s ‘growth stimulation’ policies will work. History from 1990 suggests otherwise.

Nevertheless the forecast is for a major turnaround in the 20 year decay of Wirral’s population. Even if we accept this forecast (which will be challenged in section 4) note also that the population in 2032 (~330,000) has not yet recovered to the level of 1991 (~336,000). Nevertheless it seems we need to build an additional 800 houses per annum until 2032 to house a supposed additional ~10,000 people. By 2015 the government figures for Wirral had changed again (see below).

4. Forecasts of Population & Households to 2032
The core basis of the Wirral SHMA and Housing Needs Study 2016 are the local demographics. If these are wrongly forecast everything else falls. As we just saw the historical data is all over the place but we must try. Figure 3 shows the reconciled (final?) population history of Wirral and the supposed household numbers. We will work with these since the council and government do so. ONS Estimated Resident Population tables to mid-2016 tell us that the population in mid 2011 was 319,800 souls and in mid 2016 was 321,200 souls. This gives us a growth rate of 280 persons per annum.
Household numbers in 2011 were 141,000 and in mid 2014 142,400. Note that from 1991 to 2001 there was no growth in household numbers. So HH size in 2011 was 2.27, in 2014 2.255. Recently HH size has been falling at ~0.005 per annum. At that rate by 2032 HH size would have fallen to 2.17 persons. However ONS ‘Families and Households 2017’ shows that across England from 2013 to 2017 HH size stagnated. HH size change is related to increased life expectancy which has been increasing for many decades.

However the ONS Human Mortality Database just published shows a massive drop in life expectancy growth rate (2006 / 2011 12.9 weeks per annum for women down to 1.2 weeks per annum in 2011 / 2016; 2006 /2011 17.3 weeks per annum for men down to 4.2 weeks per annum in 2011 / 2016). The decline may be related to austerity and reduced funding of social care, etc. We will look at two scenarios. First that HH size continues to decline to 2032, to 2.17 persons. Second, that HH size stagnates at 2.23 persons.
How will population develop? Let’s look at actual overall trends for the recent decade and for the two latest census periods. The 2011 – 2016 growth rate we found was 280 persons per annum. The (reconciled) 2001 data puts population at ~316,000 and at 2016 as 321,200. The longer period growth rate was 347 persons per annum. We see that population growth has decelerated in recent years reflecting poor economic conditions.
Given that the government expects somewhat lower economic growth for some years related to Brexit we take the lower growth rate. Population growth 2014 to 2032 would then be 18 x 280 = 5040 persons. Population in 2014 was 321,200. Population in 2032 would be 326,240. Using stagnated HH size at 2.23 then gives us 146,296 HH versus 142,400 in 2014. Increase in HH is 3895 in total or 216.4 houses per annum. If HH size drops to 2.17, which seems unlikely, this would give us a need for 441 houses per annum. Note that the mean of 329 compares well with the actual historic delivered rate of 383 reported in the Wirral SHMA Study.
These results follow from a simple model based on actual trends and experienced trend ranges in Wirral population and households plus a few assumptions about general economic prospects over the next decade. Accuracy cannot be claimed but the housing requirement is only 27% to (an unlikely) 55% of the official target. The official housing forecast models are far more detailed, dissecting out local demographics and then adding back in council growth policies, net migration, job growth and housing market factors. But as we saw in Figure 1 this leads us to a wide range of complex but guesswork based scenarios giving a very wide range of numerical forecasts. You might well think:
’ never mind the quality feel the width’ …but I could not possibly comment.


Wirral Population & HH ONS Estimates 2015

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Is this perhaps unfair? Let’s take a key example from the Wirral SHMA & Housing Need Study 2016. Page 137 presents Table 8.2 which lists their key modelling assumptions for the growth forecasts. It starts with the basic population and two estimates:

‘2012 based SNPP 10,140 population growth 2014 – 2032.’
‘10 year long term Migration Scenario 66 population growth.’
‘Higher of the 2 approaches represents the population for the demographic starting point’.

Funnily enough if we take the scenarios mean we get 5103 compared with our 5040… but the low growth scenario is ignored. They use the 10,140 growth figure which it is said equates to 11,830 new houses. Various ‘uplift’ factors are then applied giving a 757 houses per annum requirement which is further ‘uplifted’ for Council growth plans, etc, giving ‘Fully Objectively Assessed Needs’ of 875 to 1233 houses per annum…higher than the ‘wicked’ government imposed 800 target of 2018.

5. Green Belt Land Requirements
The Strategic Land Availability Study is a necessary part of the preparation of the Local Plan and part of this is a Review of Green Belt land. In July 2018 Wirral Council published a map showing 50 green belt sites across Wirral said to be available for ‘release’ for housing development according to the landowners / developers. The interesting question is how does this area of land relate to the ‘official’ housing needs target which must be met by the Council i.e 12,000 new houses by 3032.
We now look at the land area involved and typical housing densities to answer this question. Using the NLS online measurement tools and 25 inch OS maps the total land area involved is ~7.6 square miles and ~4864 acres. Figure 4 shows the map of intended GB ‘release’ sites. The square of 3 miles X 3 miles shows the rearranged green belt sites which fill it well. Imagine a new urban township 3 miles X 3 miles square on the Wirral.

FIGURE 4 Intended Green Belt Council Release Sites

Screen Shot 2018-08-15 at 14.50.42

The DCLG Land Use Statistics (England) 2010 provides actual housing densities by region. For the NW densities have ranged from 22 to 49 dwellings per hectare in recent years with a tendency to increase. The mean is 36 dph or 14.57 dwellings per acre. At this density the GB release plan land could support 14.57 x 4864 = 70,870 houses.
The government / council required total is 12,000 houses. So the GB land proposed for development ‘release’ by the council is 5.9 X more than the land needed to meet the target (assuming that no houses are built on brown field land).Only 17% of that Green Belt land would be required. Readers might consider this a little strange. Is the Wirral Council incapable of doing a few simple calculations to support their housing planning strategy? Surely they employ professional planning officers at considerable expense to us?
I suggest that the GB land overkill is part of a deliberate political strategy. First, announce that a huge area of Green Belt is needed to meet the ‘government’s housing targets’. Second, encourage residents to ‘complain’ through local Labour Party organised resident meetings and a hysterical press campaign: those to blame being the Conservative government for trying to ‘subvert local democracy’ and Peel Holdings for ‘land banking’. Third, hold the official Consultation on the plans in September 2018.
Fourth, in December 2018 after the review, announce that the Council has listened carefully to residents’ concerns and thanks to the Council’s heroic efforts 83% of the GB sites on the release plan have been ‘saved’. Fifth, win more votes in the next election.
However the above calculations start from the official housing needs estimate of 800 x15 = 12,000.We have shown that this is a very unrealistic target taking into account actual Wirral history, population numbers, household numbers, lack of economic growth prospects and the strong slowdown in life expectancy improvement. A more likely housing requirement over the plan period is 216.4 x 18 = 3895. If we use this number the fraction of GB land on the ‘release’ plan actually required would be 5.4%.
Note also that the Council has now identified 91 brown field sites where 2,400 houses could be built. But this is 62% of our estimated 3895 requirement. If these sites are used the Green Belt needed would be just 2% of the proposed Council ‘release’ plan.
Nevertheless somebody is going to draw the short straw and lose their adjacent Green Belt. After all there is much more money to be made by not bothering with the large area of Brown Belt land available on Wirral which costs more to develop. The developers make more profit from Green Belt. The Council gets higher rates from the Green Belt luxury houses they build. Very few ‘affordable’ houses will be built because of the ‘viability’ test loophole. Surely Wirral residents are being badly misled and treated with contempt by those who were elected to protect their interests… to the benefit of land speculators and the politicians. Politicians come and go but once Green Belt land is gone it is gone forever.
Enough is enough. It is time to fight back.
Professor (retired) D P Gregg: Background in mathematical modelling, statistics and operational research. For fifteen years served as visiting professor with a leading northern university. Collaborated with several universities in Europe and the USA and led EU funded industrial projects with other large companies. For several decades led a forecasting research / decision science, internal consultancy group for a large, well known multinational company. Advised senior management and the board on tactical and strategic business planning.


Muckspreading Over Wirral’s Green Belt


© Copyright Peter McDermott and licensed for reuse under this Creative Commons Licence.


There seems to be no end to the acres and acres of ‘news’ about the so-called threat to Wirral’s Green Belt. The verdant verbiage of  Wirral’s ping pong politicians has been the equivalent to midsummer muckspreading and similarly stinks to high heaven.

Consequently we’d like to give the final word to ‘The Prof’ on the matter. Whilst we appreciate the factual analysis he brings to the alleged threat to the Green Belt we concur wholeheartedly with his assessment of the cynical games that are being played which amount to nothing more than a distraction during the dog days of summer.

Is there no limit to the dishonesty and stupidity of the council?

Having talked to the Wirral Society I was pointed to the issue of
how much land was needed to meet the official 12,000 houses
strategic target. I did a few sums you might like.
Area of Green Belt (GB) land on the published council ‘release’ map
is ~7.6 square miles and 4864 acres.
(Calculated using the NLS online mapping tools and 25 inch OS maps.)
Housing density on ‘previously undeveloped land’ in NW England is
22 – 49 dwellings per hectare, average 36 dph = 14.57 dwellings per acre.
(Data from DCLG Land Use Statistics (England) 2010.)
There is room on the GB release plan for 14.57 x 4864 = 70,870 dwellings.
The official government / council 15 year housing target is 12,000.
The GB land targeted for release is 5.9 X that actually needed.
Is the council incapable of doing simple planning calculations?
Or is the huge area of GB threatened part of a cunning political plan?
Imagine the cabinet conversation earlier this year.
‘I know, let’s scare the hell out of residents by threatening far more GB 
land than we need. Stir the sheep up! Then after the Consultation we say:
look we listened to you…we have saved 5 / 6 of your  GB land under threat! 
Vote for us!’
Of course it’s worse than this. The 800 houses a year official housing target is not based on what has actually happened on the Wirral in the last decade but on fantasies which assume economic growth and migration unprecedented in our history at a time of great economic uncertainty and as life expectancy increase falls drastically. A more realistic housing target is ~200 hpy. So  the official housing target is 4 X that probably needed. This suggests that overall the GB release plan is targeting ~24 X more land than is needed.Of course the council (and government) accept that considerable brownfield land is also available and should be used first.
The only Green Belt crisis is that created by local and central government 
politicians for their various political and selfish ends…not for our well being. 
Surely it is time to stand up to these foul people once and for all. 
                                                                                 The Prof.


Green Belt Review


Pip : Green Man or a threat to the Green Belt?

We are pleased to publish a letter from The Prof an extract from the introduction to his brilliantly researched Wirral Green Belt Review 2018 explaining why Wirral residents need to wake up and take action against threats to Wirral’s Green Belt. It would appear that there is a growing realisation that that threat lies closer to home and that the approved narrative from Wirral Council that the villains are the Peel Group and bullying bureaucrats from central Government simply doesn’t stack up – especially in the light of the proposals for the Hoylake Golf Resort.

So instead of bogus consultation meetings and political point scoring in the local newspapers Professor David Gregg (‘The Prof’)  is kindly providing facts and figures and a cogent argument as to why local activists need to be informed and get involved to protect the Green Belt. Although his analysis is about the impact of housing development at Poulton Lancelyn it serves as an excellent template for Green Belt activists . If anyone would like a free e copy of The Prof’s book get in touch with us :

Hello! Now the time scale for green belt site assessment against the national and local development criteria has been slashed to zero it is essential that local action groups make and submit their own analyses to the planning process.

As I mentioned I have done this for site 1984 at Poulton Lancelyn. I have published and am now circulating this independent report to locals, councillors, Alison McGovern and various heritage, wildlife and countryside activist groups. On several key grounds the aim to ‘fill in’ the whole GB land area east of the M53 from Prenton, south to Raby Mere is very damaging and totally unjustified on the Council’s own criteria. Somebody has gone insane. My local group will be gearing up action over the next few weeks but I thought you might like to see the report now. I am providing e copies free to any local Wirral residents affected.

                                                                          The Prof.

A Strategic Housing Land Availability Study is being undertaken by Wirral Council as part of the generation of the Core Strategy Local Plan to be submitted to the DCLG Secretary of State. Part of this process involves identifying sites within the Green Belt to be made ‘available’ by landowners and developers for housing development and their subsequent ‘release’. The NPPF of 2012 requires local authorities to boost housing supply and this has recently (March 2018) been reinforced by the Prime Minister in the new draft NPPF proposals. Fifteen councils were singled out for condemnation by the then Secretary of State for failing to define a Local Plan and deliver an adequate level of new housing. Wirral is one of these councils. Secretary Sajid Javid has recently said of Wirral

‘In the 13 years that have passed since the 2004 Act was introduced your council has failed to meet the deadlines set out in that timetable.’

The threatened consequence is direct government intervention in the housing development process. The last Local Plan was written in 2000. The policy on Green Belt in the draft 2018 NPPF remains essentially unchanged (3). However there will be increasing pressure to build on Green Belt land which is why the listing of ‘available’ sites for development in the Wirral is important. If a site is not on the list it will not be considered, given the long list of ‘available’ sites in total (~110). The aim of local resident groups at this stage should be to prevent and protest local site listing and then ‘release’ for development. The question of redefining the Green Belt and building on green belt land sites appears to have arisen because of ‘land banking’ by developers in other Wirral areas. Council leader Phil Davies informed Secretary Sajid Javid in an official letter (31.01.18) that

‘Planning permission is currently in place for 16,098 new homes including 2,577 on existing urban and previously developed sites and up to 13,521 dwellings at …Wirral Waters…
The Council’s current SHLAA to April 2017 shows potential for a further 4,531 dwellings, subject to viability…’

At an intended target rate of house building of around 800 per annum the above implies we have a 26 year supply in hand. In addition ~6,000 existing houses are claimed to be lying empty.

According to Cllr. Davies, progress on ‘housing led regeneration has been hindered’ by the cut back in Conservative central government funding. Given this background the pressure to release and build on Green Belt land must seem obscure to the ordinary Wirral resident (but read on). The unfortunate attitude of some local councillors appears to be that until a landowner or developer makes a planning application residents can go back to sleep. This presumably reflects a complacent view of current ‘national’ policy.

‘National policy states that Green Belt boundaries should only be altered in exceptional circumstances through the preparation or review of the Local Plan and that inappropriate development in the Green Belt should not be approved except in very special circumstances.’

But a new Local Plan is being written and ~110 Green Belt sites have been put forward by ‘landowners and developers’ including site 1984 ; GB parcel SPO42, adjacent to Colmore Avenue and Poulton Green Close and further south to a point near Lancelyn Farm. If all these Green Belt sites are ‘safe’ why have so many landowners put them forward formally, as available for development ? Is this simple land speculation or prior knowledge? Also, very special circumstances are with us: an alleged national shortage of ‘affordable’ housing and the government’s desire for some major political ‘virtue signaling’…