COMMENTS ON THE LETTER FROM ERIC ROBINSON TO
MARGARET GREENWOOD MP (Dec. 2018)
I will try to confine my comments mainly to the issue of housing requirement projections and green belt land needs under Robinson’s various letter headings.
‘Lack of Clarity on Wirral’s Housing Needs’
Mr. Robinson gives a one page useful summary of the history and current status of this issue. Unfortunately there are misleading statements involved which need correcting as we go. Mr. Robinson begins with the 2016 SHMA by Lichfield Consultancy. He notes the range of forecasts provided (from among 13 scenarios) as 875 to 1,235 houses per annum. Readers may note that the lower figure is higher than the proposed 803 h/a proposed by the government. However several things must be noted.
The total numbers quoted refer to 18 years not a 15 year period.
These numbers are not based on the approved ‘standard method’ in several respects. Notably they include assumptions about council policy and economic impacts which play no part in the standard method.
They are based on out of date SNPP 2012 population/household data.
The high estimate of population growth from 3 is selected (10,140) although they acknowledge a long term migration scenario based on real history which predicts a population growth of just 66 over 18 years.
Large uplifts are made for assumptions concerning ‘pent up demand’ which depend on optimistic economic forecasts and a high household formation rate.
Also Robinson does not mention the Liverpool LEP job scenario which gives 188 h/a nor the actual recent housing delivery rate of 383 h/a which we can say reflects all factors in play. Six of the 13 scenarios cluster tightly around a rate of 470 h/a or 7,050 in 15 years compared with 875 to 1,235 reported. (This compares with numbers from 5,923 to 7,170 obtained using the standard method from the latest ONS population / household data by this author and the 7,320 obtained by the council).
Based on the raw demographic data in the 2016 SHMA, without doubtful economic uplifts, we would obtain 563 h/a. If we took the average of the two population figures they quote we obtain 284 h/a before uplifts. These yield 2,820 or 4,260 or 8,440 houses over 15 years. One wonders if anyone at the council has read the SHMA report of 2016. It cost us over fifty thousand pounds to produce but its many warnings and caveats were ignored.
The author has no argument with the current standard method as a demographic starting point. Most of the projections made in my own housing report used as a basis for green belt housing requirements, used the standard method. Robinson fails to mention this fact and speaks only of an ‘alternative’ method, seeking to dismiss this work. The real problem as Robinson acknowledges is the quality and instability of the ONS population and household data and I add, the unintelligent use of ‘trend analysis’. Our housing requirements fall from 2012 to 2014 to 2016 not because of the method but because the data is unstable and still suffering from reconciliation problems between the 2001 and 2011 censuses which the ONS acknowledges as a problem nationally. In our case the basic ‘natural’ internal population projections should be quite accurate and can be calculated mechanically. They show the population decline which has been the norm here for decades. Our local problem is that the mechanical application of the ONS trend rules to historical migration data leads to a massive, unrealistic over estimate of net migration into Wirral as my report explained. This was acknowledged also by Lichfield Consultants in the 2016 SMHA as I have repeatedly pointed out, but ‘magiced’ away by referencing the brain-free ONS ‘rules’.
Robinson notes a ‘retired professor in Bromborough’ with an ‘alternative approach…which a number of people are seeking to attach importance’ to. I assume this is me. This is very disingenuous and dismissive. I repeat, my appendix 1 and 2 tables showing the implications for green belt land requirements are based on the standard method and ONS data. I also provided forecasts based on variations of trend analysis to demonstrate how sensitive targets are to slight variations in assumptions and data. I also apply official government variant scenarios on migration and life expectancy scaled to the Wirral, to show the effects of recent events. These further reduce our future housing requirements. The council readily considered the 13 scenarios created in the 2016 SMHA Lichfield Consultancy report so surely ‘a retired professor in Bromborough’ can also legitimately explore and report half a dozen explanatory scenarios? What is the council afraid of? Could it be they fear the Wirral ‘general public’ being properly informed for once about their manipulations?
Robinson’s QC is correct in advising the council that they should prepare a local plan case based on the standard method, whenever that stabilises. However the issue of data is another matter. The ONS data bases are in disarray across the country. At some point this will be challenged by some, competent, well informed local authorities. Wirral should be prepared for this by looking closely at all the relevant local historical demographic data with emphasis on migration projections… as I have attempted to begin to do. I will continue to seek out independent (official) data, such as registered voters, which allows dependable population, migration and household trends to be estimated for use in the standard model: we cannot rely on ONS projections or ‘estimates’ between censuses. They are completely discredited …as the recent government panic reactions prove.
‘Wirral Waters’, etc & Green Belt Land Requirements
Robinson’s note provides additional, new information on council assumptions. He tells us that ‘any figure over about 406 houses per year (equivalent to 6,090 over 15 years) would trigger a need to consider land to be released from the Green Belt’. Let us use the council’s own numbers to see what this actually means. On the September 2018 ONS household projections and the standard method the council says we need 7,320 houses. This is about right. This means that we need 7,320 – 6090 = 1,230 house places on GB land. The average government NW density figure is 14.5 houses per acre so we would need just 84.8 acres of GB. But the local plan GB release land parcels amount to ~4,900 acres. This is 58 X the area actually needed to meet the housing target. However the council may be forced to accept the earlier 2014 ONS data based target of 12,045 houses. This means that 12,045 – 6090 = 5,995 house places on GB would be needed. But this is just 413 acres compared with the 4,900 acres up for release. The GB release area proposed is 11.9 X the area required in the council’s own worst case scenario.
Why is it that these critical facts have not been explained to the public? I suggest that it is intended to muddy the waters. If 4,900 acres of GB land are released in this local plan ‘because the council is being forced to by the government…we have no choice’, developers (and the council) can relax and cherry pick the (up to) 413 acres actually needed, for maximum profit and convenience all round: perhaps over the full 15 years plan period. But this leaves ~4,487 acres of released GB permanently available for building, beyond the highest local plan requirements, if all the currently proposed GB land parcels are released.
Wirral would become from now on, the ultimate free for all target area for developers and speculators in the northwest. No doubt that is the plan, unless it is stopped.
If we wish to preserve Wirral in anything like its present form, the public must object loudly in the final public consultation on the Local Plan in 2019 if more than the absolute maximum said to be necessary, 413 acres of GB land, is put forward for release.
The release of 4,900 acres in one ‘apocalypse now’, is totally unjustified on the council’s own data and worst case assumptions.
It may be by mid 2019 that a revised standard methodology and an ONS data challenge will show an even smaller GB area is actually needed than 413 acres. I will continue to look into this. I suggest that when the dust settles we will find a demographic housing need of less than 3,000 houses. However the other side of the equation is how much land is available outside current green belt. Current council claims on this also need to be looked at very carefully. Robinson quotes a number of 6,090 house places available on non-GB land. Let us examine this against published brown field sites (as surveyed by the council), the contentious Peel/Wirral Waters numbers and actual empty house refurbishment.
Earlier this year the council said it had identified 2,400 places on 91 ‘brown field’ sites. This would leave 6,090 – 2,400 = 3,690 other identified places on non-GB sites. What are these? What about the Peel plans? Robinson spends considerable space in his letter attacking the Peel position, which continues the council stance taken throughout 2018. Peel were identified to the public as the villains of the piece. Robinson rejects Peel’s ‘higher scenario’ offer which presumably is the 13,571 dwellings with outline planning permission. However Peel made it clear to the government and in a public letter in 2018, that this figure only ever applied to the full 30 year Wirral Waters project span. The ‘medium scenario’ offer was 6,450 dwellings subject to council financial support on infrastructure, etc. Robinson does not mention the minimum delivery offer from Peel of 2,900 dwellings which appears to come with few strings attached (see below). One would think that urgent negotiations would now be under way with Peel and it appears Robinson’s ‘leading’ QC has sent a letter to elicit, after several years of discussion, a detailed development schedule.
N.B. From Robinson’s letter the position appears to be that the council will take the hardest interpretation of the NPPF rules in putting forward non-GB land availability and other matters in the local plan. One could see this as a cautious, conservative approach but there has been much discussion nationally about NPPF interpretation and implicit flexibility on ‘availability’, ‘deliverability’, ‘viability’, etc. If the council is not intending to seek out this flexibility and use it, by so directing their expensive QC, Wirral residents might reasonably assume that it simply wants to release as much Green Belt land as possible by hiding behind alleged ‘harsh Conservative government’ rules and ‘unreliable development partners’. Residents might wonder why. See above.
Let us return now to the numbers game. The unidentified 3,690 places on non-GB land implied by Robinson can be compared with the lower, deliverable Peel offer of 2,900 dwellings. Using this leaves 3,690 – 2,900 = 790 houses or ~53 houses per annum. Despite the negative bluster perhaps Robinson actually expects Peel to deliver their minimum offer at least. The other 790 houses may come from empty house recovery. Data supplied by a councillor suggested there were ~4,000 (> 6 months) empty houses on Wirral in 2017. In recent years the average house recovery rate (by the council) was ~238 h/a (based on their own data). So recovery of ~53 h/y or higher should be quite feasible in future.
In my local plan submission I included two tables showing the impact of various brown field options on GB requirements. I can now update these using the new council data from Robinson, for the readers’ interest. We keep the 2,400 brown field council data and the 790 houses inferred from recovery, in total 3,190. Suppose now the council comes to an accommodation with Peel on their ‘medium scenario’. This would replace 2,900 with 6,450 giving in total 9,640 dwellings. If we allowed double the inferred empty house recovery rate we have 53 x 2 = 106 p/a. This still only 44% of the actual recent rate. In this case we would have in total 9,640 + 790 = 10,430 places on brown field sites. Green Belt land needed in the worst (target) case becomes 12,045 – 10,340 = 1,705 dwelling places or ~118 acres compared with proposed 4,900 acres of parcel release.
Now it is accepted that local plans will be regularly reviewed and evolve over time as Robinson tells us in his letter. At worst then, we start with a stated need for ~413 acres of GB land over 15 years. But assuming a modest level of competence in the council and good will between Peel and the council, the ‘medium scenario’, deliverable in say 5 or 10 years time, implies only ~118 acres of GB is needed in total. I would assume that a ‘leading’ QC would be able to elegantly mount the appropriate arguments about land release phasing.
However the council points to a need for only 7,320 houses during the plan period based on the most recent 2016 ONS projections and the standard method. If this becomes accepted again, or this is forced upon the government by evidence presented by a number of councils with competence and backbones, or by independent analysts, the Peel ‘medium scenario’ tells us that total brown field places would be 10,430 and so NO Green Belt at all is needed to meet the local plan, as I argued clearly in my local plan submissions in September 2018. It is probable that it will soon emerge that the ONS demographic projection system is broken and the local authority level ONS data generally is unreliable for important decision making. However we should not rely passively on this scandal breaking.
If the council genuinely wishes to protect our Green belt as it repeatedly states, it should prioritise three actions:
Stop playing political games and negotiate urgently with Peel Holdings.
Accept the standard method but challenge the ONS population and household projections for Wirral. Among other things: consult other councils with similar misleading data problems and organise resistance; jointly commission a formal critique of the ONS automatic trend rules and data stability e.g. from the Royal Statistical Society; seek independent (but official) data to establish actual Wirral net migration trends as these dominate, unrealistically, all the government projections.
Present a phased local plan to the full extent the ‘rules’ allow, emphasising the national failings and problems with the ONS data and projection methods: the clear aim being to limit the release of GB land to the minimum necessary at any given time and NOT the reverse, which appears to be the current policy.
‘Green belt and urban sprawl’
The council does have an obligation to properly assess all available alternatives. It may choose to assess all GB parcels put forward as available for development. But to be clear: it is not obliged to release any GB land in excess of that needed to make up any shortfall from available brown field sites. We have shown that even with the worst case target using the government standard method and data, only ~ 8.4% of the council proposed GB release list would be needed. On the forecast based on the 2016 ONS data, argued (we are assured) by the council, to the government, only ~1.7% of the GB release list would be needed.
The letter gives some hints as to how the ~8% might be selected. Such sites ‘are either physically enclosed by the wider urban area or would not reduce the physical separation between existing Settlement Areas…which means their impact on urban sprawl would be much less when compared with other parts of the GB.’ These are weasel words which local activists need to look at carefully in each case. Note particularly Robinson’s comments on Irby, Thingwall, Pensby, Heswall and parts of Barnston and Gayton. Since these are all part of SA7 one gets the impression anything goes here. However the local plan background documents also discuss the attraction (in the minds of council planners) of creating a hard (neat) green belt boundary at the M53 by ‘filling in’ the whole area of high quality farm land to its east side from Storeton down to Poulton Hall and again at Eastham. Nobody living here can feel relaxed with such openly declared, Big Brother thinking. However Robinson tries to reassure us by saying ‘some of these sites may [still] be found unsuitable for other reasons, which would need to be demonstrated on the basis of technical evidence.’ However in the Infrastructure section of his letter we learn that as yet no assessments have been made in several key areas: transport, strategic flood risk, agriculture, biodiversity and sustainability. The council ‘will be commissioning a series of technical and environmental studies…’ but ‘specialist consultants’ have yet to be appointed as 2018 ends. We are told that at least the council is talking to education and health service providers. Let us hope so.
The author, given that we are now ‘Borough of Culture 2019’, notes there is no mention of assessing the impact of GB housing estates on our rich historical heritage on Wirral. To take just one example, powerful evidence now exists that the great Battle of Brunanburh, the equal of Hastings in defining English history, took place in the area between Storeton Village / Higher Bebington and Poulton Hall with the centre near Clatterbridge. Most of this land area is east of the M53 and it is all on the GB release list. Already, even before general GB release, the building of 27 luxury homes has been approved (on appeal) on GB land next to historic Storeton Hall, which will be converted into luxury apartments. It is widely believed, based on known commercial links and clear conflicts of interest, that the council made only a limp wristed attempt to stop this development at the appeal. This is the future of Wirral GB, chopped up quietly, piece by piece, unless the government and council are challenged strongly on all matters discussed earlier and on the basis of hard evidence. Much more could be said about misleading council behaviour. Be vigilant and defend Wirral in 2019.
Professor D P Gregg (retired)