Attachments: BSARA LGBCE Lichfield FER Warding 20140302.pdf … · 2018. 3. 16. · 1 Cooper, Mark...

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Cooper, Mark

From: Andre Hefer <[email protected]>Sent: 02 March 2014 12:29To: Cooper, MarkCc: Reviews@Subject: Lichfield District (FER) -- Warding arrangements consultationAttachments: BSARA_LGBCE_Lichfield_FER_Warding_20140302.pdf

Dear Mr. Cooper Please find attached the consultation response form the Beacon Street Area Resident's Association ("BSARA") regarding warding arrangements in Lichfield District. Here are some Google maps hyperlinks, in case you need higher or lower resolution than the maps we have included in our submission:

Leomansley and Stowe wards http://goo.gl/maps/vEwGJ St John's and Boley Park wards http://goo.gl/maps/HIegH Chase Terrace, Summerfield & Chasetown wards http://goo.gl/maps/pHQ2a

You may need to be a bit patient while the overlay data on the maps loads. Also Google maps is not very friendly to smart phones and tablets.

Would you kindly acknowledge receipt of this submission? Thank you in advance. Regards Andre Hefer on behalf of the Beacon Street Area Resident's Association ("BSARA") -- Web: www.beaconstreetara.org Twitter: @beaconstreetara Facebook: BeaconStreetAreaResidentsAssociation

50 Beacon Street, Lichfield, Staffordshire, WS13 7AJ E mail: - [email protected]

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2nd March 2014 The Review Officer (Lichfield) Local Government Boundary Commission for England Layden House 76-86 Turnmill Street London EC1M 5LG

Dear Sir / Madam

Lichfield District Electoral Review — Warding arrangements Consultation

I am writing on behalf of the Beacon Street Area Residents’ Association (“BSARA”) to provide our association’s response to the public consultation on the warding arrangements for Lichfield District Council.

1. Recent events Since writing to the Local Government Boundary Commission for England (“LGBCE”) on 09/October/2013 regarding the council size consultation, a number of events of note have occurred:

In November 2013 a district councillor for Chadsmead was disqualified for failing to attend council meetings for six months. This triggered a by-election. Press reports indicate that the same councillor resigned from the City council shortly before being forced to step down for failure to attend City council meetings.

In December 2013 councillors for Stowe ward held a surgery. To BSARA’s knowledge this was the first public surgery held by any district councillor for the wards of Stowe, Leomansley or Chadsmead since the 2011 election. BSARA welcomes this initiative.

BSARA understands that some councillors have now requested additional training. We understand that the current budget is £5,000 p.a. While still low this is higher than the actual expenditure on councillor training of £1,719 p.a. in 2011-12 and very low compared to the £400,000+ p.a. spent on members allowances. If the basic allowance saved by cutting two councillors was reinvested in member training, then the training budget could increase by over 100%. We think this would be money well spent.

In December 2013 Lichfield District Council withdrew its forecast of the electors, by ward, in 2019. This followed correspondence from BSARA pointing out that the forecast was inconsistent with the draft Local Plan. The quality of the revised forecast is a considerable improvement on the first attempt. The district council agrees that its latest forecast is still not consistent with the current draft of the Local Plan, which has been passed to the Planning Inspectorate and which is currently undergoing public consultation. The district council justifies this discrepancy by pointing out that – at the time the revised forecast was prepared - the full council had not yet endorsed the latest plan modifications. (cont.)


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The district council believes that incorporating these additional development sites into its revised electoral forecast would have been “premature”. BSARA has quantified the impact of this decision in section 2 of this letter.

In 28/Jan/2014 the LGBCE published revised electoral forecasts and extended the consul-tation period to 03/Mar/2014. BSARA thanks the LGBCE for agreeing to this deadline extension and for its efforts to ensure that a more credible electoral forecast was produced.

2. Forecasting the size of the district’s electoral in 2019 Our association is aware of the Schedule 2 of the Act which places an obligation on the LGBCE to “… have regard to any change in the number or distribution of local government electors in the area of the district council which is likely to take place within the period of five year immediately following the making of the recommendations.”

Our association’s rather simplistic view is that electoral imbalances matter most at election time. Lichfield district is on a four yearly cycle, so the next two elections will be in 2015 and 2019. If future rates of house building follow the draft Local Plan, then the electoral forecast in 2019 will be at a point where a number of major development sites will be at or close to their maximum housing delivery rates. Hence the electoral forecasts in affected wards are very sensitive to the actual rates at which homes are constructed and occupied. In section 3 of this letter BSARA has highlighted wards where we believe there is significant uncertainty about the likely rate of house building. Our association has recommended that in two wards the allocation of a single councillor be deferred until after the 2015, election due to the distortional effect of allocating councillors based on electors, who may exist in 2019 but will not exist in 2015.

The LGBCE’s warding arrangements consultation commenced on 26 November 2013, but the 2019 electoral forecasts only appeared on the LGBCE website on 28 January 2014. On 29 January 2014 BSARA wrote to Lichfield District Council to confirm that “our association consid-ers that – with the exception of St. John’s ward – the electoral changes / numbers of new homes are within a range that can be considered broadly consistent with the Local Plan”. Please refer to Appendix E [Appendix pages 15-21] for copies of correspondence on this topic. The Council concedes that three Strategic Development Allocation (SDA) sites for 1150 homes are included in the amended Local Plan but were not considered when computing the electoral forecast. The Council’s rationale is that - at the time of preparing the electoral forecast - it would have been premature to include these additional sites as the changes had not completed the Council’s formal approval process. This procedural step was completed at the council meeting held on 28 January 2014.

BSARA has prepared its own revised electoral forecast, including the three additional SDA sites at Cricket Lane and Dean Slade Farm, within the ward of St John’s, and Fradley, within the ward of Alrewas and Fradley. We have studied LGBCE guidance1 and hope that our work conforms to it. The net impact of our association’s changes to the electoral forecast is to add 480 homes (960 electors) within St John’s ward. The 480 homes is marginally in excess of the minimum number of homes2 – as stated in the council’s own evidence3 – the Local Plan is required to have in order to show an adequate supply of housing land at the point of adoption i.e. 2014.

(cont.)

1 - “Electoral Forecasts – A Guide for Practitioners” dated October 2011 2 - National Planning Policy Framework paragraph 47 “supply of specific deliverable sites sufficient to pro-vide five years worth of housing against their housing requirements with an additional buffer of 5%” 3 Public Examination hearing document ref CD2-23a, Strategic Housing Land Availability Assessment, November 2013, paragraph 7.31


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BSARA’s analysis supporting our amended electoral forecast is set out in Appendix A [Appendix pages 2-7]. For convenience we restate out conclusions below:

We accept the district level forecast;

We accept the forecasts for wards which do not contain Strategic Development Allocation (SDA) sites i.e. large residential development sites.

We accept the council’s forecast for the likely impact of SDA sites on the electorate in 2019 in all wards with the exception of St. John’s. Given the scale of house building on these sites, and the inherent uncertainty regarding the rate at which homes will be built and occupied, we think it would be prudent to defer the allocation of some councillors to wards, pending the actual impact on the electoral register.

We disagree with the council’s estimate for the size of the electorate in 2019 in St. John’s ward. We believe that the number of electors should be increased by 960 persons.

3. BSARA’s approach to warding arrangements Our Association has taken note of guidance issued by the LGBCE. We have also noted the district council’s amended Local Plan and Freedom of Information disclosures indicating that the district’s electorate will approach 90,000 persons by 2019 and exceed 100,000 persons by 2029. Our Associations approach has been guided by the following considerations:

With regard to the interests and identities of local communities, it is our view that there are three distinct community groups namely the urban settlements of Lichfield City and Burntwood and the rural settlements. With few exceptions our councillors are affiliated to political parties with many council debates polarised in this way. Consequently, councillors are likely to align themselves with colleagues of the same political party. BSARA thinks that many wards can be amalgamated without a significant reduction in the influence of individual councillors or having a detrimental impact on their ability to represent their communities.

Our district has historically and will for the foreseeable future continue to experience a rapid expansion in its housing stock and, via inward migration, an increase in the size of the electorate. It is arithmetically easier to maintain electoral equality for local voters in larger wards, e.g. if 3 councillors represent say 6,000 electors living in 3,000 dwellings, then it would take the construction of 300 additional homes to shift in the electoral balance by 10%. It is our Associations’ view that within urban areas and in larger rural settlements, such as Fradley, the norm should be 3 councillors per ward. Where possible BSARA’s sug-gestions have followed this warding pattern. In a few cases we have left wards with two councillors because a large development site - capable of accommodating hundreds of homes – exists within the ward. It therefore seems sensible to allow the capacity to add an additional councillor at a future date.

Our Association is in principle opposed to single councillor wards, but we recognise that this may be appropriate in a limited number of situations. BSARA believes multi councillor wards promote effective and convenient local government in a number ways: (a) it encourages meaningful contests at election time;

(b) there is less chance that residents will be under represented as a result of councillor inactivity due to old age, ill health or for other reasons;

(c) a group of ward councillors with a wider range of skills can work in support of each other for the mutual benefit of residents, and

(d) it discourages the current practice where councillors are reluctant to get involved when issues lie beyond the geographic confines of their wards. This balkanisation of accountability is detrimental to the resolution of local issues. Warding arrangements can be used to discourage this behaviour. (cont.)


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3.1. BSARA’s suggestions to reduce the number of councillors and to alter warding arrangements The existing electoral arrangements provide an unequal representation of electors. The 2013 electoral data and 2019 electoral forecast, provided by the LGBCE, indicate that:

in 8 of the 26 wards the number of electors represented by each councillor varies by more than 10 per cent from the average for the district and one ward varies by more than 20 per cent from the average;

by 2019 electoral equality is not expected to improve, with the number of electors per councillor forecast to vary by more than 10 per cent from the average in seven wards and by more than 20 per cent in four wards.

BSARA expects that in 2019 the electoral inequality is likely to be greater than LGCBE data suggests because Lichfield District Council excluded sites for some 900 homes from its electoral forecast on the basis that it would be “premature” to rely on the amended Local Plan as it had not been formally endorsed by the full council. This was done on 28/Jan/2014; therefore BSARA has taken account of this information and computed a revised electoral forecast. Our suggested warding arrangements are based on the BSARA’s revised electoral forecast in 2019, which is slightly larger than the forecast supplied by the LGBCE. This only affects the St John’s ward. Full details are included in section 2 above.

We note that Mr. Archie Gall’s letter to Lichfield District Council dated 26/November/2013 which states:

“The Commission is minded to recommend that 47 councillors should be elected to the authority in future”

“The Commission believes that 47 councillors would provide for a potential pattern of wards that could deliver a fair representation for electors in the urban and rural parts of the district.”

BSARA has attempted to create a warding proposal totalling 47 councillors. In doing so, we have experienced a number of practical difficulties:

Between 2013 and 2019 the electorate is forecast to expand by around 8,000 persons or 10%. Over 2,000 homes are earmarked for delivery in the wards of St John’s and Whitting-ton, with a significant proportion expected to be occupied before 2019. Allocating councillors, ahead of the 2015 election, based on the size of the electorate in 2019, will in itself create electoral inequality many of the homes will not have been built.

The LGBCE proposes reducing the number of councillors by nine (16%). Beyond the period of the electoral review – i.e. 2019-2029.- the Local Plan says that the housing stock/electorate will expand by an additional 15%. To ensure that warding arrangements are likely to endure in the medium term it seems sensible to achieve electoral equality through creation of more 3 councillor wards by amalgamating existing wards. Consequently BSARA has chosen not to rely a large number of boundary alterations to address current electoral inequalities as these are likely to require repeated alteration in future, especially in wards earmarked for large scale housing development.

Consequently BSARA suggests reducing the number of wards from 26 to 19, with an initial 46 councillors, rising to 48 councillors in 2019. The addition of the two additional councillors being contingent on the predicted level of house building actually occurring.

(cont.)


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3.2. Impact on electoral equality BSARA thinks that maintaining electoral equality at community level is extremely important. The draft Local Plan defines “sub housing market areas” – refer Table 1 below - which our Association thinks is a very useful way of splitting the district into communities or – in the case of rural areas – groups of settlements with common interests. BSARA has used the draft Local Plan’s sub housing market areas to measure electoral imbalance at community level i.e. are ward level electoral imbalances reinforced or cancelled out. Our association thinks this is important to ensure that the various parishes within the District are adequately represented on the District Council and also to ensure that ward and parish boundaries are logical and will remain easily identifiable. We are sure that the LGBCE will manage the conflicting requirements of maximising electoral equality at ward level with maintaining logical ward and parish boundaries.

Two wards within the rural areas have been identified separately namely Armitage with Handsacre (the only ward within the East of Rugeley sub housing market area) and Mease and Tame (the only ward within the North of Tamworth sub housing market area). Substantial housing development is planned in both wards. Once complete these new housing developments will geographically join onto the settlements of Rugeley and Tamworth which lie in neighbouring districts. It is possible that residents will identify more closely with the towns of Rugeley and Tamworth than they do with the District of Lichfield.

The effect of Lichfield District Council’s amended Local Plan will be to substantially expand the electorate in wards containing large sites earmarked for hundreds of homes. The district council has chosen to accommodate its housing needs largely within existing settlement boundaries or directly abutting onto such settlements. BSARA thinks that if a larger proportion of the District’s housing stock is to be accommodated in a small number of settlements then it is only fair that political influence – via the distribution of councillors - shifts in the same direction. BSARA feels much less strongly about addressing temporary electoral inequalities within communities’ particularly if future house building / inward migration will in itself address the issue.

Table 1:Estimating the impact of electoral inequality within sub housing market areas

BSARA’s suggested allocation

Sub Housing Market Area

Current Councillors

(A)

Pro Rata to 2013

electorateCouncillors

2013 Variance1

2013 Councillors

2019 Variance2

2019 Rural (incl. Fradley) 19 15.5 15 +3% 16 -2%City of Lichfield 17 15.0 14 +7% 15 +0%Burntwood 15 12.0 12 +2% 12 -1%East of Rugeley3 3 2.8 3 -12% 3 -8%North of Tamworth4 2 1.6 2 -14% 2 -20%District Total 56 47.0 46 48

Notes: 1 - 2013 variances calculated based on 47 Councillors and 1,727 electors per Councillor. 2 - 2019 variances calculated based on 47 Councillors and 1,901 electors per Councillor. 3 - This site is under active development. It is likely that the electoral balance will be below 10% before the 2015 election and will continue to fall as additional homes are built. 4 - It is likely that the electoral imbalance will be addressed sooner than the table above indicates. Refer to section 3.7 below.

The allocation of wards to sub housing market areas is shown in Appendix B0.

(cont.)


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Having tested our associations’ proposals at community level, we tested the impact of our proposals on electoral imbalances at ward level. Graph A below shows current electoral imbal-ances as well as the impact of BSARA’s proposals in 2013 and 2019. In 2019 our associations’ proposals would mean that 31 out of 38 councillors would be returned by wards with an electoral imbalance of under 5% and 41 out of 48 councillors would be returned by wards with an elec-toral imbalance of under 10.5%. This leaves 7 Councillors returned by wards with an electoral imbalance is still over 10.5%. It is possible that this outcome could be improved by moving polling districts between wards. This is not something that we have investigated.

Graph A: Ward variances due to BSARA’s suggestions Variance (Var): positive % =surplus % of electors compared to district average negative % = shortfall % of electors compared to district average

Increasing shortfall in electors Increasing surplus of electors

Notes: Current (2013) – Variances based on 56 councillors, the 2013 electoral roll and the existing al-location of councillors to wards; BSARA (2013) – Variances based on 46 councillors, the 2013 electoral roll and BSARA’s suggested allocation of councillors to wards; BSARA (2019) – Variances based on 48 councillors, a forecast electorate of 89,330 persons in 2019 and BSARA’s suggested allocation of councillors to wards.

A more detailed analysis of the electoral imbalances of each ward within the sub housing market areas of the district are set out in sections 3.3 to 3.7 below.


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3.3. Suggested warding arrangements for the Lichfield sub housing market area The Lichfield sub housing market area comprises the following wards: NO.15 (Boley Park), NO.16 (Chadsmead), NO.17 (Curborough), NO.18 (Leomansley), NO.19 (St. John’s) and NO.20 (Stowe). Unless explicitly stated below, our associations’ proposal is to retain the existing number of councillors and the existing ward boundary. In making an electoral forecast for Lichfield, the area of most uncertainty is the rate at which house building will take place within St John’s ward. The amended Local Plan places three Strategic Development Areas (SDA’s) within this ward – as indicated on the map in appendix B2 [Appendix page 10] - delivering 1,350 homes once completed. The council’s electoral forecast is based on 624 dwellings being added between 2014 and 2019, comprising 450 homes on the South Lichfield SDA and 174 elsewhere. Crucially the council’s electoral forecast does not in-clude any homes from the Cricket Lane and Dean Slade Farm SDA sites. As suggested in sec-tion 2 above, our association view is that the electoral forecast should have been based on housing delivery estimated for this ward consistent with the minimum number of homes required to make the Local Plan sound. BSARA’s electoral forecast has done so, which re-quires that approximately 450 of the 900 homes on the Cricket Lane and Dean Slade Farm SDA sites are delivered before 2019.

We have analysed the impact of our proposals at ward level, both in 2013 and 2019 – please refer appendix B1 [Appendix page 9]. We have also included maps setting our out proposals to alter the boundary between Stowe and Chadsmead wards – please refer appendix B2 – and the boundary alteration between St John’s ward and Boley Park ward – please refer appendix B3 [Appendix page 11].

Ahead of the 2015 elections our associations’ proposals are as follows:

Reduce Boley Park ward from 3 to 2 councillors within existing boundaries;

Reduce Curborough ward from 3 to 2 councillors within existing boundaries;

Retain 2 councillors in Chadsmead ward but transfer approximately 375 homes (750 electors) from Stowe ward to Chadsmead ward as indicated on the map in appendix B2;

Reduce Stowe ward from 3 to 2 councillors and transfer approximately 375 homes (750 homes) from Stowe ward to Chadsmead ward as indicated on the map in appendix B2.

Dependent on the rate of house building within St John’s ward and most probably after the 2015 elections our associations’ proposal is to transfer approximately 750 homes (1,500 electors) from St John’s ward to Boley Park ward as indicated on the map in appendix B3. Simultaneously with this boundary change we propose that the number of councillors in Boley Park ward be increased from 2 to 3.


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3.4. Suggested warding arrangements for the Burntwood sub housing market area The Burntwood sub housing market area comprises the following wards: NO.4 (All Saints), NO.5 (Boney Hay), NO.6 (Central), NO.7 (Chase Terrace), NO.8 (Chasetown), NO.9 (Highfield) and NO.10 (Summerfield). Unless explicitly stated below, our associations’ proposal is to re-tain the existing number of councillors and the existing ward boundary. The size of the electorate in Burntwood is relatively stable, rising by only 8% between 2013 and 2019; mainly due to the absence of large development sites. The amended Local Plan only in-cludes a single large development site for 375 homes in the Chasetown ward 2019 – please re-fer appendix C2 [Appendix page 13].

We have analysed the impact of our proposals at ward level, both in 2013 and 2019 – please refer appendix C1 [Appendix page 12]. We have also included maps setting our out proposals to alter the boundary between Chasetown and Chase Terrance wards – please refer appendix C2.


Amalgamate Boney Hay and Central wards and reduce the number of councillors from 4 to 3. The boundaries of the combined ward to follow existing boundaries;

Amalgamate Highfield and All Saints wards and reduce the number of councillors from 4 to 3. The boundaries of the combined ward to follow existing boundaries;

Amalgamate Chasetown and Summerfield wards and reduce the number of councillors from 4 to 3. The boundaries of the combined ward to follow existing boundaries except for the area bounded in ORANGE on the map in appendix C2 which is to be transferred from Chasetown ward to Chase Terrace ward;

Chase Terrace ward to retain its existing 3 councillors. The boundary to be amended to transfer approximately 450 homes (900 electors) from Chasetown ward to Chase Terrace ward as indicated on the map in appendix C2. This includes the East of Burntwood bypass Strategic Development Area. The effect of this transfer will be to increase the electors in Chase Terrace ward by 1650 persons by 2019.


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3.5. Suggested warding arrangements for the Rural (incl. Fradley) sub housing market area The Rural sub housing market area comprises the following wards: NO.1 (Alrewas and Fradley), NO.3 (Bourne Vale), NO.11 (Colton and Mavesyn Ridware), NO.12 (Fazeley), NO.13 (Hammerwich), NO.14 (King’s Bromley), NO.21 (Little Aston), NO.22 (Longdon), NO.24 (Shenstone), NO.25 (Stonnall) and NO.26 (Whittington). Unless explicitly stated below, our associations’ proposal is to retain the existing number of councillors and the existing ward boundary. In making an electoral forecast for the rural areas, the most significant uncertainty is the rate at which house building will take place at East of Lichfield Strategic Development Allocation (SDA) which lies alongside Streethay within Whittington ward. The Council’s electoral forecast for the East of Lichfield SDA site is to deliver 525 homes between 2013 and 2019 and a further 225 homes thereafter. Our association is sceptical about these forecasts due to the proximity to the route of HS2, which we expect will put off potential house buyers. For this reason our recom-mendation is based on deferring the allocation of a councillor until a substantial number of homes have been built and occupied.

In correspondence with BSARA, the Council has conceded that its electoral forecasts have not included any of the additional development sites which have been added via the most recent Local Plan amendments. This includes an additional 250 homes on the Fradley Strategic Devel-opment Area (SDA) site. In response to a Freedom of Information request the Council disclosed that the electoral forecast for Alrewas and Fradley is based on 525 homes being delivered between 2013 and 2019 with a further 475 homes being delivered after 2019 and up to 2029. Our association concurs with this forecast as we believe that the additional 250 homes are most likely to increase the delivery rate in Fradley beyond 2019. Accordingly we agree that the addition of an extra 250 homes on the Fradley SDA site, should not influence the electoral forecast for Alrewas and Fradley ward.

We have analysed the impact of our proposals at ward level, both in 2013 and 2019 – please refer appendix D1 [Appendix page 14]. No maps have been included as our proposals rely en-tirely on ward amalgamations with existing ward boundaries.


Amalgamate the wards of Bourne Vale and Fazeley, within existing boundaries, and simultaneously reduce the number of councillors for the combined ward of Bourne Vale and Fazeley from 4 to 3;

Amalgamate the wards of Little Aston and Stonnall, within existing boundaries, and simultaneously reduce the number of councillors for the combined ward of Little Aston and Stonnall from 3 to 2;

Amalgamate the wards of Whittington and King’s Bromley, within existing boundaries, and simultaneously reduce the number of councillors for the combined ward of Whittington and King’s Bromley from 3 to 2. Depending on the actual rate of house building on the East of Lichfield SDA site, an additional councillor can be added when the actual electoral imbalance justifies this. This is likely to be after the 2015 election;

Amalgamate the wards of Hammerwich and Shenstone, within existing boundaries, and simultaneously reduce the number of councillors for the combined ward of Hammerwich and Shenstone from 4 to 3.

We recognise that these proposals leave two wards (a) Longdon and (b) Colton and Mavesyn Ridware with a negative variance – i.e. a shortage of electors – of -13% and -17% respectively. As these single Councillor wards we believe that these imbalances are tolerable.


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3.6. Suggested warding arrangements for the East of Rugeley sub housing market area The only ward within the East of Rugeley sub housing market area is Armitage with Handsacre. There is a single Strategic Development Area (SDA) within this ward which is earmarked for 1,130 homes. Planning permission has already been granted for 600 homes and, according to a Freedom of Information disclosure by Lichfield District Council, 271 dwellings had been built up to 2013, with a further 409 earmarked for delivery by 2019, leaving the final 450 homes to be delivered between 2020 and 2029.

The electoral variance in the Armitage with Handsacre ward has been analysed and is presented in Table 2 below. The negative variance of 12% – i.e. shortage of electors – in 2013 is being brought into electoral balance as additional homes are built on the SDA sites. BSARA’s view is that it is likely that homes will be sold and occupied at a rate in excess of Council’s elec-toral forecast for this ward. We think it more than likely that the electoral imbalance in 2019 will be below 5% if 3 councillors are allocated to this ward. As the electoral imbalance is modest and is expected to reduce over time, our association’s recommendation is that the current number of councillors be retained and that the ward boundaries remain unaltered.

Table 2: BSARA analysis of the East of Rugely sub housing market area containing ward NO.2 (Armitage with Handsacre) only

BSARA recommend Councillors

Electorate Variance 1

Existing Councillors 2013 2019 2013 2019 2013

(47 Cllrs) 2019

(47 Cllrs) 3 3 3 4,548 5,229 -12% -8%

Notes: 1 - Both 2013 & 2019 variances calculated based on 47 Councillors. The 2013 variance is based on an average of 1,727 electors per Councillor and the 2019 variance is based on an average of 1,901 electors per Councillor


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3.7. Suggested warding arrangements for the North of Tamworth sub housing market area The only ward within the North of Tamworth sub housing market area is Mease and Tame. There is a single Strategic Development Area (SDA) within this ward which is earmarked for 1,000 homes. Planning permission has not been granted for any homes on this site. According to a Freedom of Information disclosure by Lichfield District Council, no dwellings are expected to be built on this SDA before the end of 2019. This is in accordance with the amended Local Plan. There is some doubt whether development on this SDA will be delayed for as long as the Council claims, because:

In December 2013 the Council received a planning application to build 165 homes on land North of Browns Lane Tamworth ( Ref 14/00018/OUTM ). This application is still under consideration.

The Council’s latest proposed amendments to the draft Local Plan includes Main Modification (MM4) which states that phasing is to be removed from Core Policy 6 (Housing Delivery). Phasing is the ability to stagger the delivery of homes over time. In effect the Council is stating that, as a matter of policy, it will have a housing trajectory which specifies a minimum rate of house building but no maximum.

In view of the Council’s reluctance to hold back housing delivery and the enthusiasm of Taylor Wimpey to press ahead, our association believes that it is very likely that a substantial number of homes will be built before 2020. However our association considers that the number of electors present at the date of the 2015 elections will be approximately 3,000 persons.

The electoral variance in the Mease and Tame ward has been analysed and is presented in Ta-ble 3 below. A negative variance of -14% in 2013 rises to -20% in 2019 – i.e. the shortage of electors is increasing. The increase in the variance is due to the average number of electors per Councillor rising due to house building elsewhere in the District. Our association would not normally recommend that an electoral imbalance of between -14% and -20% be tolerated. However, given the uncertainty over the electoral forecast for this ward and the electoral balance achieved elsewhere in the District – refer Graph A in section 3.2 above - our association recom-mends that the current number of councillors be retained and that the ward boundaries remain unaltered.

Table 3: BSARA analysis of the North of Tamworth sub housing market area containing ward NO.23 (Mease and Tame) only

BSARA recommend Councillors

Electorate Variance 1

Existing Councillors 2013 2019 2013 2019 2013

(47 Cllrs) 2019

(47 Cllrs) 2 2 2 2,985 3,040 -14% -20%

Notes: 1 - Both 2013 & 2019 variances calculated based on 47 Councillors. The 2013 variance is based on an average of 1,727 electors per Councillor and the 2019 variance is based on an average of 1,901 electors per Councillor


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4. Conclusion The impact of our associations proposals on electoral equality in 2013 and 2019 are summarised in table 4 below. BSARA would support further minor changes, e.g. moving polling districts or even smaller areas between wards, if these improve electoral equality and the amended boundaries are clear and logical.

Table 4: Summary of BSARA recommendation 2013 2019

Number of councillors 46 48

Number of wards 19 19

Size of electorate1 8 1,168 89,330

Average number of electors per councillor 1,765 1,861

Number of wards with a variance of more than 10% from the average2

7 3

Number of wards with a variance of more than 20% from the average3

1 1

Notes: 1 - Electoral size in 2019 is BSARA’s forecast – refer Appendix A for basis of estimate. 2 - Variance in 2019 – Comprises one 3 councillor ward with a variance of 11% and two single councillor wards with variances of 13% and 17% respectively. 3 - Ward of Mease and Tame may well be below 20%, if major residential development occurs before 2019, i.e. sooner than the council’s electoral forecast assumes.

BSARA recognises that legislation only requires the LGBCE to have regard to electoral changes which are likely to take place within five years of it making its recommendation. Our association hopes that in choosing between potential warding patterns, the LGBCE will:

Look more favourably on warding arrangements which guard against the upward drift in councillor numbers; a preference clearly expressed during the council size consultation.

Prefer warding arrangements which are less likely to lead to wholesale changes in future electoral reviews, because wards set on this occasion are incapable of accommodating the scale of the council’s house building ambitions. We note that there were approximately 74,000 electors in 1999 and that the Local Plan suggests that this is likely to grow to over 100,000 electors by 2029.

Recognise the difficulty in maintaining electoral equality over a five year period, when the electorate is expanding rapidly but councillor numbers remains fixed.

Please do not hesitate to contact me should you require any further clarification.

Yours sincerely

Bob Smith - Chairman Enclosures: The following page lists the appendices to this letter


List of Appendices Pages

A Forecasting the size of the electorate in 2019: Local Plan impact 2 -7

B0 Electoral Equality — Allocating 47 councillors pro rata to electors within existing wards / Allocation of wards to sub housing market areas

8

B1 Electoral Equality — Lichfield sub housing market area 9

B2 Map — Proposed boundary alterations for Chadsmead & Stowe wards 10

B3 Map — Proposed boundary alterations for St Johns’ & Boley Park wards 11

C1 Electoral Equality — Burntwood sub housing market area 12

C2 Map — Proposed boundary alterations for Chase Town & Chase Terrace wards 13

D1 Electoral Equality — Rural (incl. Fradley) sub housing market area

14

E Correspondence with Lichfield District Council concerning the consistency of the electoral forecast (2019) with the amended draft Local Plan

15 -21

Appendices [ Page 1 of 21 ]


BSARA forecast of the size of the electorate of Lichfield in 2019 - Appendix A

1. In troduction Set out in this appendix is BSARA’s estimate of the size of the electorate in 2019. We hope that we have followed the guidance for practitioners supplied by the LGBCE? We note that two 3 councillor wards currently have electoral imbalances of +28% and +19%. This shows that since the last electoral review, published in October 2000, the electorate in certain wards has grown at a much faster rate than the evidence presented to the LGBCE at that time.

2. Conformity to ONS/DCLG projections LGBCE guidance emphasises the need for electoral forecasts to be underpinned by sound evidence. It also says “we expect officers preparing forecasts to reflect the ONS subnational forecasts and to consider the impact of likely housing and economic development, expected migration into, out and within the authority and the expected difference between the number of adults in an areas population and the number of electors.”

The Council has prepared its electoral forecast based on the draft Local Plan which is currently being publicly examined. The Inspector examining the plan has determined that it should “significantly boost” the rate at which homes are delivered compared to the past. Subnational projections indicate what is likely to happen should past trends continue. As the Local Plan includes a deliberate strategy to build homes at a faster rate than ONS/DCLG projections of population/households suggest, it follows that inward migration will be accelerated and the adult population and the electorate will also expand faster than subnational projections indicate. BSARA concurs with the council’s decision to base the 2019 electoral forecast on the draft Local Plan rather than on ONS/DCLG projections.

We are aware that LGBCE guidance states “because of a tendency of local authorities to over-estimate population and electorate growth the Commission’s guidance recommends the use of ONS projections”. Lichfield district may be the exception which proves the rule. Figure I below shows that the actual rate of house building has consistently exceeded ONS/DCLG pro-jections. Figure II below shows that Lichfield District also exceeded house building targets set in the now defunct Regional Spatial Strategy for the West Midlands.

Figure I: Lichfield District’s cumulative rate of house building exceed all recent long-term household projections by the DCLG

Source: Estimated demand – DCLG subnational household projections for Lichfield District Actual supply –Dwelling count per council tax records for Lichfield District

(cont.)




Our association hopes the LGBCE is persuaded by this evidence. The Local Plan covers a period from 2008 to 2029, so it is a matter of judgement as to what the likely level of development will be in the first five years post adoption, i.e. 2014-2019. This is likely have a significant impact on the electoral forecast for individual wards, where a large scale residential development is expected in this time frame.

(cont.)

Figure II: Cumulative Completions & Housing Targets per Lichfield District Council

Source: Lichfield District Council – Table 7.1 Strategic Housing Land Availability Assessment, dated November 2013.Local Plan examination, core document reference CD2-23a




3. The relationship between housing development and the changing size of the electorate

Figure III below shows that there is an very strong relationship between the increase in housing and the increase in the adult population. Table 1 and Table 2 below show across the district both the number of adults per home and the number of electors per home are in the range of 1.8-2.0 persons per home. This suggests that the vast majority of adults say between 90% and 100%, are on the electoral roll.

Demographic data provided by the ONS shows that the natural change (births less deaths) for the District is approximately zero, so net inward migration drives the increase in the district’s population. Figure III below also shows that electorally significant growth in the adult population only took place in wards where large scale house building took place. This is because in many wards the population increase due to piecemeal development of small plots of land is being offset by falling occupancy of existing housing due to an aging population.

4. V acant dwellings factor The most recent statistic for Lichfield district is that in March 2008 3.2% of the District’s homes were vacant compared to 3,6% for the West Midlands and 4.7% for England. BSARA believes that the district continues to experience low levels of vacant dwellings. For electoral forecasting purposes the percentage of vacant dwellings can therefore be ignored

Figure III: Expansion of adult population vs. expansion in total dwellings Lichfield District (inter-censal period 2001-2011)

Source: ONS – Neighbourhood statistics. 2001 and 2011 census data




5. E lectorate per dwelling factor Across the District the number of adults (persons aged 18+) per dwelling is relatively stable at 1.8-2.0 persons – refer Table I below. The only significant distortion arising from adults living communally is in Bourne Vale ward – refer note 1 in Table 1 below and Figure 3 above.

Table I: Adults per dwelling per Census in Lichfield District

Adults per dwelling

A dults per dwelling

Wards 2 001 2011 Wards 2001 2011

All Saints 2.0 1.8 Mease and Tame 2.0 1.9

Boney Hay 1.9 1.8North of Tamworth sub housing market area 2.0 1.9

Chase Terrace 1.9 1.9 Alrewas and Fradley 1.9 1.9Chasetown 1.8 1.8 Bourne Vale1 2.4 2.8Highfield 2 .0 2.0 Burntwood Central 1.9 2.0Summerfield 1.8 1.8 Colton and Mavesyn Ridware 2.0 2.0Burntwood sub housing market area 1.9 1.9 Fazeley 1 .8 1.8Boley Park 1.9 1.8 Hammerwich 2.1 2.1Chadsmead 1.7 1.8 King’s Bromley 2.0 2.0Curborough 1.8 1.9 Little Aston 2.0 2.0Leomansley 1.8 1.7 Longdon 1.9 1.9St. John`s 1.9 1.8 Shenstone 1.9 2.0Stowe 1.7 1.7 Stonnall 1.9 1.9Lichfield sub housing market area 1.8 1.8 Whittington 1.9 1.8Armitage with Handsacre 1.8 1.9 Rural sub housing market area 2.0 2.0East of Rugeley sub housing market area 1.8 1.9 District Total 1.9 1.9Source: ONS – Neighbourhood statistics. 2001 and 2011 census data

1 – Adult population includes ordinary residents living in communal accommodation. The statistics for Bourne Vale ward will have been distorted by the Swinfen Hall Prison and Young Offenders Institution.

The average number of electors per dwelling is presented in Table II below. BSARA does not have access to 2013 dwelling count data, so we relied on 2011 census data. The net increase in dwellings from 2012 to 2013 was only 440 homes spread across the district This is too small to distort the average electors per dwelling (C) in Table II below. BSARA believes that the average of 1.8-2.0 electors per dwelling is reliable.

Table II: Electors per dwelling in Lichfield District

Sub housing market area

Electors 2013 (A)

Dwellings2011 (B)

Electors per dwelling (C=A/B)

Burntwood 2 1,041 10,023 2.1 City of Lichfield 25,820 14,280 1.8 East of Rugeley 4,548 2,293 2.0 North of Tamworth 2,985 1,484 2.0 Rural (incl. Fradley) 26,774 14,828 1.8 District Total 81,168 42,908 1.9 Source: 2011 Dwelling – ONS census data 2013 electorate –LGBCE website




6. Impact of the amended draft Local Plan Since LGBCE guidance is to rely on ONS/DCLG subnational projections, we have started by quantifying the extent to which the Local Plan intends to boost the number of households and adults compared to trend based projections. The 2008-based subnational household projection for Lichfield district says that there are expected to be 45,000 households in 2018 and 47,000 households by 2023, so interpolating to 2019 there are expected to be 45,800 households. The Council’s draft amended Local Plan sets housing delivery of 4,150 dwellings between 2013 and 2019, comprising an annual target 480*6=2,880 dwellings plus addressing a historic shortfall in house building since 2008 of 1,270 dwellings. By adding the Local Plan housing delivery target to the actual number of dwellings at the time of the 2011 census and the actual net completions subsequently, one arrives at a total number of 47,760 dwellings in 2019. This is 1,960 dwellings (47,760 - 45,800) higher than 2008-based projection for the district. At 1.9 electors per dwelling this suggests that the size of the electorate in 2019 will be 3,724 persons larger than the ONS’s 2008-based subnational population projection indicates. BSARA thinks this is electorally signifi-cant especially if much of this accelerated house building will take place in a handful of wards.

The council produced a revised electoral forecast in late January 2014 which states that there are expected to be 88,370 electors in 2019, an increase of 7,202 persons over the 2013 electorate. BSARA’s estimate is that, subject to the number of homes being built and occupied, following the amended draft Local Plan, the electorate will increase by 7,885 persons (4,150 homes * 1.9 electors per home). The discrepancy between the BSARA and Council estimates is only 9%, so BSARA has accepted the Council’s figure.

While BSARA was satisfied with the electoral growth at district level, we challenged the estimate for St John’s ward. Reports to Council, which have been supplied to the Planning Inspectorate, state that two additional Strategic Development Allocation (SDA) - Dean Slade Farm and Cricket Lane – are required to address a shortage in the 5-year housing land supply. Please refer Appendix E for details. The council cannot adopt its Local Plan unless a Planning Inspector judged it to be “sound”, which requires that the council is able to show that it has enough land allocated to meet the minimum requirement of 5-year supply of housing land plus a 5% buffer. Relying on evidence which the council supplied to the planning inspectorate, it would take 480 homes – roughly half of the 900 homes earmarked for the Dean Slade Farm and Cricket lane sites - to achieve a 5-year supply plus a 10% buffer, if the plan was adopted in 2014.

BSARA has therefore increased its electoral estimate for St John’s ward by 960 persons (480 dwellings * 2 electors per dwelling) to bring the electoral estimate into line with the Local Plan. We have made no adjustment for Alrewas & Fradley ward as we do not expect the 250 extra homes to affect the electoral forecast.

Table III: Assumed rates of housing delivery from Strategic Development Sites used to estimate electoral growth at ward level

SDA (Ward)

Comple-tions

2008-2013

Number of New homes 2013 to 2019

Approx Number of new homes 2019 to 2028

South of Lichfield SDA (St Johns) 0 450 0East of Lichfield SDA (Whittington) 0 525 225Fradley SDA (Alrewas & Fradley) 0 525 475East of Burntwood SDA (Chasetown) 0 350 25East of Rugeley SDA (Armitagewith Handsacre) 271 409 450North of Tamworth SDA (Mease & Tame) 0 0 1,000Source: L ichfield District Council – reply to a F reedom o f Information request to sta te the housing growth on Strategic Development Allocation (SDA) sites used to estimate the growth in the electorate.




7. Conclusion – adjustments required to electoral forecast produced by Lichfield District Council

Based on our analysis and the guidance from the LGBCE, our association has reached the fol-lowing conclusions about the council’s latest electoral forecast for the size of the electorate in 2019:

We accept the district level forecast;

We accept the forecasts for wards which do not contain Strategic Development Allocation (SDA) sites i.e. large residential development sites.

We accept the council’s forecast for the likely impact of SDA sites on the electorate in 2019 in all wards with the exception of St. John’s. Given the scale of house building on these sites, and the inherent uncertainty regarding the rate at which homes will be built and occupied, we think it would be prudent to defer the allocation of some councillors to wards, pending the actual impact on the electoral register.

We disagree with the council’s estimate for the size of the electorate in 2019 in St. John’s ward. We believe that the number of electors should be increased by 960 persons.


Appendix B0

Pro rata to2013

electorate

Pro rata to2019

electorateBurntwood 15 12.2 11.9City of Lichfield 17 15.0 15.0East of Rugeley 3 2.6 2.8North of Tamworth 2 1.7 1.6Rural (incl. Fradley) 19 15.5 15.7Total 56 47.0 47.0

2013 2019Burntwood 15 12 12 -3 -3City of Lichfield 17 14 15 -3 -2East of Rugeley 3 3 3 0 0North of Tamworth 2 2 2 0 0Rural (incl. Fradley) 19 15 16 -4 -3Total 56 46 48 -10 -8

Current Councillors

Current Councillors

NO.10 (Summerfield) 2 NO.2 (Armitage with Handsacre) 3NO.4 (All Saints) 2 Total East of Rugeley 3NO.5 (Boney Hay) 2 NO.23 (Mease and Tame) 2NO.6 (Central) 2 Total North of Tamworth 2NO.7 (Chase Terrace) 3 NO.1 (Alrewas and Fradley) 3NO.8 (Chasetown) 2 NO.11 (Colton & Mavesyn Ridware) 1NO.9 (Highfield) 2 NO.12 (Fazeley) 3Total Burntwood 15 NO.13 (Hammerwich) 2NO.15 (Boley Park) 3 NO.14 (King`s Bromley) 1NO.16 (Chadsmead) 2 NO.21 (Little Aston) 2NO.17 (Curborough) 3 NO.22 (Longdon) 1NO.18 (Leomansley) 3 NO.24 (Shenstone) 2NO.19 (St. John`s) 3 NO.25 (Stonnall) 1NO.20 (Stowe) 3 NO.26 (Whittington) 2Total City of Lichfield 17 NO.3 (Bourne Vale) 1

Total Rural (incl. Fradley) 19Total Lichfield District 56

Theoretical distribution of of Councillors (within current ward boundaries) across Sub Housing Market Areas

Councillorsreductions

2013Sub Housing Market

AreaCurrent

Councillors

BSARA's Councillor distribution

District ward

Allocation of current wards and councillors to Sub Housing Market Areas


Equitable Councillor distribution

Current Councillors

District ward

BSARA's recommended distribution of Councillor reductions acrossSub Housing Market Areas

Councillorsreductions

2019


Lichfield sub housing market area — Appendix B1BSARA Council Difference

2019 2019 2019Councillors 47 47 47Electors 81,168 89,330 88,370 -960 = 480 homes in St John's wardElectors / Councillor 1,727 1,901 1,880

BSARA suggested allocation of Councillors to wards (2013) in the Lichfield sub housing market area

Name of District ward

Existing number of

Councillors

Suggested number of

Councillors

Suggested Changes in Councillors

2013

Electorate 2013

(before boundary change)

FromSt John's

toBoley Park

FromStowe

toChadsmead

Electorate 2013(after

boundary change)

2013before

boundary changes

2013after

boundary changes

NO.15 (Boley Park) 3 2 -1 4,077 4,077 +18% +18%NO.16 (Chadsmead) 2 2 0 2,820 +750 3,570 -18% +3%NO.17 (Curborough) 3 2 -1 4,038 4,038 +17% +17%NO.18 (Leomansley) 3 3 0 5,574 5,574 +8% +8%NO.19 (St. John`s) 3 3 0 5,176 5,176 -0% -0%NO.20 (Stowe) 3 2 -1 4,135 -750 3,385 +20% -2%

17 14 -3 25,820 25,820 +7% +7%

BSARA suggested allocation of Councillors to wards (2019) in the Lichfield sub housing market area

Name of District ward

Existing number of

Councillors

Suggested number of

Councillors


2019

Electorate 2019


FromSt John's

toBoley Park

FromStowe

toChadsmead


boundary change)

2019before

boundary changes

2019after

boundary changes

NO.15 (Boley Park) 3 3 0 4,107 +1,500 5,607 -28% -2%NO.16 (Chadsmead) 2 2 0 2,832 +750 3,582 -25% -6%NO.17 (Curborough) 3 2 -1 4,068 4,068 +7% +7%NO.18 (Leomansley) 3 3 0 5,871 5,871 +3% +3%NO.19 (St. John`s) 3 3 0 7,228 -1,500 5,728 +27% +0%NO.20 (Stowe) 3 2 -1 4,409 -750 3,659 +16% -4%

17 15 -2 28,515 28,515 +0% +0%Explanation

Boundary Changes

Boundary Changes

Electoral Forecasts

(1) Variance in 2013 computed based on 1,727 electors per councillor.Variance in 2019 computed based on 1,901 electors per councillor.(2) The increase in the electorate between 2013 & 2019 is likely to be concentrated in St John's ward, +39%, vs. an average of +10% for the wards listed above.(3) Electoral inequality would be increased if full account was taken of new homes expected to be built by 2019, but which will not exist at the time of the 2015 election.(4) BSARA proposes that prior to the 2015 election the number of Councillors in this sub housing market area be reduced from 17 to 14 as indicated in the top table. Ward boundaries should be retained, except for approximately 375 homes (750 electors) who should be moved from Stowe to Chadsmead ward, as indicated on the map marked Appendix B2.(5) Dependent on the actual rate of house building in St. John's ward, a limited electoral review can be carried out to transfer approximately 750 homes (1,500 electors) from St John's ward to Boley Park ward as indicated on the map marked Appendix B3. At the same time an extra Councillor should be added to Boley Park ward.

Variance

Variance

Voters roll2013 Variance explained: Positive % = under

representation (too many voters)Negative % = over representation (too few voters)BSARA figures used for 2019 variances


Map data ©2014 Google -

To see all the details that are visible on thescreen, use the "Print" link next to the map.


https://maps.google.com/maps?ct=reset

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Leomansley ward current boundary in BLUE

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Chadsmead ward current boundary in RED

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Stowe ward current boundary in GREEN

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Proposed transfer of 375 homes (750 voters) from Stowe ward to Chadsmead ward

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Hallam Park development (150 homes). Not included in Local Plan

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A more logical boundary would be to follow Stafford road. Not part of current proposals.

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Appendix B2

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Dean Slate Farm Strategic Development Allocation (SDA) 450 homes

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South of Lichfield Strategic Development Allocation (SDA) 450 homes

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Cricket Lane Strategic Development Allocation (SDA) 450 homes

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Boley Park ward current boundary in ORANGE

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St John's ward current boundary in BLUE

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Proposed future reallocation of approximately 750 homes (1500 voters) from St John's to Boley Park wards. Timing dependent on rate of house building on SDA sites.

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Appendix B3

Burntwood sub housing market area — Appendix C1BSARA Council Difference

2019 2019 2019Councillors in District 47 47 47Electors in District 81,168 89,330 88,370 -960 = 480 homes (St John's ward)Average No. Electors / Councillor 1,727 1,901 1,880

BSARA suggested allocation of Councillors to wards (2013) in the Burntwood sub housing market area

Name of District wardExisting

number of Councillors

Suggested number of

Councillors


2013

Electorate 2013


FromChase Town

toChase Terrace


boundary change)

2013before

boundary changes

2013after

boundary changes

NO.5 + NO.6 (Boney Hay & Central) 4 3 -1 5,015 5,015 -3% -3%NO.9 + NO.4 (Highfield & All Saints) 4 3 -1 6,032 6,032 +16% +16%NO.8 NO.10 (Chasetown & Summerfield) 4 3 -1 5,836 -900 4,936 +13% -5%NO.7 (Chase Terrace) 3 3 0 4,158 +900 5,058 -20% -2%

15 12 -3 21,041 21,041 +2% +2%

BSARA suggested allocation of Councillors to wards (2019) in the Burntwood sub housing market area



Suggested number of

Councillors


2019

Electorate 2019


FromChase Town

toChase Terrace


boundary change)

2019before

boundary changes

2019after

boundary changes

NO.5 + NO.6 (Boney Hay & Central) 4 3 -1 5,075 5,075 -11% -11%NO.9 + NO.4 (Highfield & All Saints) 4 3 -1 6,110 6,110 +7% +7%NO.8 NO.10 (Chasetown & Summerfield) 4 3 -1 7,282 -1,650 5,632 +28% -1%NO.7 (Chase Terrace) 3 3 0 4,186 +1,650 5,836 -27% +2%

15 12 -3 22,653 22,653 -1% -1%Explanation

Boundary Changes Variance

(1) Variance in 2013 computed based on 1,727 electors per councillor.Variance in 2019 computed based on 1,901 electors per councillor.(2) Based on 47 District Councillors the optimal number of Councillors in the Burntwood sub housing market area is 12. The suggestion is to move from 7 wards represented by 15 Councillors to 4 wards represented by 3 Councillors each.(3) It is suggested that Chasetown and Summerfield wards are merged and that simultaneously approximately 450 homes (900 voters) are transferred to the adjoining Chase Terrace ward.(4) A Strategic Development Allocation for 375 homes exists within the current Chasetown ward. This is within the area which we suggest is transferred to Chase Terrace ward. Once these homes are occupied the enlarged Chase Terrace ward,electoral variances will be reduced further.(5) The increased electoral imact in 2019 is due to an assumed increase of 750 votes, or 375 homes delivered on the East of Burntwood bypass Strategic Development Allocation.

Voters roll2013

Electoral Forecasts


Variance explained: Positive % = under representation (too many voters)Negative % = over representation (too few voters)BSARA figures used for 2019 variances




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Summerfield ward existing boundaries in YELLOW

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Chase Terrace existing boundaries in RED

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East of Burntwood Bypass Strategic Development Allocation (SDA) 375 homes

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Chasetown ward existing boundaries in BLUE

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Proposed immediate reallocation of appromimately 450 homes (900 voters) from Chasetown to Chase Terrace. On completion of house building on the SDA site this is expected to rise to approximately 1650 voters

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Appendix C2

Rural (incl. Fradley) sub housing market area — Appendix D1BSARA Council Difference

2019 2019 2019Councillors 47 47 47Electors 81,168 89,330 88,370 -960 = 480 homes in St John's wardElectors / Councillor 1,727 1,901 1,880

BSARA suggested allocation of Councillors to wards (2013) in the Rural (incl. Fradley) sub housing market area



Suggested number of

Councillors


2013

Electorate 2013


None suggestedonly

amalgamarions

None suggested

onlyamalgamarions


boundary change)

2013before

boundary changes

2013after

boundary changes

NO.1 (Alrewas and Fradley) 3 3 0 4,667 4,667 -10% -10%NO.3 + NO.12 (Bourne Vale & Fazeley) 4 3 -1 5,263 5,263 +2% +2%NO.21 + NO.25 (Little Aston & Stonnall) 3 2 -1 3,845 3,845 +11% +11%NO.26 + NO.14 (Whittington & King`s Bromley) 3 2 -1 4,195 4,195 +21% +21%NO.22 (Longdon) 1 1 0 1,628 1,628 -6% -6%NO.13 + NO.24 (Hammerwich & Shenstone) 4 3 -1 5,645 5,645 +9% +9%NO.11 (Colton and Mavesyn Ridware) 1 1 0 1,531 1,531 -11% -11%

19 15 -4 26,774 26,774 +3% +3%

BSARA suggested allocation of Councillors to wards (2019) in the Rural (incl. Fradley) sub housing market area



Suggested number of

Councillors


2019

Electorate 2019


None suggestedonly

amalgamarions

None suggested

onlyamalgamarions


boundary change)

2019before

boundary changes

2019after

boundary changes

NO.1 (Alrewas and Fradley) 3 3 0 5,653 5,653 -1% -1%NO.3 + NO.12 (Bourne Vale & Fazeley) 4 3 -1 5,793 5,793 +2% +2%NO.21 + NO.25 (Little Aston & Stonnall) 3 2 -1 3,894 3,894 +2% +2%NO.26 + NO.14 (Whittington & King`s Bromley) 3 3 0 5,611 5,611 -2% -2%NO.22 (Longdon) 1 1 0 1,654 1,654 -13% -13%NO.13 + NO.24 (Hammerwich & Shenstone) 4 3 -1 5,712 5,712 +0% +0%NO.11 (Colton and Mavesyn Ridware) 1 1 0 1,576 1,576 -17% -17%

19 16 -3 29,893 29,893 -2% -2%Explanation


(1) Variance in 2013 computed based on 1,727 electors per councillor.Variance in 2019 computed based on 1,901 electors per councillor.(2) The increase in the electorate between 2013 & 2019 is likely to be concentrated in the wards of Alreswas and Fradley, +39%, and Whittington, +50%, vs. an average of +11% for the wards listed above.(3) Electoral inequality would be increased if full account was taken of new homes expected to be built by 2019, but which will not exist at the time of the 2015 election.(4) BSARA proposes that prior to the 2015 election the number of Councillors in this sub housing market area be reduced from 19 to 15 as indicated in the top table. All ward boundaries should be retained. The number of wards should be reduced from 11 to 7 through a series of ward combinations as indicated above.(5) At a future date and dependent on the actual rate of house building an additional Councillor can be added to the merged ward of Whittington & King's Bromley.

Voters roll2013

Electoral Forecasts


Variance explained: Positive % = under representation (too many voters)Negative % = over representation (too few voters)BSARA figures used for 2019 variances



Page 1

6th January 2014 Ms Diane Tilley, Chief Executive Lichfield District Council Frog Lane LICHFIELD WS13 6YY

Dear Ms Tilley

Electoral Review — Consultation on warding arrangements

I am writing on behalf of the Beacon Street Area Residents’ Association (“BSARA”) regarding the current consultation by the Local Government Boundary Commission for England (“LGBCE”) concerning warding arrangements.

On the 18/Oct/2013 the LGBCE asked Lichfield District Council to estimate of the number of electors, by ward, in 2019 and to supply this information by 26/Nov/2013. On 20/Dec/2013 the District Council advised BSARA to disregard a spreadsheet containing these estimates provided to the LGBCE on 10/Dec/2013. The consultation period is due to end on 03/Feb/2014. BSARA asks that this information be provided as a matter of urgency as it is likely to have a material influence in determining the most equitable allocation of councillors to wards.

Our Association’s principal interest is in ensuring an equitable distribution of Councillors between the urban centres of Lichfield City and Burntwood and additionally to ensure an equitable distribution between urban vs. rural wards. BSARA has reviewed the Local Plan, including the “Main Modifications” that the Environment & Development (Overview & Scrutiny) Committee will be considering on 07/Jan/2014. We have concluded the Council’s proposals are likely to have a material influence on the number and distribution of electors in the six years from 2013 to 2019. This arises for the following reasons: Analysis by the DCLG has shown that in Lichfield District, 94% of new households are

formed by net inward migration. This is because the rate of household formation due to natural change (births minus deaths) is negligible. Therefore the expansion of the District’s population aged 18+ is highly correlated to the rate at which new homes are built.

The District Council’s draft Local Plan proposes to “significantly boost” housing supply and also to eliminate an under delivery of homes in the period from 2008 to 2012. BSARA estimates that the effect of the Plan, including the latest “Main Modifications” is to require that 4,850 new homes are delivered over the six years from 2013 to 2019. This is large enough to influence warding arrangements because a large proportion of the homes will be delivered in a small number of wards.

The effect of the latest “Main Modifications” to the Local Plan has been to front load the delivery of homes in the period 2013-2019 and to further concentrate the delivery of new homes in urban wards or in rural wards which lie alongside urban areas.

BSARA has reviewed the information supplied to the LGBCE for reasonableness and for broad consistency with the draft Local Plan. (cont.)


Lichfield District Electoral Review — Consultation on warding arrangements

Page 2

The results have been summarised in the table below. It is clear that the information supplied to the LGBCE is incompatible with the Council’s Local Plan. Specifically the information supplied to the LGBCE significantly understates the likely increase in the number of electors and also distorts the distribution of new electors across the District.

The Council says that in 2013 the District had 81,168 electors and 42,294 dwellings, i.e. an average of 1.92 electors per dwelling. Across the sub housing market areas of the District the number of electors per dwelling varied between 1.86 and 2.01.

Since the construction of new homes is the principal driver behind the increase in the size of the electorate, one might expect that the electorate would expand most rapidly in areas earmarked for large scale residential development. The table below highlights the deficiencies in the data supplied to the LGBCE. The Council appears to be suggesting that 100 new home in Lichfield City will contain 50 electors while the same number of new homes in rural wards will contain 170 electors. There does not appear to be any logical connection between the Council’s distribution of new homes and the Council’s distribution of new voters.

Data supplied by Lichfield District Council to the LGBCE is incompatible with the latest draft of the Local Plan

(A) – Supplied to LGBCE : estimate of change in size of the electorate (B) – Forthcoming public consultation : Implied delivery rates for new homes contained in latest modifications to draft Local Plan


Increase in number of electors1 2013-2019

Increase in homes per draft Local Plan2

2013-2019

Average number of electors per

new home A B C=A/B

Burntwood 977 4.6% 969 8.6% 1.0 City of Lichfield 1,161 4.5% 2,173 15.6% 0.5 East of Rugeley 448 9.9% 477 21.1% 0.9 North of Tamworth 66 2.2% 0 0.0% N/A Rural (including Fradley) 2,126 7.9% 1,231 9.2% 1.7 District Total / Average 4,778 5.9% 4,850 11.5% 1.0 Legend: 1 – Per email dated 10/Dec/2013 from Lichfield District Council to the Local Government Boundary Com-mission for England .Reduced proportionately from 5,577new electors over 7 years (2013-2020) to 4,778 new electors over 6 years (2013-2019) BSARA understands that this evidence has now been withdrawn. 2 – BSARA’s estimate of the impact the latest Local Plan modifications published by Lichfield District Council shortly before Xmas, i.e. 501 dwellings per annum (10,030 dwellings over 21 years) plus a historic backlog of 1,405 homes to be eliminated within the first five years i.e. by 2019.

BSARA expects that, in the period 2013-2019, between 1.5 and 2 electors will be added for each new home. BSARA’s believes that the Council’s Housing Delivery Policy (CP6) will accelerate inward migration and - over the period 2013-2019 - expand the electorate by between 7,300 and 9,700 persons. This is 66-100% larger than the data supplied to the LGBCE on 10/Dec/2013. BSARA hopes the Council will act swiftly to remedy this unsatisfactory situation.

Yours sincerely

Bob Smith - Chairman cc: Tim Bowden, Review Manager, the Local Government Boundary Commission for England



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29th January 2014 Ms Diane Tilley, Chief Executive Lichfield District Council Frog Lane LICHFIELD WS13 6YY

Dear Ms Tilley

Electoral Review — Consultation on warding arrangements — Local Plan consistency with ward level electoral estimates

My previous letter dated 6th January 2014 expressed concern about the quality of the initial electoral estimate that Lichfield District Council supplied to the Local Government Boundary Commission for England (“LGBCE”). On 21st January 2014 I confirmed by email that the Beacon Street Area Residents’ Association (“BSARA”) considered the revised district level electoral forecast to be as broadly consistent with the proposed level of housing development suggested in the Local Plan. I noted that BSARA was awaiting a response to a Freedom of Information (“FOI”) request to determine whether electoral estimates at ward level were also consistent with the Local Plan.

BSARA has now reviewed the District Council’s reply to our FOI request. Our association considers that – with the exception of St. John’s ward – the electoral changes / number of new homes are within a range that can be considered broadly consistent with the Local Plan. We did not raise main modifications MM14 because, while the electoral estimate is inconsistent with the Local Plan, the 250 homes at Fradley are unlikely to contribute to an electoral imbalance of significance in the Alrewas and Fradley ward.

In reaching this view regarding St. John’s ward BSARA has applied the criteria used by the LGBCE to assess the significance of an electoral imbalance. The LGBCE appear to use the fol-lowing review bands:

A single ward with an electoral imbalance of more than 30% requires the LGBCE to consider the need for an electoral review.

Wards with electoral imbalance of > 20.5% are coded RED on the LGBCE spreadsheet which presumably implies that the imbalance should be addressed during the electoral review.

Wards with electoral imbalance of > 10.5% but < 20.5% are coded YELLOW on the LGBCE spreadsheet, which presumably implies that this imbalance should be noted during the electoral review.

Our reservations about St. John’s ward arise from the Council’s claim that the Deans Slade Farm and Cricket Lane Strategic Development Allocations (SDAs) are needed to “achieve a 5-year housing supply in the early stages of the plan”. (cont.)


Electoral Review — Consultation on warding arrangements — Local Plan consistency with ward level electoral estimates

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The Council’s FOI response, Part (iv) – refer attachment Appending A -, says the electoral forecast for St Johns’ ward is based on the South of Lichfield SDA delivering 450 homes over the period 2013-2019, while Deans Slade Farm and Cricket Lane SDAs will not contribute any additional homes in this period. Hence the electoral forecast and the Local Plan appear to be inconsistent. The location of the SDAs are indicated on the attached map – refer Appendix B.

Background papers considered by the Oversight & Scrutiny Committee on 7th January and considered by the full Council on 28th January state that additional sites are required so that the District “can achieve a 5 year housing supply in the early stages of the plan”. The 7th January report stated in paragraph 2.16 about Deanslade Farm and Cricket Lane SDAs that "Both sites are deliverable in the short term, assisting the Council in the crucial need to achieve a 5 year supply ....". A report to Council dated 28th January in paragraph 3.10 stated "The District Council, against an increased housing requirement, currently only has a 3.31 year supply and incorporat-ing the submitted Plan this increases to 4.52 years – therefore it is essential that we are able to deliver homes in any new allocation within a 5 year window." (underlining added). The Council expressly proposes to rely on the Deans Slade Farm and Cricket Lane SDAs to address this shortfall. If Deans Slade Farm and Cricket Lane increase the housing supply equivalent to one year of demand then 480 homes / 960 voters would be added in the period 2013 to 2019. The electoral imbalance in St. John’s ward would consequently increase from +11% to +28%, with 47 District Councillors. The inclusion/exclusion of Deans Slade Farm and Cricket Lane SDAs is therefore of electoral significance in this ward. BSARA suggests Local Plan modifications MM12 (Cricket Lane), MM13 (Dean Slade Farm) & MM14 (Fradley) be treated consistently in calculat-ing the electoral impact over the period 2013-2019.

The District Council appears to have become more optimistic about the housing delivery rates of existing SDAs. In July/2013 the Council told the Examination in Public that the existing SDAs could deliver homes at a rate of 200 dpa, or 1,000 homes over five years. This delivery rate was also used in the latest 5-year housing land supply – refer paragraph 7.33 Strategic Housing Land Availability Assessment dated November 2013. However by the time the District Council prepared its electoral forecasts for the LGBCE in January 2014 it had increased its estimate to 376dpa, or 1,880 homes over five years for the same SDAs. This higher level of housing delivery is consistent with the views expressed at the Examination in Public by the companies who will be developing these sites. Half a years supply corresponds to 240 homes, so it may be that the 5-year housing land supply shortfall (2012-2017) was temporary and may have been eliminated by the Council’s higher delivery rates for the current SDAs. If so, additional sites will still be required but not necessarily to address a supply shortage in the early stages of the plan.

Could you please confirm whether the District Council concurs with BSARA’s analysis and whether the District Council agrees that consistent assumptions should be used to estimate the electoral impact of SDA sites over the period 2013-2019 as those which are used to compute the adequacy of the 5-year housing land supply, where these periods overlap substantially?

Yours sincerely

Bob Smith - Chairman cc: Tim Bowden, Review Manager, the LGBCE 1 3.3 years supply, excludes any delivery of homes from any SDA sites 2 4.5 years supply includes delivery of homes from existing SDA sites and excludes the impact MM12 (Cricket Lane), MM13 (Dean Slade Farm) & MM14 (Fradley)


Appendix A Freedom of Information response from Lichfield District Council Net number of new homes between 2013 and 2019 used to estimate the number of additional electors in St. Johns’ ward

Legend: BLACK – Freedom of Information request BLUE – Response from Lichfield District Council

N.B. The Council’s response has been truncated to show house building rates in r elation to St. John’s ward only.

(iii) Can the District Council please provide a breakdown, by ward, showing how the housing tar-get o f 9 ,600 homes will be de livered? It wo uld be useful if the follow ing date ra nges cou ld be used: (a) start of Plan (2 008) to start of LGBCE review period (b) L GBCE review period (2013-2019) and (c) end of LGBCE review period to end of Plan (2028). Please note that the following figures are approximate and based on information published with-in the Strategic Housing Land Availability Assessment (SHLAA 2013). Data relates to the sub-mitted Local Plan Strategy and do not include sites proposed as Main Modifications to the Plan. The data set includes:

All Strategic Development Allocations and broad Development Locations within the sub-mitted Local Plan Strategy. Sites are considered to come forward in line with the trajecto-ries contained within HD-58.

Figures do not include windfall allowance of approx 30 per annum.

FOI Question (iii) (A) (B) (C)

Ward

Completions 2008-2013 (gross)

Number of New homes 2013 to 2019

Approx number of new homes 2019 to 2028

Lichfield - St John's 207 624 0 (iv) Can the Dist rict Council p lease provide the sam e information requested in (iii) above, but only listing homes to be delivered on sites listed as Strategic Development Allocations (SDAs)? FOI Question (iv) (a) (b) (c)

SDA (Ward)

Completions 2008-2013 (gross)

Number of N ew homes to 2019

Approx Nu mber on ne w homes to 2028

South o f L ichfield SDA (St Johns) 0 450 0

Conclusions regarding St. John’s ward:

The electoral estimate is based on 624 homes being delivered with 174 being outside Strategic Development Allocations (SDAs) and the entire allocation of 450 homes within the South of Lichfield SDA being delivered;

The electoral estimate assumes that no new homes are delivered from either Deans Slade Farm SDA (Local Plan Main Modification MM13) or Cricket Lane SDAs (Local Plan Main Modification MM12) in the period 2009-2013.



Appendix E

Reply by email from Lichfield District Council dated 10 January 2014

From: Brown, John [mailto:[email protected]] Sent: 10 January 2014 13:42 Subject: NUMBER OF MEMBERS OF DISTRICT COUNCIL AND REVIEW OF WARDS Dear Mr Smith,

Further to the e-mail dated 6th January 2014 sent to you by the Chief Executive I am writing to update you on the current situation. The District Council are currently awaiting confirmation from the Local Govern-ment Boundary Commission for England on the approach to take on the Warding arrangements and on a possible extension of the consultation period until the end of February 2014.I have been informed that confirmation of the situation should be forthcoming at the start of next week and you will be contacted once a response is received.

John G.Brown

Reply by email from Lichfield District Council dated 14 January 2014

From: Brown, John [mailto:[email protected]] Sent: 14 January 2014 11:36 Subject: NUMBER OF MEMBERS OF DISTRICT COUNCIL AND REVIEW OF WARDS Dear Bob,

Further to your e-mail dated 10th January 2014 I am writing to inform you that representatives of the Local Government Boundary Commission for England are going to meet a Working Group of Members and Officers on Thursday 16th January 2014 in order to discuss the way forward. I will endeavour to keep you informed.

John G.Brown



Appendix E

Reply by email from Lichfield District Council dated 07 February 2014

From: Brown, John [mailto:[email protected]] Sent: 07 February 2014 12:45

Dear Mr Smith,

I refer to your letter dated 29th January 2014 addressed to the Chief Executive. The points that you have raised have been considered in detail and I would respond as follows.

The housing projections which were used as part of the methodology for the figures supplied to the Local Government Boundary Commission for England were based on information within the submitted Local Plan Strategy and it’s supporting evidence base. At the time of providing this data for the Boundary Com-mission, and responding to your Association's Freedom of Information request, the proposed main modifi-cations to the Local Plan Strategy to allocate two additional sites to the south of Lichfield (within St Johns Ward) were progressing through the District Council’s committee cycle with a formal decision not having been made by the Council at that stage. Additionally these sites are to be considered through the ongoing examination of the Local Plan Strategy. As such to include these sites within the figures provided at that stage would have been premature of a formal decision being made by the Council and through the Local Plan Examination. The figures provided do include housing from the Strategic Development Locations which have been found sound by the Inspector within his Initial Findings report. In the response to the Freedom of Information request it was made clear that the figures provided did not include the sites pro-posed as Main Modifications to the Plan.

With regards to the phasing of the Strategic Development Allocations which are proposed as Main Modifi-cations to the Local Plan, appendix A of the committee papers include Concept Statements for these sites which include an ‘assumed delivery’ trajectory of the houses from these sites. Of these sites only Cricket Lane is assumed to deliver homes within the Boundary Commission timescales. As was established at the hearing sessions and through the Main Modifications, phasing has been removed from the Local Plan Strategy, as such the two sites proposed as Main Modifications could come forward within the next five years or play an important role in maintaining a five year supply across the plan period.

As I am sure you will appreciate the District Council has been undertaking a considerable amount of work using all information available to arrive at a decision on what submission it wishes to make in response to the consultation exercise that is currently underway. A final decision on the submission will be made at a meeting of the Council on 24th February 2014.It is for your Association to decide if it wishes to make a submission and if it does to determine the basis of that submission.

John G.Brown


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