‘Objectively assessed need’ or subjectively guessed greed? The FOAN

The Government, its planning inspectors and Cornwall Council’s planners make great play of meeting the so-called ‘full objectively assessed need’ (FOAN) in calculating how many houses should be built over the 20 year period of the Local Plan. Cornwall Council is told to base this calculation on the regular population and household projections produced by the Office for National Statistics (ONS) and the Department of Communities and Local Government (DCLG). There’s only one small drawback. The projections are seriously flawed and inaccurate.

Along with others I’ve been pointing out for some time now that these projections consistently over-estimate population and household growth in Cornwall. This matters because the housing target is then over-estimated in turn on the basis of the projections. It’s been pointed out here and here and here.

In addition to projections of future growth, the ONS produces annual mid-year estimates (MYEs) as well as the decennial census. Things get worse. Because over the course of the 2000s the MYEs, supposedly a factual record of the ‘real’ population in June each year, was also discovered to have exaggerated Cornwall’s population growth. And by a quite a wide margin – 13.6%.

Apart from a handful of councillors, both elected representatives and unelected planners at County Hall have united in choosing to ignore this evidence, declining to use it or tell their officers to do so in order to produce a more robust case for a lower housing target. But it’s not just campaigners in Cornwall raising questions about the accuracy of ONS data. Even the Treasury select committee chairman, Andrew Tyrie, has recently accused the ONS of producing ‘poor quality data’. If Cornwall’s councillors and their officers refuse to listen to local campaigners perhaps they’ll take note of the growing criticism of ONS data.

Very occasionally, tucked away in some obscure background paper, we meet a passing reference to discrepancies between official estimates and actual outcomes. For instance, in 2012 Peter Brett Associates’ ‘Housing requirement for Cornwall’ paper noted there was a ‘discrepancy between census data and MYEs’ (p.9). They found this ‘interesting’, but rapidly moved on, concluding that ‘it is not yet possible to provide a credible alternative’.

The Council has therefore been aware of the discrepancy between official figures and actual outcomes since 2012 but has done nothing to provide that ‘credible alternative’. This is despite government planning guidance that explicitly ‘expects that … projections are then tested against local data and understanding’ (Planning Policy Advisory Committee agenda, Nov 17th, 2015, appendix 1, p.2).

Instead, when challenged, the Council’s planners have resolutely refused to engage with the discrepancy. They respond in three ways. First, they claim projections are sometimes over-estimates of actual growth, sometimes under-estimates. Not true. All five ONS population projections since 2004 have consistently over-estimated growth. Not a single one has under-estimated it (see Table 1 below).

Second, rather bizarrely they argue that as the inputs to the computer model that underlies the projections are correct then the outcomes must also be right. Even if they’re demonstrably proved to be wrong! Furthermore, in a fine example of Alice in Wonderland logic, critics of the projections are dismissed because they haven’t used this same computer model. And if that doesn’t work, they sagely point out that the projections are not intended to be forecasts. So presumably it doesn’t matter if they’re wrong. Except that by then the damage is done, as the never-sending spiral of population growth is given another spin.

Finally, they deny that Cornwall is unusual, in that such discrepancies are no larger than in other local authorities. This is also untrue.

Let’s restate the argument yet again, focusing just on the ONS projections and MYEs. (The DCLG household projections have overestimated growth even more wildly.)

Here are the projected population totals for 2014, the most recent year with a MYE, compared with the actual estimate for that year.

Table 1: Population projections for 2014 compared with actual outcome

Projected population (000s) MYE 2014 (000s) Difference
2004 base 568 545 +23
2006 base 574 545 +29
2008 base 556 545 +21
2010 base 553 545 +8
2012 base 547 545 +2

Even the most recent projections retain this built-in over-estimate.

Why do all these projections so consistently overestimate population growth? Population changes as the result of the combination of two factors. The first is the difference between births and deaths (natural change). The second is the difference between inwards and outwards migration (net migration). Natural change in Cornwall can be accurately gauged and is currently negative (i.e. left to natural change alone the Cornish population would fall). But, as can be seen in Table 2, the projections consistently over-estimate net migration.

Table 2: Net-migration in ONS projections compared with actual net-migration for 2010-11

projected net-migration p.a. MYE net-migration p.a.
2006 base +6,600 +3,900
2008 base +4,800 +3,900
2010 base +5,000 +3,900

The Council’s planners assert that such projections are based on trends. This is not the case. A trend line, whether based on five years or ten years, would produce a lower net migration figure.

The current over-estimate of up to 1,000 net migrants a year is a minimum. This is because MYEs also have a record of consistently over-estimating net migration to Cornwall. Let’s compare the originally published MYEs for 2001-10, supposedly a factual record of population totals and certainly taken to be so by Cornwall’s planners at the time, and the same series as later revised in the light of the 2011 census.

Table 3: MYEs of annual net-migration, original and revised, 2001-10

original estimate revised estimate
2001-02 +7,000 +6,100
2002-03 +6,200 +5,400
2003-04 +4,800 +4,600
2004-05 +5,200 +4,500
2005-06 +4,600 +3,700
2006-07 +5,300 +4,700
2007-08 +3,300 +3,500
2008-09 +2,500 +2,000
2009-10 +4,500 +3,700
totals +43,400 +38,200

So we must assume the current over-estimate of up to 1,000 a year is a minimum as there is no credible reason to assume this inbuilt bias and the exaggeration of migration into Cornwall has been resolved.Over-estimating net migration by up to 1,000 a year may not sound much, but it amounts to a discrepancy of 20,000 over the 20 year plan period. That’s the equivalent of 8-10,000 houses, which are being added unnecessarily to the housing target because of the structural flaws of the ‘FOAN’. Cornwall Council continues to deny these flaws are a major issue, let alone make use of them in their submissions to the Government. This is one of the reasons why the Government inspector last year found himself knocking at an open door when he ‘asked’ the Council to add 5,000 houses to an already grossly inflated target.

All this leads to two questions.

1) In official datasets why is there an inbuilt over-estimate of net migration to Cornwall?


2) Why do the planners and the vast majority of councillors at Cornwall Council continue to ignore this?

The answer to the first question lies in the methodology employed by the ONS.

For the answer to the second question, we must recognise that the ‘FOAN’ is a device that is in fact part of a game, disguising strategic planning as merely a ‘technical’ issue that provides for ‘need’. It’s not. It’s part of a process that sets out to justify the ongoing transformation of Cornwall through a high housing/population growth regime. It’s a smokescreen for meeting external demand and the need for profit by developers rather than anything much to do with ‘local need’. Furthermore, it’s nothing new. This policy has been effectively pursued since the 1960s under various guises.

High population growth, almost three times the rate in England, over that period has not solved Cornwall’s economic problems. Far from it. And it’s piling up environmental and cultural issues. It’s time to recognise that this process is not technical at all; it’s political. A radical change of mind-set is long overdue in order to challenge current unsustainable policies and the spurious data that legitimate them. That shift – to a properly sustainable strategy for Cornwall – can only result from political change, not quibbling over technical matters, which is exactly what they want us to spend our energy doing.