This letter was published retrospectively on 16 December 2021

Dear Ed, 

Office of National Statistics’ Population and Household Projections for Coventry

It is now quite apparent to us that despite your prompting, ONS have no intention of ‘working with us’ as envisioned by you in your personal letter to me of 10 May 2021, nor of complying with your request to ONS that they do this (your letter to ONS of the same date).  I have previously reminded them of the wording of your letter and informed them that we would be assisted in the work by Professor Tony Champion and called for suitable dates. Following your recent prompting, James Robards from ONS contacted me and I spoke to him personally. He explained that their work on the review was already complete and would be published later this week. I asked for an outline of the work undertaken and a general description of the conclusions. He said that he was not authorised to reveal this at that time, but would speak to those above him and come back to me.  

That was over a week ago. I have heard nothing further from ONS, until yesterday when I learned from Keith Kondakor, a mathematician and a Green Party Councillor on Nuneaton & Bedworth Council who contributed evidence to the OSR’s review, that he had attended a preliminary meeting called by the ONS last week. He and I have been invited to ONS’s presentation to be held on Thursday this week, 29th July.  

It is now apparent to me that the general issue of flawed population projections caused in the main by failure to reflect the true figure of students returning to their home country upon completion of their studies was first raised in a letter dated 7th November 1916 to ONS from James Pitman, Managing Director of an institution named ‘Higher Education UK and Europe’. It is co-signed by others responsible for higher education in the UK. The letter calls for a review of ONS figures for international students remaining in the UK upon completion of their studies.  

That letter referred to David Cameron’s former home affairs adviser revealing in a letter to The Daily Telegraph that the Coalition Govt. were fully aware that official figures on students overstaying their student visas were ‘absolute rubbish’.  

On the 21st July 2017 the House of Lords Economic Affairs Committee found that ‘existing emigration data is wholly inadequate’. ‘Increasing reliance has been placed on migration statistics to formulate and judge Government policy. Longstanding and widely identified problems with the International Passenger Survey mean that it cannot bear the burden placed upon it and cannot be relied upon to provide accurate estimates of net migration. The current approach cannot calculate with any precision how many students stay at the end of their degree. 

 You duly conducted an inquiry in to the quality of student migration estimates and found ‘that they do not bear the weight put upon them in public debate’. You considered that ‘these estimates should add clarity on the pattern of student migration ….. instead of which they create doubts and fail to present a complete and coherent picture’. You found that they ‘should have been described as ‘experimental’ and directed that in future ONS should make clear these estimates should be treated with caution. 

 Did they follow that directive from you?  What I do not understand is why you cannot direct ONS to revise their figures so as to reflect in cases such as these the Home Office figures for students returning home on completion of their studies and other local administrative data. Surely the objective should be to correct figures which are clearly flawed and to replace them with more reliable figures so as to limit the damage caused by them as soon as possible. Simply to underline that they should be treated with caution is surely not what either arms of Government or members of the public are looking for. Unless the flaw or flaws which led to the false or unreliable estimates are identified and corrected they are likely to be repeated as appears to be the case here. 

On the 3rd July 2017 in an Email to Keith Kondakor, Tim Pateman, a senior researcher in Population Projections for ONS made a number of concessions: 

  1. There is difficulty in capturing the out migration of students.
  2. Uncertainty is growing around these estimates as we move away from the Census year.
  3. International migration is the biggest contributor to uncertainty for Coventry. 

The Home Office at that time carried out 2 calendar year checks which established that, contrary to ONS’s  earlier assertions, c.96% of foreign students returned home on completion of their studies. Despite this ONS has refused to adjust their figures. 

It is not clear to me that either ONS or you fully appreciate the full consequences of that refusal. At the two seminars (by virtual means)  on the projections which OSR kindly invited CPRE Warwickshire and others to, held on 19 and 26 February 2021, we were all asked for what other purposes these population projections were being relied upon and how errors affect planning. Responses given listed the consequences – loss of land to housing, including Green Belt; incorrect projection of needs for the health service; excessive provision in school places; incorrect calculations of grant to local authorities where these are based on projections of the local population in different age groups. In the case of Coventry these consequences are now apparent. 

When Merle Gering of Keep Our Green Belt Green first approached ONS and later when Andy Street, the Mayor of the West Midlands approached ONS in 2020,  in marked contrast to the concessions made by Tim Pateman above there was a refusal to accept any criticism of the figures. ONS declined to place weight on locally-collected data which showed a different picture from that projected by ONS’s methodologies. 

That the local data for Coventry was much sounder than ONS’s projections has been demonstrated by the work undertaken by Merle Gering and Cllr Kondakor. For example, the ONS project that there will be 30% growth in 20-29 year olds by 2030, and this 30% figure also appears as the projected growth for Coventry as a whole over the period. The local data points to a very different conclusion, low growth, not higher than for any other urban area in the Midlands. 

We do not yet know what form ONS’s review has taken but it seems improbable that they have yet revised their methodology to meet detailed criticisms.  

I want to emphasise how much we appreciate the courtesy and attention which you and your staff gave to our case, but cannot disguise the disappointment and frustration at your apparent inability to be more decisive. I do not see how you can be an effective regulatory authority without the ability to change the methodology employed by ONS or even caution those government departments and local authorities who have historically relied on their figures.  

In the realisation that the new Census figures will determine how accurate or inaccurate the ONS projections have been we wrote to ONS on 30th June 2021 asking to be informed of the provisional Census figures for Coventry as soon as they become available. This is because several planning applications for housing on what was Green Belt land are near to the grant-of-permission stage. They are on land which was removed from the Green Belt by the local planning authorities on the the sole ground that the ONS projections for population and household growth of Coventry were sound and reliable – and to the planning authorities immutable. 

We have received a letter from Sir Ian Diamond dated 15th July 2021 which appears to be a rebuff. The Census Coverage Survey is now complete and he explains the process whereby they will assess the number of those who did not take part. ONS staff will consult with local authorities and anyone nominated by them. The provisional figures will never be published and on the face of it will not be shared with us. 

 I am sure that you can understand that this is quite unacceptable. Our sole concern is that the true figures now take the place of wholly unsound projected ones with suitable adjustments made if necessary. We have suitable expertise available to assist.  Coventry City Council has a huge financial interest in the ONS’s high projections for the city’s population remaining in use. These inflate the level of government grant payable to the City Council and are the justification for its aim to grant permission on greenfield sites for private sector housing in the higher Council Tax bands. Achieving more higher tax-band housing to bring in more income is an aim of the City Council.  

We believe that ONS should withdraw its current population and household projections for Coventry and make a new and informed set of projections, using the 2021 Census and drawing on the local data sources which Merle Gering and Keith Kondakor have assembled and continue to monitor. May we ask that the Office of Statistics Regulation urges this course of action now on ONS? 

Yours sincerely  

Sir Andrew Watson 

Chairman, Campaign to Protect Rural England Warwickshire Branch


Related Links:

Ed Humpherson to Sir Andrew Watson: Response to OSR’s review of population estimates and projections