Memorandum by Westminster City Council
INTRODUCTION AND
BACKGROUND
1. Westminster City Council is pleased to
respond to the request from the Lords Economic Affairs Committee
to set out our concerns in relation to impacts of migration and
in specific the impact caused by the use of inadequate population
estimates and projections and the implications for the distribution
of funding to English local authorities.
2. International migration levels to Westminster
and surrounding boroughs have been traditionally significant,
and recently published ONS figures, covering the years 2001-06
show Westminster as having the highest volume of international
migration per 1,000 population in England & Wales. Westminster
is uniquely placed therefore, to comment on the problems caused
by non-robust national migration statistics on the resources of
local authorities and the consequent impacts on the benefits of
international in-migration.
3. Westminster has been at the forefront
of research in a growing consensus within the public sector that
flaws in national migration figures and the current definitions
and formulae used to drive local authority, police and health
service resources are so significant that they threaten mainstream
services and community cohesion.
4. It should be noted that although there
are direct impacts of migration to local authority areas such
as the pressures to the private rented sector, overcrowded accommodation,
rough sleeping, increased cleansing and refuse collection, the
indirect impacts are greater still. Indirect impacts are those
caused by the lack of accurate government management data. In
the case of population estimates this is extremely urgent and
will cause severe detrimental impacts in the forthcoming three-year
grant settlements if not recognised.
What are the numbers and characteristics of recent
immigration? How can data on immigration be improved? How far
has inadequate data affected public policy?
5. Annual population estimates and projections
for local authority and NHS areas use the 2001 census as a baseline
and adjust for estimated annual changes in the number of births
and deaths as well as the impact of internal migration within
the UK and international migration to and from overseas. It is
the distribution of migration patterns and their impact on service
pressures which is of significant current concern to many local
authorities including the City of Westminster.
6. On 24 April the Office for National Statistics
published the initial conclusions for its Improving Migration
and Population Statistics (IMPS) study and released indicative
changes to the previously issued population estimates for 2001
through to 2005 for each local authority area.
7. Revisions to the 2004-based sub-national
population projections was released on 27 September in the light
of this new methodology and these are expected to be used as the
primary population sources for the three year CSR 07 local government
finance settlement which will be published in December.
Use of population estimates and projections to
distribute government funding
8. In addition to the £26bn allocated
through the revenue support grant system population data is also
used to distribute the majority of local authority specific grants
for social care services (eg children's services, carers' grant,
supporting people). It also influences the targeting of regeneration
funding via the Neighbourhood Renewal and Safer Stronger Communities
funds (now being delivered via local area agreements) and is the
denominator for the primary deprivation indicator used to distribute
the £28 billion Dedicated Schools Grant (the main source
of schools' funding) by the DfES. Funding allocations to Primary
Care Trusts through the capitation formula are also primarily
driven by population.
9. It is therefore essential that the underlying
population estimates are robust and credible. Unfortunately Westminster
City Council believes that the current estimates are failing adequately
to quantify population levels amongst "hard to count"
areas which have large levels of international migration inflows.
Challenges faced by Westminster as a first point
of arrival
10. Westminster faces particular challenges
as it is the first point of arrival for a large proportion of
new arrivals from overseas. An estimated 2,000 migrants arrive
at Victoria Coach station each week on coaches which originate
on the continent. This figure excludes migrants arriving on train,
tube, bus and coach services from the major London airports.
11. Since the 2001 census Westminster has
seen rapid population growth linked to increasing levels of international
migration. The following research results outline the issues raised
by Westminster regarding current population estimates.
— Westminster is the number one destination
for working migrants accepted through the Workers Registration
scheme—over 16,000 have registered in Westminster between
May 2004 to March 2007.
— Over 34,000 residents of Westminster
received a New National Insurance number between 2002-06—equivalent
to 17% of our 2001 census population.
— Around half the rough sleepers in
central London are now A8 migrants (Council survey December 2006).
— There has been a large rise in the
numbers of migrants being supported through voluntary groups.
Destitution amongst A2 migrants from Bulgaria and Romania who
are not entitled to work permits is becoming an increasing issue
in the City according to voluntary bodies in the Victoria and
Pimlico areas who support refugees and migrants.
— Our 2006 Housing Needs survey has
identified increasing overcrowding and household sizes linked
in significant part to a growth in housing of multiple occupation.
This is adding further to the acute pressures on affordable housing
in the City where 44% of children already live in overcrowded
accommodation.
— Thousands of migrants are not being
counted within Westminster's boundaries. Independent research
has found that Westminster has over 13,000 illegal migrants within
its boundary at any one time and that around 11,000 short-term
migrants annually are "hidden" as they are not registered
in official statistics.[13]
— Innovative research using ethnographic
techniques conducted by ESRO suggests that some migrant communities
in Westminster may be twice as likely to register for bank accounts
and mobile phones than with state institutions such as with a
GP or for National Insurance numbers.
— The ESRO research also found that
the Office for National Statistics' definition of a "household"
does not accurately reflect the complex living arrangements of
migrants in the 21st century.
— Research conducted by SQW and Local
Government Futures shows that official estimates are not "fit
for purpose" in areas as diverse as Westminster. This is
backed up by the fact that the Office for National Statistics,
responsible for compiling population estimates, refused to include
Westminster in a test of the forthcoming 2011 census that was
undertaken in May 2007. The ONS said: "our methods might
be sufficiently good enough for more typical cities".
— Local Government Futures research
revealed: "We have found no evidence to suggest that the
combination of the City of Westminster's extreme characteristics
have been considered, or addressed, by the current or proposed
ONS methodologies for calculating mid-year population estimates
between 2002 and 2005."
— A recent survey for the Local Government
Association estimated that the cost to local authorities of supporting
people with no recourse to public funds was an average of £818
thousand per local authority in 2006-07. Westminster City Council
alone incurred over £1m in 2006-07.
— At a population summit held by Westminster
City Council and attended by approximately 30 other councils it
identified the non-measurement of short term migration as a major
problem: "Short term migration has a significant impact on
the provision of public services in many local authority areas
but migrants who are identified by the International Passenger
Survey as planning to stay in the country for less than 12 months
are excluded from the existing population estimates used to distribute
grant funding. This approach will by definition exclude many international
students planning to stay in the UK for a single academic year
or migrants from Old Commonwealth nations such as Australia and
South Africa as well as individuals from A8 migrant states whose
intentions are not firm when they arrive in the UK. In the absence
of an ONS short term migration dataset at local authority level
(which is not expected until 2008 at the earliest) the government
should introduce a specific grant for the CSR07 period to target
resources at those authorities most affected by these communities.
This grant could be distributed using proxy indicators such as
WRS or NiNO data which are available at local authority level".[14]
— The summit also found a lack of clarity
on the minimum standards of accuracy for population estimates
and raised concerns about the relocation of the ONS to Wales linked
to inadequate funding of migration estimates methodology.
Problems with the 2001 Census
12. The foundation of all UK population
statistics is the decennial census, but this foundation has been
shaken over the last two decades. The 1991 census was considered
a failure in national terms, largely as a result of the introduction
of the Poll Tax (Community Charge) which provided an unwelcome
incentive for some people to avoid completing the form, or for
missing members of their household off the return in an effort
to avoid paying this new form of taxation.
13. Whilst the Office for National Statistics
(ONS) regarded the national performance of the 2001 census as
successful, within London, and Westminster in particular, serious
shortcomings were identified. In 2004, following a high profile
campaign by Westminster City Council, the ONS accepted that their
previously issued population figures were wrong for the borough.
ONS subsequently produced a revised population total for Westminster
of 203,000 for 2001; this revision was regarded as the best estimate
available and added an additional 17,500 people to the original
census figure.
14. However, Westminster City Council considers
that due to problems with the enumeration process, the high population
turnover, the diversity of its population and more generally the
large numbers of hard to count groups resident in the City this
revised 2001 census figure remains an underestimate.
Concerns about ONS methodology for estimating
international migration at local authority level
15. International migration estimates, which
include only people who move to a country other than that of their
usual place of residence for a period of at least a year, are
currently based on estimates of Total International Migration
allocated on the basis of the International Passenger Survey (IPS).
International in-migrants are then allocated to local authorities
on the basis of the distribution of in-migrants according to the
2001 census and thus any errors in the census will be compounded
in the subsequent population estimates.
16. In the revisions published on 24 April
2007 the ONS linked to the publication of the results of its Improving
Migration and Population Statistics (IMPS) study it announced
that it was intending to supplement the migration estimates identified
through the IPS with data derived from the Labour Force Survey
(LFS). In the ONS's view this was designed to improve the distribution
of migrants between regions and also to individual local authority
areas. The LFS is a quarterly sample survey of households living
at private addresses in Great Britain and its purpose is to provide
information on the UK labour market that can then be used to develop,
manage, evaluate and report on labour market policies. The Labour
Force Survey, however, has significant drawbacks as a tool for
allocating migration as it has an even smaller sample size of
migrants than the IPS and does have any significant coverage of
communal establishments or housing of multiple occupation.
17. Independent research commissioned by
Westminster found:
18. "We do not believe the recent proposals
by ONS, to incorporate the use of the Labour Force Survey within
their methodology for allocating inward international migration
flows amongst local authorities in England, will more accurately
reflect the extreme characteristics of the City of Westminster.
Consequently, the new ONS proposals will not more accurately reflect
the City's resident population. It is clear that, until the City
of Westminster's extreme characteristics are reflected in the
ONS methodologies, the midyear population data produced for the
City will always be inaccurate." Local Government Futures
September 2007.
19. The Office for National Statistics'
rationale for using the Labour Force Survey in the formulation
of TIM estimates is not robust, as the relevant Labour Force Survey
migration sample sizes are actually smaller than those of the
International Passenger Surveys. SQW September 2007.
20. The ONS also announced its intention
to adopt a propensity to migrate model to produce estimates of
out-migration at the local authority level and changed the basis
for making assumptions about individuals who switch their intentions
between being a short term visitor or a long term migrant. However
this latter data is only informed by people leaving the UK and
not by those switchers who decide to stay permanently.
21. The council contests the assumptions
made by statisticians and politicians regarding migration. On
too many occasions public statements have been made as fact regarding
the assumed behaviour of migrants which have not been backed up
by research. For example:
— "That these figures are lower
than previous estimates [revised population estimates] simply
reflects the reality that many migrants to the UK who arrive in
London quickly move on (including many of those you indicate as
arriving through Victoria Coach station)." Letter from John
Healey, Treasury Minister to Sir Simon Milton.
— "The improvements that the ONS
is making to its methodology makes the information more accurate
and improves quality." Angela Eagle, Treasury Minister.
— The Home Office used a report that
suggested just 5-13,000 migrants would arrive in the UK on the
accession of EU A8 countries. The Home Office paper, coordinated
by the University College London economist Christian Dustmann,
said: "Estimates for the UK range between 5,000 and 13,000
net immigrants a year." Guardian 2 September 2006.
— The Home Office says its best estimate
of illegal immigration is 430,000 but the number could be between
310,000 and 570,000. Immigration Minister Tony McNulty said the
figures were a "best guess". "By its very nature,
it is impossible to quantify accurately, and that remains the
case," he said. BBC Online 30 June 2006.
— Migration figures released by the
ONS earlier this month [April] suggested that approximately 56,000
Poles entered the UK in 2005, although the Department for Work
and Pensions has issued figures suggesting that over 170,000 Polish
citizens applied for National Insurance numbers in the same year.
Observer 29 April 2007.
22. Westminster's research shows that migration
is complex and assumptions made will not fit migration patters
uniformly throughout the country.
Poor management data impacts on local communities
23. The cumulative effect of the population
revisions changes announced on 24 April in London was a loss in
population of over 60,000 residents between mid-2001 and mid-2005,
most of which is attributable to the change from the use of the
IPS to the LFS at the regional level. Westminster saw a reduction
to its previous migrant allocation of around 15,500 which the
City Council believes is counterintuitive. This resulting relative
loss of population does not reflect our experience on the ground
and evidence from a number of boroughs and other authorities to
the contrary.
24. Westminster City Council believes that
they will lose upto £18 million before damping in funding
per year because the government is not properly counting population.
The potential loss of £18 million per year would be the equivalent
of an £150 increase on top of the average band D council
tax bill in Westminster. However, last year the Council gave a
commitment given to residents that they would not increase council
tax by more than 2% per annum until 2009-10, subject to the need
to maintain financial prudence. The alternative would be facing
difficult decisions in relation to social care services where
there is a major threat to our future funding. The council says
the mismanagement of migration will affect services as three-year
funding for councils at the end of this year will lock them into
settlements that disregard these "hidden" communities.
25. There is mounting evidence from alternative
estimates, the Statistics Commission, the Audit Commission, the
Governor of the Bank of England, and the ONS that suggests that
the population estimates significantly underestimate the scale
of international in-migration nationally. This reflects the weakness
of using small sample survey data to generate information on the
migration patterns of hundreds of thousands of individuals.
26. Of those sampled by the International
Passenger Survey in 2005, for example just under 3,000 were in-migrants
as opposed to permanent UK residents. If the samples from the
three largest airports (Gatwick, Heathrow and Manchester) are
excluded only 79 in-migrants were in fact interviewed by the ONS
through the IPS in 2004 for all the other UK airports combined
(including Liverpool, Stansted and Luton which have the largest
proportion of low cost flights from central and eastern Europe).
Similarly in 2005 only 17 migrants coming through the Channel
Tunnel were interviewed under the IPS. Westminster questions whether
these sample sizes—which will drive the data for the distribution
of NHS and local authority funding over the CSR 2007 period—are
sufficiently robust to measure the true quantum of migration into
the UK.
27. The current assumptions about migration
which are derived primarily from survey-based methods need to
be supplemented by a more rigorous review of local datasets held
by local and central government as well as seeking evidence from
the business and voluntary sector. This requires a more pro-active
approach by government departments to data sharing.
28. There has been widespread criticism
of the methodology used by the Office of National Statistics to
measure migration dating back to an investigation conducted by
the Statistics Commission in October 2003—The 2001 Census
in Westminster: Interim Report.
" . . . it is a fact that whatever the true
population in Westminster on Census night, the population now—two
years later—could be significantly different. The churn
in population in inner urban areas, and especially in Westminster,
is high, with up to a quarter of the electorate on the electoral
register changing annually. We know that methods currently used
for measuring migration into and out of the UK, and between local
authority areas, are unreliable. Particularly unreliable are the
estimates of international emigration and immigration into and
out of Central London. Without improved methods, up-dating population
census figures is liable to error."
29. The Statistics Commission has written
to government departments alongside the Office of National Statistics
to further reinforce the consequences of using "limited"
population data.
"There is now a broad recognition that available
estimates of migrant numbers are inadequate for managing the economy,
policies and services." Letter from Karen Dunnell, National
Statistician in May 2006 to four government departments.
"Until our research has concluded you may
wish to consider how the estimates and projections are used and
whether there is any scope for recognising the particular uncertainty
for those parts of the country that are affected by relatively
high levels of migration." Letter from Glen Watson, Director
Social Reporting & Analysis Group Office for National Statistics
to Lindsay Bell Director, Local Government Finance CLG December
2005.
Short term migration
30. The existing population estimates and
projections issued by the ONS only include migrants who intend
to stay in the country for more than 12 months. Individuals planning
to stay for less than 12 months are classified as short term migrants.
31. This approach will by definition exclude
from the existing population estimates many international students
planning to stay in the UK for a single academic year or migrants
from Old Commonwealth nations such as Australia and South Africa
as well as individuals from A8 migrant states whose intentions
are not firm when they arrive in the UK. Until and unless these
individuals leave the UK any switching from being a short term
migrant to a "permanent" resident will not be identified
through a change in the national quantum of population through
the International Passenger Survey. If there has been an increasing
trend in recent years for short term migrants to decide to remain
in the UK permanently this may not be adequately captured therefore
through the current methodology leading to the understatement
of the nation's population.
32. Whilst the majority of short-term migrants
may arrive in the UK without families so they make fewer demands
on some of the more expensive forms of public services such as
education and children's social care, they still use a range of
local authority services which means that the authority incurs
costs whether it be in relation to waste management, leisure provision
or housing. In addition short term migrants who fail to find jobs,
or lose their jobs and who are not entitled to or have only limited
entitlement to benefits may become homeless and destitute.
33. The ONS has recognised the need to produce
a robust short term migration dataset at regional and local authority
level but this is not expected to be available until late 2008
at the very earliest. Experimental national estimates are however
expected to be published in late September 2007. In view of the
acute pressures being placed on local services by short term migration
it is imperative that the production of a short term migration
dataset is prioritised by the ONS—this should be supported
by new resources from HM Treasury if required.
34. In the absence of a consistent ONS short
term migration dataset at local authority level Westminster considers
that the government should introduce a specific grant for the
CSR07 period to target resources at those authorities most affected
by this issue. This grant could be distributed using proxy indicators
such as WRS or NiNO data which are available at local authority
level. It would be inappropriate for this issue to be ignored
until the next spending review.
2 October 2007
13 Westminster Population Research. SQW September 2007. Back
14
Westminster City Council Population summit 2 July 2007. Back
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