Manchester Ward Boundary Changes – An Annotated Library

An independent annotated library offering access to the official LGBCE documents, MCC documents, maps and the formal complaints for the 2016-18 Manchester City Ward Boundary changes.

The submissions by Manchester City Council and by local groups and citizens are also available on the LGBCE page for Manchester. However many documents are huge, the maps are difficult to find, and so are the statutory requirements that matter.

Moreover, the LGBCE page does not include the formal complaints to the LGBCE and MCC, the responses to the Freedom of Information Act requests, MCC’s supposed “comprehensive mailing list“, or other relevant documents that reveal the failures across the Manchester City Council area.

Hence the need for this independent annotated library.

Context

What is the Local Government Boundary Commission for England (LGBCE)?

You might be forgiven for guessing… err.. the LGBT C of E ?!  No, this is what it says on the tin:

“The Local Government Boundary Commission for England (LGBCE) was established by Parliament under the provisions of the Local Democracy, Economic Development and Construction Act 2009 (the 2009 Act).

“Independent of central and local government, and political parties, it is directly accountable to Parliament through a committee of MPs chaired by the Speaker of the House of Commons.

“The Commission’s objectives are:

  • To provide electoral arrangements for English principal local authorities that are fair and deliver electoral equality for voters.
  • To keep the map of English local government in good repair and work with principal local authorities to help them deliver effective and convenient local government to citizens.

“We are responsible for, among other things, conducting three main types of review of local government:

Electoral Reviews – These are reviews of the electoral arrangements of local authorities: the number of councillors, the names, number and boundaries of wards and electoral divisions and the number of councillors to be elected to each. Electoral reviews are initiated primarily to improve electoral equality. This means ensuring, so far as is reasonable, that for any principal council, the ratio of electors to councillors in each electoral ward or division, is the same. … The Commission is responsible for putting any changes to electoral arrangements into effect and does this by making a Statutory Instrument or order. The local authority then conducts local elections on the basis of the new arrangements set out in the order.”

Quoted from the LGBCE Technical Guidance  pdf download

“The Commission’s website www.lgbce.org.uk provides details of reviews which it is or has undertaken. It also provides all representations received on current reviews.”

Why 96 Councillors for Manchester?

Manchester City Council (MCC) was asked by the LGBCE to make a case for the number of Councillors.

pdf download MCC’s submission to the LGBCE in June 2016, describes the hard work of Councillors and an increasing population in Manchester, and concludes:

“Manchester’s continued success internationally, nationally and regionally relies upon having adequate representation at every level. The City Council therefore considers that the size of the council should remain at 96 councillors across 32 wards (3 members per ward).”

This number was accepted by the LGBCE.

Requirements for an open process

pdf download The LGBCE’s Technical Guidance document sets out the statutory requirements and process for Boundary Reviews in England.

Statutory Requirements for a Boundary Review in England

Within the LGBCE’s pdf download Technical Guidance document:

Paragraph 2.17 sets out the commitment to transparency and consultation.

Paragraph 3.5 sets out the three statutory criteria for changing ward boundaries:

What must we take into consideration as part of an electoral review?

3.5 Schedule 2 to the 2009 Act sets out the statutory criteria to which we are required to have regard in conducting electoral reviews. In broad terms, in making recommendations, we are required to have regard to:

  • the need to secure equality of representation;
  • the need to reflect the identities and interests of local communities; and
  • the need to secure effective and convenient local government.

3.6 Included in the community identities and interests criterion is the desirability of fixing boundaries which are and will remain easily identifiable, and which will not break local ties. …

Paragraphs 4.32 – 4.47 elaborate these three statutory criteria.

Paragraph 6.2, quoted below, is perhaps the most relevant for complaints about failures in the notification and consultation process in Manchester:

Paragraph 6.2 of the LGBCE Technical Guidance states:

“All local authorities under review are required, under the 2009 Act, to provide us with information which is relevant to the review. … Figure 2 provides a list of the minimum information we require at the start of the review.”

Figure 2 then itemises the requirement of a:

“Comprehensive mailing list of community groups, partners and usual stakeholders, including … residents associations, community groups etc.”

The failure of process in Manchester

Contrary to this requirement, the “Comprehensive Mailing List” supplied by Manchester City Council did not contain a single Residents’ Association across Manchester.  It contained only 5 resident-led neighbourhood community groups from across the 32 wards.  The word ‘resident‘ is absent.  It is a list of Chief Executives, managers and Council staff.

The MCC’s list is below.  These people were informed of the boundary changes and invited to respond.

pdf download The supposedly “Comprehensive Mailing List” supplied by Manchester City Council.

The failure was deliberate

Over a year later, after Freedom of Information Act requests, and in response to an individual complaint to Manchester City Council, the MCC Corporate Complaints Team has now acknowledged that:

“it was decided that the list would not contain resident groups”

This admission is contained on the centre of page 2 in this Manchester City Council response:

pdf download Manchester City Council Response to an Individual Complaint

Manchester City Council surrounds this admission with self-justification about why “it was decided” not to notify the “resident groups” across Manchester.

MCC's justifications, and a response

This significant admission by Manchester City Council is buried in 3 types of self-justification, about why “residents groups” across Manchester were cut from the list.

Firstly, MCC claims the fuller list was “unmanageably large”. Yet clearly, it must always be for the LGBCE, not the local authority, to decide what is “unmanageably large” for the LGBCE. Moreover, electronic lists are not “unmanageable”, and the LGBCE requirement for a “comprehensive” list will inevitably mean a “large” list.

Whilst MCC’s vital “comprehensive mailing list” contained fewer than 250 individuals, a more recent MCC email on a minor consultation was sent to 345 email recipients. So there is no justification on list size.

Secondly, MCC justifies cutting the list by saying that “it is not feasible to include every resident group in the city and contact details can be unreliable. To have proceeded with a partial list could have given rise to unfair opportunity being given to some residents groups above others.

This claim challenges the feasibility of the LGBCE process nationally, and so sets a dangerous precedent. Within the current statutory requirements, the justification does not hold. The mailing list was required to be “comprehensive”, so it was MCC’s responsibility to make it so. If that was indeed “not feasible” in Manchester for some reason, then it should be obvious to all that the existence of a few omissions is preferable to complete omission. It also has to be for the LGBCE, not MCC, to decide.

Thirdly, MCC justifies the cut by saying that “the Council had agreed to support the consultation through its own communications channels to achieve city wide reach.” That is far from the reality. Like every local authority, Manchester was requested by the LGBCE to use “channels you would normally use to engage residents”. Yet crucially MCC did not use the e-bulletin email list which it routinely uses for its local updates and consultations. That is the channel promoted by MCC as the means to be kept informed on governance issues. The press-releases too didn’t get published. Hence even well-informed and well-connected organisations and residents remained completely unaware of this ward Boundary Review.

On the submission form to the LGBCE, Manchester City Council nevertheless claimed to be providing a “Comprehensive list of community groups, partners, stakeholders, residents associations & community groups, plus details of…“.  This MCC wording differs slightly from the LGBCE wording, so it has clearly been written rather than just pasted.

Given that MCC had already “decided that the list would not contain resident groups“, and removed residents groups from the list, the MCC submission checklist is at best misleading (see p2, left side).

pdf download MCC’s submission checklist set to the LGBCE, 20/5/2016

The formal complaint

pdf download Complaint-to-LGBCE-by-8-community-organisations-in-Moss-Side-and-Rusholme
Eight community and business organisations in Moss Side and Rusholme made a formal complaint to the LGBCE.

This concise 3-page document is the final stage of that complaint to the LGBCE, before taking the complaint to Parliament.  It sets out the failure of notification and consultation.

The complaint focusses on this failure of process, rather than the proposed boundaries, because it is addressed to the LGBCE who is responsible for the process.  That includes the LGBCE failure to demand that Manchester City Council supply a genuinely “comprehensive” mailing list, with “residents associations, community groups, etc.” (see LGBCE requirements above).

The complaint states that the Boundary Review for Manchester should be rejected, and carried out properly to meet the statutory requirements.

The failure is “regrettable”

In its responses to the formal complaints (see below), the LGBCE has described the failure to notify residents across Manchester as “regrettable”.  It has also acknowledged that as a result:

“The Commission’s draft and final recommendations were almost entirely based on the proposals of Manchester City Council.”

What did Manchester City Council Propose?

With so few residents / voters knowing about the Boundary Review, the proposals made by Manchester City Council were adopted by the LGBCE with few changes (see maps below).  Manchester City Council is responsible for the revised boundaries.

So what did MCC propose, that Mancunians should have been able to review and comment on?

Do ward boundaries matter? Evidently yes. Page 3 of Manchester City Council’s proposal states that they are the building blocks for future delivery:

“The devolution journey underway in Greater Manchester is reshaping the local political landscape and the configuration of public services in the city…. The warding patterns proposed in this submission will form critical building blocks for the future delivery.”

Is it just about equalising population? No. Manchester City Council justifies its boundary changes not only in terms of population, but also in the “Proposed Character” of each ward.

In many cases these appear to increase the inequalities between wards.  For example, while every ward adjacent to Moss Side is described as having green spaces, Moss Side is stripped of Whitworth Park (which had no population anyway), and is proposed as “a high-density residential area” (p33-4).

pdf download Manchester City Council’s proposed changes to the ward boundaries
Warning this original document is 40Mb and 131 pages long.

pdf download Selected pages – Manchester City Council’s proposed changes to ward boundaries
Here is a selection of pages from the document above, including the introduction and then focussing just on these 8 wards:

Ardwick, Charlton, Charlton Park, Fallowfield, Hulme, Moss Side, Rusholme, Whalley Range.

Some sentences are colour-highlighted to help you scan it.  The existing and proposed maps for each ward have been arranged on adjacent pages, so they can be compared.  Individual pages, and all page numbers, remain as in the original MCC document.

Maps

The wards as MCC Proposed

All can be viewed in the original MCC proposal document (link above).

Here we show the stripping of Moss Side’s three most valuable assets, which are then tacked on the sides of Ardwick and Whalley Range:

  • MCC has proposed the beautiful Whitworth Park, and Whitworth Art Gallery with its recent £15m public funding, be moved out of Moss Side into Ardwick (where by coincidence a MCC Deputy Leader is Councillor).
  • MCC has proposed the prime development site for south Manchester on Princess Rd be moved out of Moss Side into Whalley Range (where by coincidence those developments are likely to have a higher value).

This Boundary Review is justified as equalising ward population sizes.  But nobody lives or votes in Whitworth Park or Whitworth Art Gallery.  So the removal of Whitworth Park and Gallery from Moss Side is NOT justifiable by the ward boundary review.  A post on why it matters.

(Click to enlarge)

Moss Side

Existing

Moss Side ward map, before change
As proposed by MCC
Moss Side ward map, as proposed
Ardwick

As proposed by MCC

Ardwick ward map, as proposed
Whalley Range

As proposed by MCC

Whalley Range ward map, as proposed

The wards the LGBCE Recommended

To make sense of those individual maps, here is the final recommendation laid before Parliament by the LGBCE, showing the wards together.

pdf download The full map for the whole of the Manchester City Council area is on the LGBCE website here.

LGBCE ward boundary changes for Moss Side, Manchester

The comparison

This final map compares the Manchester City Council proposals with the final LGBCE recommendations across Manchester. Produced by Manchester City Council, it shows that the ward boundary changes recommended by the LGBCE as black lines, with additional pink lines to show the few differences from the original proposal by Manchester City Council.

Manchester map: LGBCE changes from MCC proposal

The invitations you missed

These are the notifications / invitations you did NOT receive from the LGBCE, because Manchester City Council “decided that the list would not contain resident groups”.  They do suggest a desire by the LGBCE for an open process.

pdf download LGBCE letter 1 – Inviting proposals for ward boundary changes

pdf download LGBCE letter 2 – Inviting comments on the draft proposal

 

The complaints and replies

Explanation and Update on the Formal Complaint about Manchester’s Ward Boundary Review
a post on this website, providing a briefing on the complaint, with evidence.

pdf download Stage-1-2-complaint-to-LGBCE-by-8-community-organisations-in-Moss-Side-and-Rusholme

The initial Stage 1-2 complaint to the LGBCE by 8 community and business organisations in Moss Side and Rusholme.  It includes the harm being done to Moss Side and Rusholme by the boundary changes.  Jump to Annex B on page 12 for the complaint.  (Annex A lists the requirements on the LGBCE.)

(For precision, please note that this Stage 1-2 complaint states that searches could only find 1 tweet about the boundary review consultation by MCC.  MCC have since stated that they sent a total of 4 tweets about it during the 2 consultation periods.  As even 4 tweets don’t announce a major public consultation, that doesn’t change the point.)

pdf download LGBCE-Response-Manchester-Complaint-Stages-1-2

The LGBCE’s response to the Stage 1-2 complaint.  It is quoted and response to in the Stage 3 reply by the 8 community and business organisations.

pdf download Complaint-State-3-to-LGBCE-by-8-community-organisations-in-Moss-Side-and-Rusholme
The response, and subsequent Stage 3 complaint by the 8 community and business organisations in Moss Side and Rusholme.  This concise 3-page document (already linked above) is the final stage of that complaint to the LGBCE, before taking the complaint to Parliament. It sets out the failure of notification and consultation by the LGBCE.

pdf download LGBCE-Response-Manchester-Stage-3-Final-2017-09-06
The LGBCE’s response to the Stage 3 Complaint.

A comment on the LGBCE responses

In its responses to the complaints, the LGBCE has described the failure to notify residents as “regrettable”. It has also acknowledged that as a result, “The Commission’s draft and final recommendations were almost entirely based on the proposals of Manchester City Council”.

Yet its only action is to say “Commissioners will look for other lessons that may be learned from the Manchester review”. Surely the Commissioners should not need to learn to require what they had already set out as the LGBCE’s requirements?

Both of the LGBCE responses downgrade its own requirements and failures. The most recent refers to the “minimum information” as merely “the information that is routinely sought”.  It refers to the omission of all residents’ associations across Manchester as merely “some groups might not have been alerted on this occasion”.

The replies are therefore inadequate.  In its ducking of any accountability, the LGBCE responses indicate there is no accountability.

Other related documents

The LGBCE’s Manchester page sets out the LGBCE process, and includes all submissions made during the two consultations.  It also offers a link to the final recommendations now put before Parliament for consideration.

Lucy Powell’s email to Labour Party members, August 2017

This email informs members that “A Boundary Commission review of the ward structure in our city has taken place over the past year“.

It is written as if Manchester City Council are not responsible for the revised boundaries, and as if the Boundary Review is an autonomous process, rather than something for which Manchester City Council provided the notification list for the public consultation.

In reality, Labour Party members, like other residents across Manchester, were not notified during the consultations because Manchester City Council made a decision that the “comprehensive mailing list” for notification “would not contain resident groups”. (Evidence above.)