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Housing Numbers

Housing NumbersFylde Council has just begun a consultation on a crucial part of its new local plan. (See end for links)

Central to this consultation, it has announced the number of houses it says Fylde needs over the next nineteen years or so.

This article is about the proposed housing numbers.

For most folk, dealing in the abstract with housing numbers like this is dry as dust, and boring, so they don't bother.

But we hope to show how they change people's lives and why they are so important

The housing numbers are why new houses are built in Fylde. They affect property values, they impact on the council tax payable to Fylde, and they increase the 'new homes bonus' the Government will pay to councils that approve new house building schemes.

They are often seen to damage wildlife and countryside areas, and farmland, (giving rise to protest groups such as Queensway and Wesham Action Group and so on), they increase pressure on local services like doctors, dentists, chemists, schools and more, and they increase road traffic.

Wherever new houses are located, there will be fierce criticism from those living locally - and sometimes from the wider community. But that only arises when it's too late to make changes. The time to argue the case is now, when the numbers are being decided.

So it's really important that the number of houses Fylde needs is as accurate as can be. It's one of the most important decisions Fylde will make.

Arguments about the number of houses needed, and the dates you count them within, and which houses (or planning permissions) you can take into account in the calculation, are also the reason that we've been having an unprecedented number of costly public inquiries in recent years.

So although it's dust dry and boring, it's really important to get it right.

We disagree with the number Fylde has just published - in fact we disagree with quite a bit of the UK's current housing policy - even that promoted by Westminster.

For example, (and as regular readers will know) we absolutely refute the idea of "Affordable Housing.' (and we know we're almost alone in this perspective).

This con-artist (but fiendishly clever) doublespeak term was coined by a bunch of Herbert Marcuse Frankfurt School enthusiasts in the last Government (and has been continued by the present one), to make us think they mean cheap houses for newlyweds.

In fact, it's 95% a euphemism for what, at one time, would have been called 'council houses' (more accurately referred to a socially subsidised housing).

We're not going into the Affordable Housing history again here. Readers can look up our 'Affordable Housing' article which gives a full analysis of the topic.

For the most part, Fylde's present 'Affordable Housing' policy says that developers who are building new houses to sell, must also build 30% (it used to be 60%) of the site as houses for rent. And the rental houses must externally identical to the owner occupied (so called 'market value') housing which is being built for sale. (So no-on can tell they are housing those who might be, ahem, less well-off).

This was a key part of the awful social engineering policy devised by former Chief Executive Ken Lee, to "produce a more balanced community" - and was swallowed hook line and sinker by the former Commissar John Coombes.

It was based on a tissue of lies so thin a child of five could have seen through it.

That said, and to his credit, since Cllr Trevor Fiddler got his hands on the policy he has made great attempts to shift it away from rental and toward part-subsidised owner occupancy.

But we still disagree with the underlying logic for two reasons.

Firstly, by having builders cross-subsidise the 'Affordable' housing from their (normal) 'Market Value' housing, it pushes up the price of the Market Value housing, making it even less affordable than it otherwise would have been. So in that sense, it is self defeating. The new 'private' owners are, in effect, paying part of the cost of their new house as a subsidy to those in the 'Affordable Houses' living next to them.

But even worse than that is the principle of subsidising property. This requires complex and sometime labyrinthine rules about what happens when Affordable Houses are vacated and whether they can be subject to the 'Right to buy' legislation and what happens if and when the occupants buy them and want to sell them. Complex clawback arrangements have to be devised and administered.

The aim of the scheme is to help people - especially those who can't really afford it - to have a home to live in.


If that's the aim, then subsidise the *people* not the houses.

Same result different path.

We already have bureaucracy that deals with taxation and benefits. Just add the subsidy entitlement into that if you want. Set the personal criteria that give entitlement to such a benefit, make it an explicit payment via the tax and benefit system, and leave the builders to produce decent sized homes, rather than el-cheapo matchboxes.

But we digress (as usual!) - so back to the main plot.....

So how did Fylde's housing number come about? What is it? And what does it mean for Fylde?

Well, in the summer of 2002 Ken Lee persuaded the Council to commission a respected company called Fordham Research to assess the state of repair of houses throughout the Fylde. (at least that was how it was sold to Councillors). But it actually turned into an assessment of housing "need and desire" using what we consider to be doctored questions to give a particular result. (We're not saying Fordham were responsible for this, we suspect they were not. However they did not make any public issue when their report was - some would say subsequently - 'mis-used', so they may not be as white as snow)

Then, the "and desire" bit was purposefully dropped from the title once the report had been delivered. The survey became shortened to the 'survey of housing need', and it found that the overriding need was for social rented housing (which was said to be a massive (actually ridiculous) 97% of identified need for housing in Fylde).

It purported to say that of all the housing needed in Fylde, only 3% was needed for what normal people would describe as houses for sale. The rest needed to be socially subsidised housing.

We think this lunacy shows that to get a particular answer, it very much depends on how you phrase the questions.

Now, any normal person would have seen that 97% and laughed.

We might have described it as beginning with 'B' and ending with 'ollocks' - but such was Lee's hold over the Council that he sold it to them.

Using twisted logic and the doublespeak for which Fylde is now infamous, the Council concluded that Fylde had a 'need' for 420 extra affordable dwellings per year.

As we said in our 'Affordable Housing' article ..."You would have thought Councillors might have spotted something was wrong - when the Joint Lancashire Structure Plan for 2001-2016 showed an annual need for *only 155 dwellings OF ALL TYPES* in Fylde Borough, and the Council itself was only allowing the building of an annual average of 254 dwellings per year.

This new figure of *need* for 420 'Affordable Houses' a year was plainly preposterous.

So given their previous form on this matter, we're always ready to take whatever Fylde now says about its housing need with a HUGE pinch of salt. (Probably equal in volume to the gritterloads that weren't spread on the Square last winter)

We're especially cautious now, because they invited the same company to 'update' their figures from last time.

Yes Really!

The next big thing to happen about housing numbers was that the North West Regional Spatial Strategy was published.

The RSS said Fylde had to take a total of 5,500 more houses by 2021. That was something like 458 houses a year from when the RSS was published to 2021.

Fylde's previous total had been 254 dwellings a year.

You can now see why developers like Kensington and Metacre (and others) were swarming all over green land in Fylde. To them it looked like the 'California Gold Rush' all over again.

It was going to be 'Quantative Easing' for housebuilders.

Thankfully, if it's not actually dead by now, this dreadful RSS is, at last, in its final death throes after the Rt Hon St Eric Pickles started the process to kill it off almost as soon as he took charge of the Local Government Department at Whitehall.

Which brings our 'housing numbers' news timeline up to today.

So what's the latest 'educated guess' at how many houses Fylde needs?

Well using what they call their assembled 'evidence base' - some of which (including the Fordham reports) we absolutely do not trust - Fylde now says that 280 additional households a year are needed in Fylde.

That's better than the RSS's 458 homes a year, and better than Fylde's own preposterous 420 a year, but it's still an increase on it's previous number of 254 dwellings a year.

So we had a look behind the scenes to see how this figure had been arrived at.

Essentially it was down to Fylde's Local Plans officers. They used some generally reliable information like the Office for National Statistics' Census Data, and some (what we consider to be less reliable) updated reports from the likes of Fordham. They also engaged a housing specialist to work with them for a while to do some research.

That produced the first draft of what the number should be.

Then Fylde established a group to supposedly give democratic legitimacy to the numbers (and to other aspects of the new local plan).

We take significant issue with the process that was used to create this 'democratic camouflage' group.

It's properly called the 'Local Development Framework Steering Group' and it has the appearance of a Council Committee.

But its far from that.

In November 2011, it had present at its meeting:


  • Councillor Dr Trevor Fiddler - Portfolio Holder - Planning and Development
  • Ben Aitken- Chairman - Development Management Committee
  • Councillor Kevin Eastham - Vice-Chairman - Development Management Committee
  • Councillors Julie Brickles, Maxine Chew, Peter Collins, Fabian Craig-Wilson, Charlie Duffy, Peter Hardy, Nigel Goodrich, Angela Jacques, Linda Nulty, Richard Redcliffe, Heather Speak, Viv Willder


  • Ian Curtis - Head of Governance
  • Mark Evans - Assistant Director: Planning Services
  • Julie Glaister - Planning Policy Manager
  • Janet McDonald - Principal Planning Policy Officer
  • Matthew Park - Planning Policy Officer
  • Fiona Riley - Planning Policy Officer
  • Andrew Loynd Principal Car Parking and Energy Officer

Other Representatives

  • Mr Bernard Whittle - Chair - Local Strategic Partnership

There may be other members, but those were the ones present at that meeting.

The Agenda and Minutes for this group are published in secret, They are not public documents. Members of the public may not attend its meetings as of right, and Freedom of Information requests for its agenda and minutes to be published have been met with a refusal to publish because....

"... the Council has decided to rely on the exemption under section 36 (1) (b) and (c) of the Act, in that disclosure of the agenda and minutes would, or would be likely to, inhibit -

(i) the free and frank provision of advice, or

(ii) the free and frank exchange of views for the purposes of deliberation, or

(iii) would otherwise prejudice, or would be likely otherwise..."

The refusal to disclose continued....

"Under section 36, the qualified person must give their reasonable opinion that the exemption is engaged.

[Name deleted by cb] is Council's Monitoring Officer, is the qualified person and has confirmed that in her reasonable opinion the exemption is engaged. In her opinion, [Name deleted] considers that the exemption is engaged because she considers that members of the Group require free space to develop and air their arguments without the contraints that would be imposed upon them if the minutes of the meetings were open to public scrutiny. [Name deleted] further considers that this would be likely to have a prejudicial effect of the quality, robustness and effectiveness of the local development framework."

In short this says that councillors needed to work in secret because if the public found out what there were saying they would be too embarrassed or ashamed to have said it in the first place.

We say that is a disgrace and, as our regular readers will understand, we fundamentally oppose this view in principle.

The electorate need access to which councillor holds what view in order to be able to decide whether to vote them in or out at the next election. If we do not know their beliefs and values, and the causes they argue for or against, how are we otherwise to make our choices?

We accept there are sometimes legitimate reasons to exclude some information that councillors need to discuss (for example disciplinary matters that may eventually exonerate an individual, or the personal circumstances of employees, or sometimes information about prices for contracts to prevent collusion and price fixing) but these can be dealt with by making individual reports exempt, and by redacting specific parts of documents published under the Freedom of Information Act.

Seeking to exempt the complete agenda - and more especially the minutes - of a democratically elected body deliberating public policy in order to avoid embarrassing or shaming the participants is a complete travesty of democracy, and it shows the depths that are still being plumbed by Fylde Council.

We also think there's another reason it was done in secret this way (of which more later)

So this is an issue upon which we're making a stand.

We have said we are not satisfied with the FoI refusal, and we have exercised our right to appeal the decision to refuse to provide the information. In the first instance the refusal (which dates back to our request in March and FBC's refusal in April) was considered by Fylde.

Now, our appeal is currently with the FoI department of an adjacent authority, and if that does not overturn FBC's refusal to publish the minutes and agenda for these meetings, we will probably end up with a complaint to the Information Commissioner.

We regard this matter as a hugely important point of principle. It cannot go unchallenged.

The whole of this secrecy ethic at Fylde derives from the dreadful Cabinet System of governance which excludes rank and file councillors from receiving all the information and reports they need to hold those making the decisions to proper (and sometimes embarrassing) account.

As it happens, we actually have most of the Steering Group's early minutes and agenda that refer to the debate on housing numbers anyway, so we are able to bring our readers some background information about what went on.

But that's not the point. The more important issue is the secrecy, and the precedent that this matter would otherwise set.

We have these documents - not because a member of staff or a Councillor delivered them to us in a clandestine operation in the dead of night - but because (as so often happens) Fylde published them on their website.

In this case they were published and we downloaded them (having done a Google search of FBC's website) We routinely download almost all agenda and minutes. But one of the agenda was missing, so we asked (nicely) if it was an omission that it was not published, and could we please have a copy - expecting it to be provided on a return email.

The officer who looks after the website must have thought the same as we did, because they created an official committee page with pictures of the Councillors involved, dates of the meetings and downloadable pdf files of the agenda and minutes we already had.

It was all very easy to follow, and we were very impressed - both with Fylde's response time and what had actually been done. They also told us they had asked in the Governance department what had happened to the 'missing' minutes we had asked about, and would get back to us.

The reply came a few days later and was a surprise.....

It came from the Council's solicitor who said:

"The Local Development Framework Steering Group is not a committee of the council and its papers are not normally published. The publication of the papers on the website was an error. However, a decision was taken to publish certain papers concerning the process of moving towards a locally generated housing requirement figure because doing so would demonstrate that the process had started and would assist in the Queensway inquiry. Those latter papers will remain on the website, but the rest will be or have been removed."

Publication was an error but we're publishing some of them indeed!

One of the Minutes carries an instruction from the Steering Group to publish their agenda on the Council's website!

The minute of their meeting held on 21 November 2011 say "IT WAS AGREED - That the next meeting of the group be held on 19 December 2011 at the Town Hall, St Annes commencing at 18:00 and that the agenda for that meeting should be published on the Council’s Website once it has been received by Members of the Steering Group."

But to date, officers have refused to carry out this instruction.

We wondered why.

So far as we can tell, the logic is that the genesis of the group was not to create a group that does what it's name suggests (to steer and thus control the direction and progress of the new local plan). It's purpose seems to be more to convince council members (and subsequently to be able to say to the public) that councillors are having a say in the preparation of the new local plan.

This is the usual Fylde doublespeak of course.

Yes, Councillors are (literally) having a 'say', but no one is listening when they say anything.

The group is unable to give life to its deliberations as decisions because it is considered to be only an "advisory" group.

The decision taker is actually the Portfolio Holder for Planning, (Cllr Trevor Fiddler),

We think this was an attempt to introduce what was being viewed by the Conservative High Command as the future model for a new corporate governance structure for Fylde. (A Cabinet Portfolio Holder backed up by a toothless 'advisory group' that he can choose to ignore at will), and this was the reason the "Local Development Framework Steering Group" was established in such secrecy and with such a non-public format.

Now our readers will see why this is such an important matter.

If those Conservatives with influence had carried out their plan (which we understand is now less likely), the ability to have all such 'advisory' meetings (concerning all aspects of Council operation) carried out with unpublished agenda and minutes, and no public access, would have become firmly established and.... well, as Mme Lagarde so eloquently put it.... "We shiver!"

So, getting back to the housing numbers, how did Fylde's number of 280 become the figure, and did everyone in the Local Development Framework Steering Group meetings agree with it?

Our first reference is their meeting of 19th September where "Councillor Fiddler said that the report before the committee was not the same report as he had previously seen. Andy Foot stated that he had been asked to refine the figures further following his meeting with Councillor Fiddler."

So we see that Cllr Fiddler didn't like the first figure that had been produced and it had been refined (for which read 'changed').

Mr Evans explained that the model looked at demographic, economic and housing affordability factors in reaching the figure.

Mr Foot (the Housing specialist consultant engaged by FBC) told the group "The present trends were for smaller household sizes and for the population to become older. 400 people more died than were born in Fylde households on present figures. ONS projections increased this to 600 people. But net inward migration more than made up this decline. This inward migration was from the UK, as net migration from abroad was negative."

Councillor Fiddler observed to the group that the figure of 280 corresponded broadly to completions in Fylde in recent years.

Councillor Armit said that housing delivery was 255 historically. He asked why Mr Evans was recommending 280 rather than 260. Mr Evans responded that the figure looked at need on the future, not development in the past.

Councillor Nulty felt that the figure should be 260 rather than 280. Councillor Fiddler stated that the final figure might well be 260, as the figure decided was not the figure at the end of the process. The recommendation would be that this was the starting point for going down the next part of the flowchart.

Councillor Mulholland said that we need to be careful not to be too sensitive about the figure of 280. We did not want appeals allowing because we had underestimated housing need.

Councillor Redcliffe felt that unless there was something significant that had changed, he would not want to go to 280, and should use the historical figure instead. Mr Evans stressed that the projections were built around a range. You could come up with different figures by taking different figures within the range.

Councillor Aitken argued for a lower figure to protect agriculture. Councillor Fiddler pointed out that the national framework did not mention this as a priority.

Councillor Fiddler invited the meeting to accept 280 as the starting point for the exercise. The next stage would be to look for sites suitable to deliver this number of houses.

At their next meeting on 17 October 2011, Dr Trevor Fiddler stated that further to the last meeting, there was an opportunity to refine the proposed 280 gross figure. In doing so, he referred to the components that influence the final housing figure namely: longevity, migration and single occupancy/ changes in household characteristics.

Councillor Fiddler went on to say that a 255 figure was a median which was more in line with the historic rate of delivery of new homes in Fylde over the last decade but that such a figure was not to be taken as an indicative position of Fylde.

Councillor Aitken presented a graph to the group which depicted the number of dwellings completed between 1990 and 2010. It suggested that the 20 year average worked out at around 252 dwelling per year. The graph was circulated at the meeting.

Councillor Goodrich commented that whilst he was not unhappy with the 280 figure, he was more concerned about a compliant, defensible figure.

In response, Councillor Fiddler confirmed that the position should be sound and reasonable and that the 255 figure was a median that was fair and could be defended.

Councillor Redcliffe commented that he would also prefer the lower figure unless arguments for a higher demand for housing could be demonstrated.

Councillor Nulty concurred with this and stated that there did not appear to be a convincing argument to look at a higher figure.

Councillor Duffy stated that the figure could only be accurate if it reflected future housing need but he preferred to take a lower figure that was defensible as opposed to a median figure.

Mr Evans advised that the Core Strategy was a plan for the future development of the borough and that, whilst historic delivery could be used as an indication that a proposed housing target is achievable, historic rates should not be relied up on solely as a means of predicting future need.

Mr Evans further commented on the range of figures presented in the report by Andy Foot (previously circulated) He added that the figure was based upon household projections that were expressed as a range by the Office for National Statistics (ONS). This could result in less or more households dependent on the figure and a more detailed piece of work could be carried out to gain a better understanding of how the ranges interact with each other. He would be happy to refine the piece of work.

Further to the above, Mr Evans stated that 280 figure was a median and the question is where in that band did we want to place the figure. He added that in time, the Council might need to re-profile the figure so that a lesser number of dwellings are delivered during the early years of the plan, e.g. in order to address foul drainage capacity issues raised by United Utilities.

IT WAS AGREED to accept the notes of the previous meeting held on 14 September 2011 and that, subject to the following addendum, the 19 September notes be accepted:

“Substitute the 280 figure with 255 and in this regard, the Assistant Director: Planning Services be asked to further comment on this at a later stage in the process”."

So, as we can see from the minute of the October meeting of the group, there was widespread support by Councillors for a figure lower than 280

At their meeting in December two important things happened.

First, the note of the previous meeting was reproduced, where planning chief Mark Evans "sought further clarification from the group regarding minute 2 (defining the requirement for new homes within the borough), in that the proposed figure of 255 needed to be quantified and validated. Councillor Nulty confirmed that the group had asked Mr Evans to look to produce a further piece of work on the matter. It was emphasised that the group was an advisory group to the Portfolio Holder." (our emboldening).

So there you have the fly in this particular ointment.

This group cannot make decisions. It is an advisory group to the Portfolio Holder.

He alone will decide the number.

You'll remember, this is the same chap who made an Individual Portfolio Holder Decision to sell Melton Grove when he knew nothing about the sale. He simply trusted officers and his Conservative instinct, both of which let him down on that occasion.

Such is the state of democracy at Fylde today.

The second important point is on page 36 of the 19th December meeting. It was a new report headed "Defining The Requirement For New Homes Within The Borough" and, in summary, it says:

"Following concern regarding a suggested gross housing figure, Members requested The Portfolio Holder to substitute the originally suggested gross housing figure of 280 with a lower figure of 255 and in this regard, the Assistant Director: Planning Services was asked to further comment on this at a later stage in the process.

Additional work has been carried out in regard to the establishment of a gross housing figure and it is recommended that, based on demographic forecasts, the gross figure remains unchanged.

If Members ultimately wish to seek a lower housing figure, this should be based upon a conscious decision to seek a lower housing target housing figure rather than to seek to vary the gross housing figure itself."

The recommendation of the report is: "That, for the purposes of establishing a target housing figure for inclusion in the Core Strategy, a gross housing figure of 280 dwellings per annum is used as a base figure".

And that is what it's been set at.

With no published agenda, our readers won't get to see the logic for this number, so we've reproduced the report that was given to the Steering Group. You can follow this link to see a copy of Mr Evans second report on the matter.

We'd describe it as a 'killer' report - (not so much that it's brilliant, more that it's intended to kill off the move to accept a lower number now).

In our view it had a specific purpose - to refute and disregard the decision made by elected councillors at the previous meeting. It accentuates all that mitigates toward 280 houses and fails to address the negatives.

Now, Mr Evans may be right with his numbers. It may be that 280 is the 'right' number, but the process to arrive at it is, in our view, the wrong one.

But what is beyond dispute is that the number which has come out is the one chosen by the Portfolio Holder Dr Cllr Trevor Fiddler, and it is 280.

We agree with the Councillors who said it should be lower, and we will explain why.

In broad terms, the Steering Group were told that the factors that weigh on the number of houses that Fylde needs are:

Demographics. How many people in Fylde are being born and dying.

Households. How many people live in each household (ie the size of an average family) and whether that number is increasing or decreasing

Migration: Whether, (netted off for people moving into Fylde and people moving out) the number of people that want to live here is increasing or decreasing.

Each of those is supposedly allowed for in the 280 dwellings a year.

Taking each in turn

Demographics. Fylde has a hugely skewed demographic toward the elderly. The coastal strip holds about two thirds of Fylde's population where the elderly demographic is much more pronounced. This means that because of the high proportion of older people, more people are dying than are being born. On the basis of demographics we should not be building any more houses. The current population is declining, and we should be allowing the number of houses to reduce if anything.

Households. This is the big problem area. In 2004 the FT ran a prophetic article about the supposed Household types and sizesend to "boom and bust" and it carried this graphic showing how the average number of persons per household had been, (and was expected to continue to be) in decline as the growth in single households increased, and the number of married couples reduced.

When separation and divorce is rife, as it is now, you need double the number of residences that a community of two parent families need. Each separated person needs somewhere to live, so two dwellings are needed where one was needed before.

Despite being a government that says it seeks to advance the family, there has been precious little to achieve this aim and much to damage it. Consequently we will continue to see a significant rise in the number of households needed in Fylde, and it will be necessary to accommodate this need (at least until Government produces the policies that makes staying as a family (preferably as an extended family) more advantageous). So there is an argument for some increase if the rate of family fragmentation has increased since the housing numbers were previously agreed.

Migration. The other big demand for property in Fylde is net inward migration. People like to live here, and there is significant demand for a seaside retirement property from people in say, east Lancashire, or Manchester or perhaps as far as Birmingham.

We do not believe Fylde has a duty (or even a responsibility) to sacrifice its countryside and its quality of life to meet the needs of inward migration. Quite the contrary, like the worst examples in Spain, that sort of attraction could become a fatal attraction and result in the denial of the very attractiveness of the area in the first place.

So we believe there is a proper debate to be had as to whether the numbers ought to be reduced on the basis of restricting inward migration in order to protect the current environment, and we now hope to hear that argument advocated strongly by those councillors who advocated reducing the numbers in private.

We also hope this article will help those who might wish to make a better informed comment to be able to do so.

Looking forward, the next stage in the local plan process after this consultation will probably be the more worrying for most folk.

It will decide where the 240 or 280 houses a year are going to be built.

This process is already causing ructions in Wyre (which is a bit further ahead than Fylde). Residents around Great Eccleston are up in arms at an expected increase of housing in their area.

Their Parish Council has boxed very clever. They undertook their own household survey a while back, and asked every resident in the village about their future housing needs. (we saw the forms that had been delivered). That gave the Parish Council a powerful local evidence base of their own.

We also understand they appointed their own expert consultant and they are now in the enviable position of being able to challenge Wyre BC's own evidence base.

That's what parish and town councils are, and should be, good at. Keeping Borough Councils honest.

A group that looks to us like a Provisional Wing of the Great Eccleston Parish Council but denying any such link and calling itself 'concerned residents who love their village' have put out two leaflets in Great Eccleston, both exalting residents to object to Wyre's Draft Core strategy. The first includes some interesting arguments that our readers might like to see. Follow this link to see the first leaflet in full. The second leaflet is more a follow up / reminder, but readers can follow this link to see the second leaflet for the sake of completeness if they wish.

Maybe some of Fylde's parish and town councils will do the same sort of thing in preparation to argue the case with Fylde.

Fylde has this week published its first main tranche of documents concerning the new local plan and we've provided readers with some links to the FBC website below:

About planning policy in Fylde

Timetable for the development of the local plan

Issues and Options - exhibition timetable and links

Issues and Options document  (PDF 5mb)

Housing numbers paper  (PDF 0.5mb)

Dated:  6 June 2012


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