Response from Herts County Council to BSCF's Formal Objection to Proposed Schools' Relocation
Letter from John Harris, Director - Schools Children and Families, Herts County Council to Kevin Steptoe, Head of Development Control, East Herts District Council
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Reply from the BSCF Top
Mr C Dempster
Head of Development Control
East Herts Council
|26 October 2008|
Your Refs: 3/08/1101/OP, 3/08/1102/OP, 3/08/1103/OP, 3/08/1115/OP, 3/08/1116/OP, 3/08/1117/OP
APPLICATIONS TO BUILD TWO SCHOOLS AT WHITTINGTON WAY BISHOP'S STORTFORD AND HOUSING ON THE SITES TO BE VACATED AT WARWICK ROAD, BELDAMS LANE, LONDON ROAD AND ON THE RESERVE SITE AT HADHAM ROAD
1. The Bishop's Stortford Civic Federation have seen copies of the separate letters from the Essex and the Herts County Councils' Children, Schools and Families Directorates dated respectively 1 September and 2 October 2008 which comment on these planning applications and, in the case of the Herts letter, on the representations made by the Civic Federation in its letter of 18 August. The Herts County Council letter contains a number of misleading and unsubstantiated assertions which the Civic Federation believe should not be allowed to pass unchallenged, and I am therefore writing to you to comment on them. I hope you will be able to take these further representations into account in making your report to the East Herts Development Control Committee.
Essex County Council Representations
2. Briefly, Essex County Council's letter notes that:
- 2 – 3 FE of the two foundation schools' intakes comes from Essex – 550 pupils in total in years 7 – 13.
- Over 1000 Essex pupils attend all Bishop's Stortford secondary schools.
- With no change in the foundation schools' admissions criteria the number of pupils attending these schools who live in Essex could be expected to increase proportionally to any increase in the size of the schools.
- Therefore there can be no guarantee that enlarging these schools would give Bishop's Stortford residents any greater chance than now of securing a place at a local school.
- There would be adverse traffic congestion impacts on the town.
- There would be an adverse impact on the nearest Essex secondary school, contrary to the assertion made in the applicants' Supporting Planning Statement
- Essex County Council have not been consulted about the proposals even though there is a statutory obligation to do so.
3. Herts County Council in its response notes simply that it cannot control the schools' admissions policies (or those of two of the other Bishop's Stortford schools) and that it supports the relocation of those schools with unchanged admissions policies. This response ignores the other serious criticisms summarised above, in particular, the legitimate concern of a neighbouring education authority about the risk of compromising the viability of one of its own schools as a result of this proposal. The Civic Federation agree with Essex County Council that their interests as LEA and those of current and future generations of Essex pupils have been entirely ignored. We also observe that, were Herts County Council to build a new school at Hadham Road as we advocate, it would be able to set admission criteria based on geography which would improve the prospect of Bishop's Stortford parents being able to send their children to a local school. As Essex County Council points out, the current proposals provide no such opportunity.
4. Herts County Council have commented on our representations using the same headings as those in our letter of 18 August. This response therefore follows the same format.
Size and Condition of Schools
5. Finance and funding are issues which should have no bearing on a decision on a planning application, but since the County Council appear to think that this forms part of the exceptional justification for setting aside Green Belt protection, we feel we should respond to the points made. Both schools opted some years ago for financial independence as a consequence of foundation status. It has been the responsibility of their Boards of Governors to budget for all the costs of running their schools including the maintenance of their property. It is not for the Civic Federation to tell them how to set and manage their budgets, but if they spend their funds properly there is no reason why the buildings should be subject to further deterioration.
6. The Herts and Essex School, which has the oldest buildings, appears to be in generally good condition and would seem to require no more than the replacement of a small number of inconveniently sized classrooms, which could easily be undertaken without relocation. A new hall and sixth form block were completed some 10 years ago and this would be no more disruptive or challenging a task. The Boys High School may be in a worse state of repair, but we question whether it is uniquely inadequate in a County which has many school buildings of a similar vintage. In any event, as we and the CPRE have pointed out, rebuilding in situ is feasible and therefore provides no justification for moving to the Green Belt.
Viability and School Size
7. The County Council offers no new arguments to support the claim that bigger schools are better, and ignores the evidence in our previous letter that both teachers' leaders and senior politicians in the education field believe that larger schools risk prejudicing educational accomplishment and social skills. The response also downplays the outstanding achievements of all our local schools, particularly Hockerill Anglo European College which has the oldest buildings and the smallest intake. We remain of the view that not moving to a new location will be less disruptive to the education of the current generation of school pupils than these proposals.
8. The County Council appears unable to understand the simple point and strongly expressed wish of Bishop's Stortford parents that a separate, new school will offer them a wider range of choice than merely enlarging the institutions we have already. For those parents whose preference is for single sex education, we question whether shared school transport, shared recreational areas, shared use of sports facilities and co-educational sixth forms, will be seen by them as meeting their aspirations. Since parents have not been consulted about the move the County Council is in no position to respond to this concern.
9. Turning to the balance between single sex and co-educational places, we share the view of Mr Martin (County Head of School Access) who, in his evidence to the Local Plan Inquiry in 2005 said ‘Expansion…of St Mary's which, as a faith school with a wide catchment area, would not address the issue' [of the prospective shortfall in places]. Similarly it should not be included in any assessment of the balance between single sex and co-educational places.
The Shortfall in School Places
10. The County Council claims that the Civic Federation's calculation of the shortfall in school places is unrealistic because it uses ‘unorthodox methodology and has made errors in calculation and assumptions.' We believe that the methodology we have used is both logical and entirely transparent whether or not it is ‘unorthodox'. It relies solely on data published by the County Council which we presume to be accurate. We also believe it gives a more accurate reflection of the difficulty Bishop's Stortford parents experience in getting their children into a local school than the applicants' calculations which the County Council support.
11. We are not aware of any errors of calculation. The County Council has cited no specific errors of either calculation or assumption. We therefore trust that you will disregard these unsubstantiated criticisms unless they are supported by specific examples. Should the County Council be able to provide any specific examples we would of course like the opportunity to consider them.
12. Turning to the calculations favoured by the County Council, the applicants have not disclosed, and we therefore have no idea what factor they have used to convert a forecast of additional housing into an estimate of school places required. It may have no evidential basis but we have had to rely upon it in our own calculations, in the absence of anything else. We are also unable to understand how or why the applicants have converted a shortfall of 288 places in 2011 (their figure) into only 2 FE. Clearly this is arithmetically incorrect but in the absence of any disclosed assumption we have had to speculate about both the conversion factor and its rationale. If our speculation is correct, we believe the rationale underlying the conclusion is nonsense.
13. Finally, we suspect that the applicants and the County Council (like us, we admit) have overlooked the fact that this year's and future years' intakes at year 7 will have to remain in full time education until the age of seventeen. The annual intake at all Bishop's Stortford secondary schools (apart from boarding places at Hockerill) is about 780 pupils. About half are likely to stay on into the sixth form anyway and thus add no further pressure on places. However, if only half of the remainder stay on at school rather than moving to another educational institution, our schools will have to find an additional 195 places (6.5 FE), a point which we believe adds weight to our contention that there will be ample demand for a 6 FE school if the additional housing assumed by the applicants materialises.
14. The other argument put forward by the County Council under this heading can be characterised as ‘ Trust us – we're professionals'. However, it is precisely because the parents of Bishop's Stortford believe that the County Council have failed to plan adequately for the inevitable educational consequences of the additional housing they have known about for years that we can have no confidence in the methods and assumptions the LEA have used to support their professional judgment.
The Hadham Road Site
15. We are pleased that the County Council now accepts that the site is large enough for a 6 FE school. For years past it has been asserting the exact opposite – clearly inaccurately. Since the County Council argues that provision of the full range of sports facilities would entail the loss of woodland, it is worth recording the views of the applicants' consultants in their environmental assessment of this site:
"An area of woodland and scrub which contains some mature trees, chiefly ash with some oak and sycamore, with many smaller trees including hawthorn and fruit trees. The site does not have any significant existing and future effects on birds, mammals and bats."
The Federation's President, who has lived in the area for nearly fifty years, comments:
"The environmental consultants also say that the proposal would result in a loss of a small area of scrub which forms part of the existing woodland which itself is relatively recent and is of little ecological interest
The woodland, much of which is a decayed orchard is inundated with ivy both as continuous ground cover and totally covering all the trees.
Much of it is impenetrable and has little or no amenity value. Its loss (for school playing fields) would be insignificant."
16. We recognise that development of a 6 FE school would require use of the whole site but note the County Council's view that this would meet the need for on site sports pitches. On the question of sharing facilities with the Rugby Club, peak use of club facilities and of school facilities are at different times of day and days of the week. The availability of the school pitches for practice outside normal school hours would thus avoid any need for the intensification of the use of Jobbers Wood. Other sports facilities such as squash courts might also benefit from shared use.
Schools in the Community
17. Effective engagement with the community depends on the physical accessibility of the schools. As our evidence has demonstrated, the accessibility of the Whittington Way site is significantly worse than the schools' present locations. Moreover, use of the Hadham Road site for a school would improve accessibility still further by serving a quadrant of the town which has no such facilities at present.
18. It should also be noted that all the sports facilities at a Hadham Road school would be wholly additional to those the two schools have at their present locations. Relocating to Whittington Way would mean that the new facilities would be largely substitutes for those in place already but which would be lost to housing development. For example, the 4 lane Herts and Essex swimming pool would be replaced by a 6 lane pool at Whittington Way, but it would have to serve a school population three times as large. A new school at Hadham Road would enable an extra school swimming pool to be built with a correspondingly smaller demand being placed on it by the school population. Sport England's acquiescence in the proposed move to Whittington Way may possibly have arisen from an incomplete presentation of the facts to them.
Funding and Timing
19. We repeat that while these are not germane to a decision on a planning application, we cannot allow the County Council's points to remain unanswered. As the applicants have pointed out, Bishop's Stortford has provided over 40% of East Herts' total housing allocation since 1991. Those houses have generated council tax revenues for our local authorities and income tax revenues for central government. Central and local taxation are the ultimate sources of any finance for new schools, whatever funding mechanism is used. Education is by far the largest local authority budget and how and where it is spent is a matter of choice by the LEA. Their response makes it clear that they have chosen not to spend Bishop's Stortford's taxpayers' contributions in the way that the local community would wish, but instead pay for a schools relocation which the community opposes by inflicting unwanted additional housing in inappropriate locations in the town. The huge environmental damage which the whole of the community would have to bear is completely ignored by the County Council.
20. The main risk to the development of a new school at Hadham Road is the obstinate refusal of the County Council to contemplate building on a site it already owns. Meanwhile an opening date of 2011 for relocated schools at Whittington Way is looking increasingly implausible, and with the housing market continuing to decline we have seen no evidence that finance will be available from developers in sufficient amounts to pay for a move at any time in the near future (or indeed any evidence at all to support the claim that developers' contributions would be sufficient to pay for the relocation). Decisions on these applications will have a profound effect on educational provision and the physical development of Bishop's Stortford for decades to come. They should not be influenced by short term financial considerations.
21. We have commented on the main point at issue in para 7 above. As to the quality of leadership which the County Council and the Boards of Governors have demonstrated in bringing the relocation proposals forward, I would merely observe that the failure to consult current and prospective parents of pupils at the schools, all but one of the feeder schools, or the adjacent LEA speaks for itself.
22. Turning to the example quoted of Janveh School, we raised this simply to illustrate that it is perfectly possible to start a new school from scratch. We believe that we have demonstrated that there is substantial underlying demand for a new school in Bishop's Stortford, and that building one on a green field site which is already available would provide a more attractive opportunity to grow facilities in line with the school population than moving into second hand buildings as Janveh School appears to have done.
The Consequences of not Granting Permission
23. The tone and content of its remarks indicate that the County Council is not prepared to enter into a rational discussion about any alternative to its own preferred proposals. It seems rather to have decided on the solution first and then defined the problem so as to fit it. In the process, the impact on the community, which would be hugely and wholly adversely affected, has been ignored. I would comment briefly on the points in the County Council's letter as follows:
- The County Council have advanced no reasoned argument for refusing to develop plans for a new school at Hadham Road.
- The County Council appear determined to foist the cost of schools expansion on to the local community by inappropriate use of the schools' existing sites for housing.
- The County Council appear to acknowledge that there could be an alternative location (on the ASRs) even for their preferred option which would not involve building on the Green Belt.
- We share the view of the County Council that it would be a thoroughly bad idea to locate the majority of secondary school places on the periphery of the town. That objection applies with equal force to the Whittington Way site as it would to the ASRs.
- The County Council notes that development of the ASRs (which we oppose) would require full implementation of the Bishop's Stortford transport strategy. It seems to have overlooked the fact that the applicants' transport assessment of the Whittington Way relocation has made exactly the same assumption.
24. The fact that there clearly are alternatives to the proposals in these applications to which proper consideration has not been given is in itself a sufficient reason for refusing permission for development on the Green Belt. The case for doing so has been strengthened by the Government's recently announced decision to permit Stansted Airport to expand from 25 to 35 million passengers per annum. Even without any alteration to flight paths, this will lead to the Whittington Way site breaching the noise regulations for new schools on a regular rather than occasional basis. The County Council's response ignores this issue.
25. I should be grateful if you would include these additional representations from the Civic Federation in your report to the Development Control Committee.JOHN RHODES
Bishop's Stortford Civic Federation