Manchester City Council

MANCHESTER CITY COUNCIL

REPORT FOR RESOLUTION

COMMITTEE: Children and Young People Overview and Scrutiny Committee

DATE: 12th December 2006

SUBJECT: Transforming Education and Children’s Services: The Future Pattern of High School Provision in Manchester Co-Educational (Mixed) Schools and Single-Sex Schools

REPORT OF: Chief Executive, City Treasurer and Director of Children’s Services

PURPOSE OF REPORT:

To seek in principle approval to the future provision of co-educational and single sex maintained and Academy high schools in Manchester.

RECOMMENDATIONS:

1. That the results of informal consultation on the future balance of single sex and co-educational high school provision be noted.

2. That the proposals for future provision contained in this report be approved in principle, subject to the outcome of:

i) further discussions with Head Teachers, Governing Bodies, school staff, parents and pupils and other interested parties; ii) more detailed work on the financial, legal and educational implications of the proposals

3. That a further report be submitted to a future meeting of the Executive in respect of the next stage of the development of these proposals.

FINANCIAL CONSEQUENCES FOR THE REVENUE BUDGET:

None directly related to this report but elsewhere on the agenda an update on the Academies Programme highlights revenue consequences for the BSF/Academies Programme of which these proposals form part.

FINANCIAL CONSEQUENCES FOR THE CAPITAL BUDGET:

Previous reports to the Executive have outlined the proposals for BSF Waves 1 and 4 and the Academies Programme. The capital budget for the provision of the proposed new schools will be contained within the existing proposals for investment in the secondary schools estate, which is based upon the number of pupils in the City. There is an increased risk to the Capital Programme by building more/smaller schools than previously planned.The proposals in this Report involve schools to be funded from Wave 1 (Levenshulme High School for Girls, Burnage High School for Boys, and part funding for the new co-educational school on the Burnage site), Academies (the new dual single-sex Academy at the North Manchester High School for Boys site, and the new co-educational

Academy at the Rochdale Road/Queen’s Road site), and Wave 4 funding (Whalley Range High School and part funding for the new co-educational school on the Burnage site).

If implemented the proposals will generate a land sale from the surplus North Manchester High School for Girls site, and the receipts will be shared 50/50 with DfES after allowing the City Council the first £500,000.

CONTACT OFFICERS:

Dr Alan Irving, Chief Education Officer, 0161 234 7001, [email protected]

Geoff Little, Assistant Chief Executive, 0161 234 3317 [email protected]

Dave Carty, Head of Public Private Partnership Unit, Corporate Services Department, 0161 219 6266, [email protected]

Brenda Wile, Lead Officer, BSF Learning Transformation, 0161 219 6272, [email protected]

Liz Treacy, Head of Legal Services, 0161 234 3339, [email protected]

Allan Seaborn, Assistant Chief Education Officer, 0161 234 7155, [email protected]

BACKGROUND DOCUMENTS: See attached Appendices

WARD (S) AFFECTED

All

IMPLICATIONS FOR:

ANTI POVERTY EQUAL OPPS. ENVIRONMENTAL EMPLOYMENT YES YES YES YES

1. INTRODUCTION

1.1 Last year the authority consulted on the future of education and children’s services and the proposals for Academies; it was acknowledged that a subsequent consultation on the specific issue of co-education/single sex provision would be required. This has now taken place. Appendix A describes the consultation process and results. This report now proposes a way forward in respect of the future balance of co-educational and single sex schools.

2. ISSUES FOR CONSIDERATION

2.1 The informal consultation was conducted separately in North and South Manchester. In the North there was no clear-cut majority of those who responded in favour of either single sex or co-education. In the South there was an overall preference for retaining single-sex schools. Petitions were received from mosques

in favour of retaining single-sex schools, the majority focusing in favour of single- sex education for girls.

2.2 Consultation suggests that there is demand from communities and parents to be able to choose both co-educational and single-sex schools. There are strongly held views for both co-educational and single sex and the authority respects both sets of views. The proposals in this report are therefore aimed at offering sufficient single sex provision in the City, in either the maintained sector or Academies, to meet demand from parents who believe it provides a better learning environment and for those parents who prefer a single sex environment. The proposals also increase the number of co-educational places for parents who, under the current admissions policy, are only able to access single sex schools when co-educational provision is their first preference.

2.3 The population of the City is growing (mid-year estimate for 2005 441,000 up from 437,000 in 2004) and the proportion of that population from ethnic minority backgrounds is projected to rise from 21% to 28% by the time of the next census. Within these projections there are and will continue to be rapid changes in population size and composition as a result of migration into and around the City. Cultural and faith considerations such as the preference of Muslim parents are therefore likely to be a continuing and important factor in education provision in the City. Provision is therefore required that will attract people from different ethnic groups in each district so that separate education of different ethnic groups is avoided. Feedback from the consultation exercise has revealed strong support for single sex girls’ education in particular.

2.4 High quality schools are needed as part of the regeneration process to attract families and so increase the City’s population. Schools should not simply react to increases in population post regeneration. This, plus the fast changing demographics of this City, means that in each area a flexible approach is needed that can adapt to changing demographics and changing parental preferences for single sex and co-educational provision.

2.5 Capital for the school building programme and revenue for running the new schools will follow pupil numbers. If the authority is to have schools of the right size but also, where needed, single sex schools, we will need to get the best value out of the available resources. The proposals in this report therefore include some shared use of facilities to achieve economies of scale.

2.7 Any proposals will need to have the support of the key stakeholders, including communities, parents, Academy sponsors and school governing bodies, Head Teachers, staff and pupils. The proposals that follow have been discussed with the Head Teachers involved but further discussions will be needed with all stakeholders.

3. PROPOSALS

3.1 Clearly having all single sex schools is not an option as there is significant demand for co-education. An all co-education solution would fail to meet the objectives of parental choice, cohesion and flexibility. It is therefore proposed to promote a balance of co-education with some single sex provision but with single sex schools for boys and girls co-located on the same site. There would be one such pair of Academy schools in north Manchester on the North Manchester High

School for Boys site and one pair of maintained schools in south Manchester on the Levenshulme High School site. Whalley Range High School would remain as a single sex school for girls.

3.2 The dual single sex schools at North Manchester and Levenshulme would have entirely single sex teaching, i.e. separate learning accommodation for boys and girls. Sports facilities, dining areas, learning resource centres and other facilities would be shared on a timetabled basis creating economies of scale. Governance, leadership and management arrangements will need to be very clear to ensure that each single sex school gets the full benefit of the shared facilities whilst retaining their separate identities as single sex schools. A proposal under consideration is that each pair of schools would be federated as a single school with one governing body and one executive Head Teacher responsible for overall development and running of the site. Each school would then have its own Head Teacher for leadership and management of the curriculum and teaching. Further work is required to explore this option.

3.3 The preferred option for consultation in the south of the City would be to relocate Burnage High School to the Levenshulme site where there would be a 750 place boys and a 750 place girls school. A new 750 place co-educational school would be established on the Burnage site.

3.4 The preferred option for consultation in the north of the City would be to relocate North Manchester High School for Girls to the North Manchester High School for Boys site to create a 900 place girls and a 750 place boys ‘federated’ academy. A new 750 place co-educational academy would be created on a site at the junction of Rochdale Road and Queens Road, Harpurhey. Proposals for co-educational sixth form provision on both sites will be explored.

3.5 The organisation and governance of the North Manchester Academies is a matter that will require further discussion with sponsors and the DfES.

4. CONCLUSIONS

4.1 Officers have taken into account the feedback from the initial consultation exercise and have reviewed pupil-planning projections to arrive at the recommendations in this report. The Director of Children’s Services will report back to the Executive in due course on the outcome of further discussions on each of the proposals.

ANTI-POVERTY

Providing locally based integrated children’s services will address the needs of all Manchester children and contribute to the achievement of the five outcomes of “Every Child Matters”. Providing an adequate number and distribution of school places in high quality designed 21st Century premises is a key priority in raising educational attainment at GCSE; increasing school attendance; increasing special needs education through mainstream schools; meeting the requirements of the Extended Schools Prospectus; and assisting Manchester residents to access further education and employment opportunities. Through engagement with our private sector Sponsors we will be creating opportunities for the schools and their associated communities to be actively involved in creating an education system that will inspire them to want to learn, achieve and contribute to society; with the

aim of breaking the cycle of high unemployment and low aspirations.

EQUAL OPPORTUNITIES

Barrier-free access provision will be incorporated into the design of all new Manchester schools and other premises for integrated Children’s Teams.

ENVIRONMENT

The existing school estate is in urgent need of renewal or rebuilding. The new school buildings will directly contribute to Area Regeneration Initiatives in their respective areas. Investment in energy conservation, crime prevention measures, improving road safety adjoining new schools will all contribute to the development of a safe and attractive local environment improving the quality of life for Manchester residents. This will allow Children’s Services to contribute to the requirements for safety in “Every Child Matters”.

ECONOMIC/JOB

New partnerships with Manchester based businesses through our Education Partnership Programme will create new opportunities to equip young people with academic, vocational and life skills. The new school building programme will create opportunities during construction and Officers will work with private sector partners, Learning and Skills Council and vocational training educational providers to link trainees directly to the opportunities created by the investment. The ‘Industry Clusters’ (one Academy linked with three/four BSF schools city-wide) will also provide opportunities to engage pupils in a focused ‘employment curriculum’ as part of the 14-19 agenda, as well as enabling our teaching staff to experience working in our Sponsors environments. There will also be opportunities for training the long-term unemployed as teaching assistants with placements in the new schools. This will help children achieve the “Economic Well Being” outcome of “Every Child Matters”.

APPENDIX A

Consultation of the future pattern of co-educational and single sex schools in Manchester, November 2006

1. CONSULTATION PROCESS

1.1 Two consultation leaflets were designed, one for North Manchester and one for Central/South Manchester. Each leaflet outlined the results of the first consultation and the proposed BSF plan for the relevant area.

1.2 A short questionnaire asked respondents to give their name, address and designation (parent, pupil etc) as well as their opinion on whether schools should change to co- educational, stay single sex or in the case of Levenshulme change to dual single-sex education on one site. There was space for respondents to explain reasons for their preference.

1.3 60,000 leaflets were produced and distributed to stakeholders across the City and 3,595 completed questionnaires were returned by the extended deadline of 31st July 2006. This represents a response rate of just less than 6%. Pupils, parents and staff accounted for two thirds of the response.

1.4 Approximately 25,000 leaflets were distributed to North Manchester; to parents, pupils, staff and governors of North Manchester High School for Boys and North Manchester High School for Girls; to primary schools in the area in sufficient numbers for all parents; to all Headteachers and Chairs of Governors of other high schools in the North with extra copies for them to distribute; to community and religious groups with translations available upon request; and to libraries and regeneration offices. Additional leaflets were distributed following requests. 1,370 completed questionnaires were returned from the North.

1.5 Approximately 35,000 leaflets were distributed to Central/South Manchester; to parents, pupils, staff and governors of Burnage High School, Levenshulme High School and Whalley Range High School; to primary schools in the area in sufficient numbers for all parents; to all Headteachers and Chairs of Governors of all other high schools in the central/south districts with extra copies for them to distribute; to community and religious groups with translations available upon request; and to libraries and regeneration offices. Additional leaflets were distributed following requests. 2,225 completed questionnaires were returned from Central/South Manchester.

1. RESULTS OF CONSULTATION: NORTH

a. Opinion is very evenly split in the North of the City with 45.54% of respondents opting to retain single-sex education and 46.20% opting to change to co-educational. 9% of responses stated they had no opinion.

b. There are two affected schools in North Manchester. We received a good level response from North Manchester High School for Girls with 890 replies in total, with 389 responses from North Manchester High School for Boys.

c. At North Manchester High School for Girls the overall consensus was to retain single-sex status with 85% of staff and 55% of pupils in favour of this whereas the reverse was true at North Manchester High School for Boys with pupils, parents and staff opting to change to co-educational, with a majority of pupils (82%) selecting this option.

d. Overall pupils in the North were in favour of changing to co-educational with 54% selecting this option. 37% were in favour of retaining single-sex and 9% offered no opinion.

e. Of the 100 staff that responded from the North, 80% were in favour of retaining single-sex education. 88 responses out of 100 were received from North Manchester High School for Girls.

f. There were no responses received from community groups in the North, however, two petitions were received which referred to schools in the North and these were both in favour of retaining single-sex.

g. There was a low response rate from Chairs of Governors, Councillors and other Headteachers with 4 respondents opting to change to co-educational and 1 in favour of retaining single-sex.

2. RESULTS OF CONSULTATION: SOUTH

a. Overall the preference in the South of the City is to retain single-sex education with 59% of respondents in favour of this option and 36% in favour of changing. 27% stated a preference to change to co-educational and 9% to a dual single-sex school on a single site.

b. The results for pupils in the South were evenly split with 39% of pupils in favour of retaining single sex and 38% in favour of changing to co- educational schools. 14% of students selected the dual single-sex on one site option and 14% offered no opinion.

c. There was a higher response rate from parents in the South with 580 completed questionnaires received against 282 in the North. Parents in the South were overall in favour of retaining single-sex with 70% selecting this option. 25% were in favour of changing to co-educational and 4% were in favour of the dual single-sex option. 1% offered no opinion.

d. Of the school staff responses, 64% chose the single-sex option and 21% were in favour of changing to co-educational. 13% selected the dual single-sex option and 2% offered no opinion.

e. All completed questionnaires received from community groups were from the South and were returned with petitions received from Mosques. 98% of respondents were in favour of retaining single-sex with only 1% in favour of changing to co-educational and only 1 respondent was in favour of the dual single-sex option. A further 1% offered no opinion.

f. Seven petitions were received containing over 2,200 signatures opposed to abolishing single-sex education in Manchester.

g. There were 16 responses from Chairs of Governors, Governors and other Headteachers with 5 in favour of retaining single-sex, 4 in favour of changing to co-educational and 6 preferring for the dual single-sex option. One respondent offered no opinion.

h. A majority of pupils, parents and staff at Levenshulme High School for Girls were in favour of retaining single-sex education with an overall percentage of 48% selecting this option. 33% were in favour of changing to co- educational and 11% opted for dual single-sex. 8% stated no opinion.

i. Results from Whalley Range High School for Girls were similar to those at Levenshulme with 54% in favour of retaining single-sex, 26% in favour of changing to co-educational and 16% opting for the dual single-sex on one site.

3.10 A large majority of parents and staff were in favour of retaining single-sex education at Burnage High School with 77% and 58% respectively choosing this option. However, pupils were in favour of changing to co-educational with 45% selecting this option and 32% in favour of retaining single-sex.

RESULTS OF CONSULTATION: NORTH

Keep Change to No Opinion Total single-sex co-ed Pupils (North) 362 (37%) 521 (54%) 90 (9%) 973 Parents (North) 176 (62%) 95 (34%) 11 (4%) 282 Staff (North) 80 (80%) 10 (10%) 10 (10%) 100 Community Groups 0 0 0 0 (North) Chair of Governors 0 1 0 1 (North) Councillors (North) 0 2 0 2 Headteachers (North) 1 1 0 2 Other/Not specified 5 3 2 10 Total North 624 633 113 (9%) 1370 (45.54%) (46.20%)

North Manchester High School for Boys

Keep Single Change to No Opinion Totals Sex Co-ed Pupils 26 (7%) 291 (82%) 37 (11%) 354 Parents 7 (30%) 16 (70%) 0 23 Staff 5 (40%) 6 (50%) 1 (10%) 12 Total 38 (38%) 313 (80%) 38 (10%) 389

North Manchester High School for Girls

Keep Single Change to No Opinion Totals Sex Co-ed Pupils 334 (55%) 226 (37%) 52 (8%) 612 Parents 139 (73%) 45 (24%) 6 (3%) 190 Staff 75 (85%) 4 (5%) 9 (10%) 88 Total 548 (61.5%) 275 (31%) 67 (7.5%) 890

RESULTS OF CONSULTATION: SOUTH

Keep Change to Dual No Total single-sex co-ed Opinion Pupils (South) 445 (39%) 431 (38%) 161 (14%) 98 (14%) 1135 Parents (South) 408 (70%) 146 (25%) 22 (4%) 4 (1%) 580 Staff (South) 39 (64%) 13 (21%) 8 (13%) 1 (2%) 61 Community Groups 381 (98%) 3 (1%) 1 4 (1%) 389 (South) Chair of Governors 3 1 2 1 7 (South) Governors (South) 1 2 1 0 4 Councillors (South) 0 0 0 0 0 Headteachers (South) 1 1 3 0 5 Other/Not specified 35 9 1 1 46 Total South 1313 606 (27%) 199 (9%) 109 (5%) 2227 (59%)

Levenshulme High School for Girls

All Keep Change to Dual No opinion Total Single Sex Co-Ed Pupils 201 (44%) 162 (36%) 55 (12%), 36 (8%) 454 Parents 36 (86%) 5 (12%) 1 (2%) 0 42 Staff 8 (73%) 1 (9%) 2 (18%) 0 11 Total 245 (48%) 168 (33%) 58 (11%) 36 (8%) 507

Whalley Range High School for Girls

All keep Change to Dual No Opinion Total single sex co-ed Pupils 102 (40%) 81 (32%) 58 (23%) 14 (5%) 255 Parents 95 (84%) 16 (14%) 2 (2%) 0 113 Staff 12 (75%) 2 (12.5%) 2 (12.5%) 0 16 Total 209 (54%) 99 (26%) 62 (16%) 14 (4%) 384

Burnage High School for Boys

All keep Change to Dual No opinion Total single sex co-ed Pupils 135 (32%) 187 (45%) 48 (11.5%) 48 (11.5%) 418 Parents 93 (77%) 28 (23%) 0 0 121 Staff 18 (58%) 8 (26%) 4 (13%) 1 (3%) 31 Total 246 (43%) 223 (39%) 52 (9%) 49 (9%) 570

INTERPRETATION OF COMMENTS RECEIVED

The questionnaire included a space for respondents to comment on the reasons for their choice. To assess the reasons given it was necessary to categorise them in order to provide valid results. The majority of respondents gave more than one reason and it was decided all reasons would be counted. The results are therefore quantitative rather than qualitative

Reason stated Performance Ethnic or Right to No specific Other to retain single- /Attainment Religious choose or relevant sex beliefs reason North 451 29 86 85 44 South 558 246 187 397 156 Overall 1009 275 273 482 200

For those respondents that preferred to retain single-sex education, the most frequently stated reason (provided by 52%) was a belief that students perform better in single-sex schools. The performance of single-sex schools was the predominant reason given for retaining single-sex education in the North with 72% stating this belief against 42% in the South.

Ethnic or religious reasons were also stated in support of retaining single-sex education with this feeling being stronger in the South where 19% of respondents stated this against 5% in the North.

Having the right to choose was given as a reason by 14% of respondents in the North and in the South.

Reason stated Increases Reflects Brothers Personal No specific to change to tolerance society and sisters experience or relevant co-educational and respect at same reason school North 214 103 21 64 170 South 200 148 27 34 109 Overall 414 251 48 98 279

210 respondents in total opted to change to co-educational because they felt pupils perform better in co-educational schools, and 175 gave other reasons such as affects curriculum or have already experienced co-education at primary school.

For those respondents who selected to change to co-education the most frequently stated reason was a belief that it increases tolerance or respect amongst pupils and allows them to have friends or understand members of the opposite sex. This accounted for 34% of respondents’ reasons.

Other statements given for changing to co-education were the belief that co-education better reflects society (20%) and allows brothers and sisters to attend the same school (4%). Some respondents referred to personal experience and 23% did not specify a reason. 17% of respondents preferred to change to co-education because they felt young people perform better when educated together.

In general there was little difference between the North and South when it came to reasons given for a change to co-education. They reflected each other very closely with the belief that co-educational schools increase tolerance and respect being the most frequently stated reason for both locations.

The option to change to dual single-sex education on one site was only available to respondents in the South and reasons given for this followed arguments for both single- sex and co-educational. 27% stated a belief that some form of integration increases tolerance and respect amongst pupils and 22% commented that this option would provide a choice for parents. Some respondents made reference to children learning better together (17%) whilst some felt that they performed better separately but needed interaction with the opposite sex (10%).

LIMITATIONS OF THE CONSULTATION

The quantitative nature of reasons given by respondents meant they had to be grouped into the following categories before they could be analysed: Religious/Ethnic choices, Personal experience, Improved performance in single-sex, Improved performance in co- education, Accurate reflection of society/more natural, More convenient, Increases tolerance/respect. See Appendix 3.

These categories were based on a number of criteria for each and this may have resulted in losing some of the nuances within them, for example Improved performance in single- sex included the issues of having fewer distractions or negative influences, arguing and bullying.

Many respondents gave more than one reason for their preference and there was no way of judging what priority they had assigned to these reasons. As a result of this, each separate reason given was counted meaning it is not possible to form a correlation between reasons, for example, how many of those who believed that co-education increased tolerance also believed that it better reflected society.

The questionnaire did not ask parents to indicate the sex of their child or the school they attended and therefore we were unable to form a correlation between this and the reasons behind their preference. For example, with those respondents who selected a change to co-education and stated their reason as improved performance, we are unable to accurately tell whether they were parents of boys or girls.

One option given in the questionnaire was for Levenshulme to maintain two single-sex schools with some shared facilities (dual single-sex education on one site). This would be an unfamiliar concept to many and there was little space available to explain it fully in the consultation leaflet. This may have resulted in fewer respondents selecting this option.

The questionnaire did not ask respondents to state whether they had a son/daughter who attended an affected school therefore with the large responses from community groups (especially in the South) it was impossible to separate out the affected parents from the interested parties.

Due to the large number of responses received from some groups it is clear that there are strong feelings for retaining single-sex education. Some of these responses appear to have been organised which will have influenced the results in favour of retaining single- sex education both in the North and the South.

Interpretation of Comments

Having received a number of returns the responses can be divided into the following categories to aid interpretation of the data. The following is a useful guideline to the categories chosen.

Religious/Ethnic Preferences – any reference or comment suggesting single sex is preferable for cultural or religious reasons.

Personal Experience – any suggestion of experiences in attending a single sex/co-ed school. Pupils’ suggestions of how single sex/co-education affects them directly e.g. it would make their school life more/less interesting or more/less happy.

Boys/Girls perform better in Single Sex - (Fewer distractions/Negative influences). Any reference to personal opinion or studies indicating pupils perform better in single sex schools. This also includes any reference to distractions and negative influences that could affect performance. These include arguing, bullying, racism and any reference to ‘distractions’ because of the presence of the opposite sex.

Boys/Girls perform better in Co-Education – any reference to the children performing better in class because of more varied opinion/ alternative points of view from having members of the opposite sex present. This may also include reference to negative impact on education of not having opposite sex present in particular stopping girls/boys truanting to go off and see members of the opposite sex.

Reflects Society/Co- Education more natural – any reference to the fact that boys and girls should mix as it is the natural way of things. Also refers to the fact that males/females will mix in later life socially / in the work place (reflects true social demographics.) This should include references to equal opportunities and balance in society.

More Convenient (Children at the same school) – this relates mainly to the parents – if they refer to having children of both sexes and therefore it is easier for them to go to the same school. Also could include responses from pupils who would prefer siblings to attend the same school.

Increases Tolerance/Respect – any reference to co–education schools providing more understanding amongst pupils of each other’s feelings or what makes them different or similar. This also includes any suggestions of the need/pupils desire to learn to make friends or socialise with the opposite sex or improving social understanding/mixing socially. Include any reference to co-education decreasing bullying or creating a calmer environment.

Inappropriate for Boys/Girls to mix – this category relates primarily to any ‘natural’ interest that boys and girls may have in each other in negative terms. Parents may suggest children are too young to have boyfriends/girlfriends. It may not be in the best interests of the children to follow their hormonal instincts. More extreme comments concerning inappropriate sexual encounters/ increased chance of pregnancies or abuse should also be included in this category.

Right To Choose – this relates to both the co-educational and single sex options. Any mention of choice or personal desire to choose which kind of school the children go to in the area or any mention of having the right to have the option available to them.

Affects Curriculum – where the choice of subjects available may be affected because of co-ed or single sex provision. Perhaps more subjects available in co-education or bias towards some subjects being more popular amongst boys/girls.

Currently Unequal Distribution - this concerns any reference made to the current distribution of co-educational or single sex schools – either reference to there not being enough or being too many in the area.

Already experience Co-ed at primary level – this concerns any reference to co- educational schools having success at junior level therefore little need to change the status quo. The pupils may also refer to being separated from their friends from junior level by going to single sex school.

No Specific Reason – this category accounts for responses that are not relevant to the issue, too vague or where there is simply no comment provided. For example, if the reason is ‘because it will be better’ this is far too general, so this category should be selected. If the response is not of a serious nature again this should be selected. Any issues that relate to more everyday issues such having to travel further or having to move schools should be placed in this category as this consultation is about the issue of single sex/co-ed schools and is therefore unrelated to this consultation.