Education Impact Assessment Wynsome Street, Southwick
Final
September 2017
Contents
1. Introduction 3
2. Primary Education 7
3. Secondary education 17
4. Developer Contributions Requested 28
5. Establishing Appropriate Contributions 32
Appendix 1: Correspondence with Wiltshire Council 34
Amy Gilham Director, Economics Turley September 2017
1. Introduction
Purpose of the Report
1.1 This Education Assessment has been prepared on behalf of Gladman Developments (the ‘applicant’) by the Economics team at Turley, one of the UK’s largest independent planning consultancies. The assessment relates to the planning application for a residential development (the ‘proposed development’) at land off Wynsome Street, Southwick, Trowbridge.
1.2 Wiltshire Council has been identified as the Local Education Authority (LEA) relevant for the proposed development. In the Planning Consultation Response regarding the proposed development, Wiltshire Council has requested developer contributions for education as follows:
Table 1.1: Request for Developer Contributions, primary and secondary provision
Level of education Cost per pupil No. pupils generated by Total proposed development
Primary education £17,545 38 £666,710 provision
Secondary £23,3161 272 £629,532 education provision
Total £1,296,242
Source: Planning consultation response, Wynsome Street, Southwick, 11th August 2017
1.3 The Council has indicated that a new primary school is needed in the area though has not requested contributions for a specific primary school. It has indicated that the proposed development is likely to be refused planning permission unless a site for a new primary school comes forward. For secondary provision, the Council has stated that contributions will be used towards the extension of John of Gaunt secondary school or be pooled towards the provision of an additional secondary school, depending on the timing of the development3.
1 Correspondence with Wiltshire Council on 11th August 2017 provided an updated cost per pupil for the secondary level. Earlier correspondence in May 2017 stated that the secondary cost per pupil was £21,747, however this was produced using 2016 costings, which is now out of date and is superseded by the £23,316 figure. 2 The original pre-application response provided by Wiltshire Council on 2nd May 2017 incorrectly calculated the request for secondary level contributions for 20 pupils. This has been amended to 27 and the request for contributions has been changed accordingly. 3 Wiltshire Council, Planning Consultation Response for Wynsome Street, Southwick, 2nd May 2017
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1.4 This report sets out to further understand the evidence and request for contributions sent by Wiltshire Council to Gladman Developments. The following documents have been considered:
Planning consultation response, Wynsome Street, Southwick, sent from Wiltshire Council to Gladman on 2nd May;
Data and information provided by Wiltshire Council, sent to Turley on 11th and 17th August 2017 detailed in the Appendix;
Wiltshire Council, School Places Strategy, 2015 – 2020;
Wiltshire Council, Core Strategy, adopted in 2015.
1.5 The supply and demand for primary and secondary education has been reviewed in schools relevant to the location of the proposed development4 to inform the level of developer contributions that we consider proportionate and reasonable in light of the impact of the proposed development in accordance with CIL Regulation 122. 1.6 Our analysis identifies that it is reasonable to request £263,175, equivalent to 15 primary places. We find the request for contributions for secondary provision to be unjustified. Therefore, of the £1,296,242, we find that only £263,175 is reasonable, equivalent to 20.3% of the total request for contributions.
1.7 We identify a number of points of challenge with regards to Wiltshire Council’s approach to establishing developer contributions for education. A key point for challenge, at the primary level, is that Wiltshire Council requests education contributions based on the two closest schools while it considers the wider Trowbridge Town area as relevant to pupil demand from the proposed development. We therefore present our assessment of primary based on a wider geography, which includes the 2 schools used as the basis for developer contributions as well as the Trowbridge Town area. Importantly, we consider that the Council’s approach is inconsistent and is inappropriately applied in the request for contributions.
1.8 This assessment challenges Wiltshire Council’s approach in the following ways:
• Point of Challenge 1: Inconsistent geographies of analysis are used by Wiltshire Council
• Point of Challenge 2: Additional primary provision will form part of wider developments and is not taken into account by Wiltshire Council
• Point of Challenge 3: At the primary level, the inclusion of non-approved schemes is hypothetical and leads to an overestimation of future demand
• Point of Challenge 4: Cross catchment pupil movements are not taken into account in assessing demand
• Point of Challenge 5: Wiltshire Council’s supply-demand position is challengeable
4 Early years provision is not considered in this assessment as Wiltshire Council have advised that existing provision will be able to support the demand brought about by the proposed development.
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• Point of Challenge 6: At the secondary level, the inclusion of non-approved schemes is hypothetical and leads to an overestimation of future demand
• Point of Challenge 7: Not all pupils from the proposed development will attend secondary schools within Trowbridge
• Point of Challenge 8: Wiltshire Council consider that there will be no surplus capacity at secondary level but the data indicates surplus to accommodate demand
• Point of Challenge 9: The School Places Strategy acknowledges that additional provision is required but does not indicate this should be a reason to not meet housing need
• Point of Challenge 10: The deficit in demand is not sufficient in scale to warrant provision of a new school in the Southwick area and therefore finding a site for a new school should not be used as a reason for refusal
• Point of Challenge 11: Limited options for expansion are considered by the Council
• Point of Challenge 12: At the secondary level, there is sufficient capacity within the area to accommodate additional pupil growth
1.9 The above points of challenge are detailed throughout the assessment.
Proposed Development
1.10 The proposed development is for 140 residential dwellings at land off Wynsome Street, Southwick, which is within the Wiltshire Council administrative area. A location plan is shown below.
Figure 1.1: Location map of the proposed development
Source: Gladman Developments, 2017
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1.11 Since the application is at outline stage, the accommodation schedule is currently reserved. However, an indicative mix has been provided by the applicant, as shown below.
Table 1.2: Indicative Accommodation Mix
No. Beds Affordable Market Number of Units % of units
1 bed 0 0 0 0
2 bed 33 9 42 30.0
3 bed 13 34 47 33.6
4 bed 11 34 45 32.1
5 bed 0 6 6 4.3
Total 57 83 140 100.0%
Source: Gladman Developments, 2017
Structure of Report
1.12 The remainder of the report is structured as follows:
• Chapter 2: Primary Education - This section reviews existing and future capacity of relevant primary schools within the area, considers the impact of cross catchment movement, expansion plans and primary school demand arising from wider development and the proposed development;
• Chapter 3: Secondary Education - This section reviews existing and future capacity of the 3 secondary schools within the area, considers the impact of cross catchment movement, expansion plans and secondary school demand arising from wider development and the proposed development;
• Chapter 4: Developer Contributions - This section reviews Wiltshire Council’s request for developer contributions with regards to the evidence presented in Chapters 2 and 3 and;
• Chapter 5: Establishing Appropriate Contributions - Draws on the evidence collected to establish an approach to calculating reasonable education contributions.
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2. Primary Education
Context
2.1 Southwick CoE Primary School has been identified as the nominal catchment school by Wiltshire Council5. A further local school is referenced with regards to capacity and the need for contributions. The Planning Consultation Response, provided by Wiltshire Council indicates that there are four primary schools relevant to the proposed development. However, in this document and additional correspondence, the Council also references the wider geography of Trowbridge Town6.
Point of Challenge 1: Inconsistent geographies of analysis are used by Wiltshire Council 2.2 Wiltshire Council applies inconsistent approaches to considering developer contributions and wider school place planning. The geography used to establish developer contributions is based on the two closest schools (Southwick CoE Primary School and North Bradley CoE Primary School). However, in its Planning Consultation Response Wiltshire Council recognises that these are not the only schools of relevance to the proposed development. It identifies that a wider number of schools are within a safe walking distance of the development7:
“Some Trowbridge town primaries are also within 2 miles safe walking distance of the proposed development site e.g. Studley Green and Grove.”
2.3 In addition we identify Holbrook Primary School as a fifth school which is within a 2 mile walking distance of the proposed development. It is not clear as to why Wiltshire Council have not highlighted Holbrook Primary School in their assessment.
2.4 Further:
• The identified school project to which developer contributions will be pooled is stated in the Planning Consultation Response as ‘a new primary school to serve Trowbridge/Southwick area’. This is a vague indication of location and suggests that a wider geography than the two closest schools is relevant to provision in relation to the proposed development.
• Correspondence with Wiltshire Council indicated that the wider Trowbridge Town Primary area is used as a single geography when undertaking pupil place planning8.
• However, the two schools that are used as the basis for requests for developer contributions are not included in the Trowbridge Town Primary area. The Trowbridge Town area does include the 3 other schools highlighted as being
5 Wiltshire Council, Planning Consultation Response for Wynsome Street, Southwick, 2nd May 2017 6 The School Planning Area is named Trowbridge Town 7 Ibid 8 Wiltshire Council, correspondence via email on 18th August, detailed in Appendix
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within a 2 mile distance of the proposed development9. Correspondence with Wiltshire Council explains this:
• “To provide you with the complete Trowbridge picture I have instead attached a Trowbridge town forecast which summarises the picture across all the town schools. This does not include Southwick and North Bradley as we don’t class those as town schools therefore those forecasts are attached separately.”
2.5 Therefore, Wiltshire Council does not present a consistent message on the schools which should be considered in future provision relevant to the proposed development. This means that developer contributions are not based on the full picture of available supply and related demand.
2.6 Wider development coming forward, indicated by Wiltshire Council and discussed later in this chapter, also reflects the wider geography of Trowbridge. Therefore, it is considered a reasonable approach to use the wider geography to present a fair and comparable picture of supply and demand.
Identifying Relevant Schools
2.7 This assessment refers to the two closest schools, for which Wiltshire Council base their request for contributions, as well as the Trowbridge Town area to give consideration to the additional geographies which Wiltshire Council consider relevant. We consider that this presents the fullest picture of supply and demand.
Table 2.1: Primary schools relevant to this assessment
School Name Basis for inclusion in this assessment Southwick CoE Primary School Nominal catchment school; used as basis for request for developer contributions by Wiltshire Council North Bradley CoE Primary School Nearby school to Proposed Development; used as basis for request for developer contributions by Wiltshire Council Trowbridge Town Primary area10 Highlighted by Wiltshire Council in pre- application advice and in further correspondence as relevant to providing a complete picture of Trowbridge primary provision. Turley analysis of Edubase, August 2017, and Wiltshire Council Planning Consultation Response, May 2017 and August 2017
9 The three other schools are: Studley Green Primary School, The Grove Primary School and Holbrook Primary School. 10 The Trowbridge Town area includes 11 schools which are: Bellefield Primary, Castlemead Primary, The Grove Primary, Holbrook Primary, Newtown Community Primary, Paxcroft Primary, St John's Catholic School, Studley Green Primary, The Mead, Oasis Academy Longmeadow and Walwayne Court School
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Figure 2.1: Map of primary provision
Source: Turley analysis, August 2017
Current context
2.8 Analysis of the data provided by Wiltshire Council11 for this assessment indicates that across the schools that the Council have considered relevant for this assessment, there is a current surplus of 498 places.
Figure 2.2: Current capacity - primary provision
Name of School Capacity Number on Roll Surplus / Deficit Capacity Southwick CoE 210 187 23 Primary School North Bradley CoE 210 202 8 Primary School Trowbridge Primary 3,633 3,166 467 Town Planning Area 4,053 3,555 498 Totals
Source: data provided by Wiltshire Council using October 2016 School Census data
11 Correspondence with Wiltshire Council, 11th and 17th August, 2017
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Future Provision (2020 – 2021)
2.9 Forecast data for the 2 individual schools as well as the Trowbridge Town area has been provided by Wiltshire Council, indicating a total surplus of 157 primary places in 2021 12.
2.10 The forecast data, provided by Wiltshire Council, for Southwick CoE Primary School (the nominal catchment school and closest to the site) indicates that there will be surplus capacity at this school in 2021, totalling 36 places. This is an increase of 13 surplus places as a result of declining pupil numbers. For Trowbridge Town, the forecast data indicates a surplus of 121 primary places by 2021.
Table 2.2: Forecast capacity, NOR and resulting surplus capacity in 2021
Current Forecast NOR NOR
Year 2016 2017 2018 2019 2020 2021
Southwick CoE 187 182 179 175 178 174 Primary School North Bradley CoE 202 205 204 207 208 210 Primary School
Trowbridge Town, 3,166 3,390 3,481 3,519 3,500 3,512 Primary
Total NOR 3,555 3,777 3,864 3,901 3,886 3,896 Total capacity 4,053 4,053 4,053 4,053 4,053 4,053 Resulting surplus 498 276 189 152 167 157 capacity
Source: Wiltshire Council data, 11th August 2017
2.11 Wiltshire Council base the developer contributions for education on the combined capacity of Southwick CoE Primary School and North Bradley CoE Primary School. These two schools are forecast to have 36 surplus places in 2021.
School Expansion Plans
2.12 The planning consultation response from Wiltshire Council indicates that both Southwick CoE Primary School and North Bradley CoE Primary School have no space to expand to increase capacity at these schools. Further correspondence with Wiltshire Council has confirmed that there are no planned extensions to the other 3 primary schools relevant to this assessment.
12 Ibid
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Wider Development
2.13 The Wiltshire School Places Strategy 2015-2020 indicates that birth rates in the Trowbridge area remain stagnant. The report states that the projected rise in primary aged pupils in the Trowbridge area is mainly due to wider residential development coming forward13.
2.14 Correspondence with Wiltshire Council has confirmed that, due to the level of wider residential development coming forward in Trowbridge, the number of primary children in the area is set to increase14. Data on wider developments has been provided by Wiltshire Council for those schemes relevant to the proposed development. We present this below to demonstrate the additional level of demand for primary within this geography.
2.15 The Planning Consultation Response states that planning permission has been granted for 439 dwellings, resulting in an additional 136 primary pupils15. In addition to these sites, there are further sites of wider development, which have been registered but not yet granted planning permission. The wider development which has been registered but not approved is estimated to generate 866 primary aged pupils16. The following table demonstrates this.
Table 2.3: Wider development – primary level
Site of wider development Resulting pupil yield
Approved wider development 439 dwellings already with planning permission, yet to be built 136 Registered, but not approved, wider development Ashton Park 705 West of Drynam Lane and Eagle Park 24 Elizabeth Way 51 Land South West of Ashton Road 71 St George’s Works and Town Park, Silver Street 9 Clarks Mill and Mill House 6 Sub – total 866 Total (approved and registered) 1,002 Total pupil yield (discounting registered development) 136
Wiltshire Council, 11th August 2017
13 Wiltshire Council, School Places Strategy, 2015-2020 14 While the forecast data in the section prior only refers to housing development where construction has begun, this section on wider development refers to housing in the pipeline. 15 Wiltshire Council, Planning Consultation Response for Wynsome Street, Southwick, 2nd May 2017 16 The pre-planning application response from Wiltshire Council dated 2nd May indicated 952 primary pupils generated from wider development. Updated information from Wiltshire Council dated 11th August states that this number as 866, because one wider proposed development has since been withdrawn. This assessment uses the latest figures.
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2.16 We identify the following points of challenge in Wiltshire’s approach as set out below.
Point of Challenge 2: Additional primary provision will form part of these developments and is not taken into account by Wiltshire Council 2.17 In its Planning Consultation Response Wiltshire Council references wider demand (866 additional pupils from wider developments registered but not approved)17. However, it does not take into account the additional supply provided by the wider developments. It is noted that this is a reasonable approach, also followed by other Councils such as Leicestershire County Council18. In Leicestershire County Council’s school planning strategy, ‘In the right place: A strategy for the organisation of school and other learning places in Leicestershire 2014 / 2018’, the Council note that they forecast pupil places which ‘include pupils from housing gains from developments with planning permission but not those that have not progressed this far’. Therefore, it is considered appropriate to only include developments which have been granted planning permission, and which therefore are certain to come forward.
2.18 The largest of these wider developments is the site at Ashton Park, which is estimated to generate 705 primary pupils. The Ashton Park development will be required to provide ‘two new 14 class primary schools on sites of 1.8 hectares’ on condition of it being awarded planning permission19. This is equivalent to two schools each accommodating 420 pupils, therefore a total of 840 pupils. Therefore, we can reasonably assume that the demand generated by Ashton Park will be accommodated on site, because the development will provide for two primary schools if it is granted planning permission.
2.19 An estimated 705 of the 840 places will be taken up by residents of the Ashton Park development, leaving 135 places for pupils from outside of the development.
2.20 By not referencing this in its Planning Consultation Response Wiltshire Council presents a misrepresented picture of future unmet need.
Point of Challenge 3: The inclusion of non-approved schemes is hypothetical and leads to an overestimation of future demand 2.21 Wiltshire Council allocates school places based on the registration date of planning applications20. This means that it is making an allowance for places even if a development is unlikely to come forward within a reasonable timeframe. This approach uses a hypothetical position and therefore provides a misleading representation of the available places.
17 The pre-planning application response from Wiltshire Council dated 2nd May indicated 952 primary pupils generated from wider development. Updated information from Wiltshire Council dated 11th August states that this number as 866, because one wider proposed development has since been withdrawn. This assessment uses the latest figures. 18 Leicestershire County Council’s pupil forecasts ‘include pupils from housing gains from developments with planning permission but not those that have not progressed this far’, as stated in ‘In the right place: A strategy for the organisation of school and other learning places in Leicestershire 2014 / 2018’ 19 http://www.wiltshire.gov.uk/corestrategypositionstatement?directory=Matter%2009Q%20Trowbridge%20C A&fileref=3 20 Wiltshire Council, Pre-application planning information, provided on 11th August 2017
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2.22 It would be more robust to consider only those wider developments which have been granted planning permission. This approach should be used and would result in demand from 136 primary pupils from wider permitted developments.
Demand from Proposed Development
2.23 Wiltshire Council has reduced, by 30%, the number of affordable units that qualify for contributions. Therefore, of the total 140 units, Wiltshire Council has only assessed 123 units. We agree with this element of the approach.
2.24 Wiltshire Council has used the general multiplier for primary level, which is 0.31 and multiplied this by the number of dwellings for assessment (123). This results in a total of 38 primary places that would be generated by the proposed development.
Table 2.4: Demand generated by the Proposed Development, primary level
Number of dwellings Number of dwellings General multiplier for Resulting for assessment primary level primary yield
140 123 0.31 3821
Wiltshire Council, pre-application correspondence, May 2017
2.25 We make the following point of challenge with regards to Wiltshire Council’s approach to estimating demand and the resultant impact on school provision: Point of Challenge 4: Cross catchment pupil movements are not taken into account in assessing demand 2.26 Given that Wiltshire Council has identified schools in the Trowbridge Town area as well as Southwick CoE Primary School and North Bradley CoE Primary School as relevant to this assessment, it is reasonable to deduct any pupils generated by the proposed development which will not attend any of these schools, as indicated by current cross- catchment trends.
2.27 Of the 166 primary aged children presently living in the catchment area of Southwick CoE Primary School, identified as the catchment school by Wiltshire Council, a total of 154 currently attend any of the schools that Wiltshire Council has stated as relevant to this assessment. These are shown below. This is equivalent to 92.8%. The most, at 104 pupils, attend Southwick CoE Primary School.
Table 2.5: Cross catchment movement, Southwick catchment population
Name of School Number of catchment % of catchment population attending population attending schools schools
Relevant schools to this assessment:
Southwick CoE Primary School 104 62.7
Trowbridge The Grove 9 5.4
21 Wiltshire Council have rounded down 38.13 to 38 pupils
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Trowbridge Holbrook 6 3.6
Trowbridge Studley Green 2 1.2
North Bradley CE 12 7.2
Trowbridge Longmeadow 3 1.8
Trowbridge Newtown 1 0.6
Trowbridge Bellefield 2 1.2
The Mead Academy Trust 10 6.0
Trowbridge Walwayne Court 1 0.6
St John's RC 4 2.4
Remaining schools that Southwick’s catchment population attend:
Westbury Inf/Jun 1 0.6
Westbury Bitham Brook 1 0.6
Bradford on Avon Fitzmaurice 2 1.2
Sutton Veny 1 0.6
Winsley 1 0.6
West Ashton 2 1.2
Staverton CE 1 0.6
Melksham The Manor* 2 1.2
Special Schools 1 0.6
Total 166 100.0 Source: Wiltshire Council data, 11th August 2017
2.28 Therefore it can be estimated that 92.8% of children will attend one of the relevant schools to this assessment. This reduces demand at these schools from the proposed development to 3622, with 2 pupils attending school elsewhere.
Table 2.6: Primary demand created by the proposed development, taking into account cross-catchment patterns
Source Method Resulting number secondary pupils generated by the proposed development
Wiltshire Council Using general multipliers 38
Turley Using general multipliers and 36 cross-catchment trends
22 35.3 rounded to 36
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Source: Turley analysis, August 2017
Supply – demand balance 2020-2021
2.29 Wiltshire Council has indicated that there will not be capacity at the two closest schools in the future. For this reason it requests developer contributions towards additional provision. Our analysis indicates that there will be 36 places at these schools in 2020-21 once wider permitted developments have been taken into account. We therefore disagree with the future position presented by Wiltshire Council. We disagree with the scale of additional demand presented by Wiltshire Council, as only permitted developments should be included.
2.30 Given that the Council also refers to other schools within walking distance and the wider Trowbridge Town area23 as a whole both within the data it has provided and the geography in which the developer contributions will be used it is relevant to consider the supply-demand balance in these geographies.
Table 2.7: Supply-Demand Balance, primary provision in 2020-2021
Supply and demand changes Impact on pupil numbers
Supply Forecast surplus capacity for relevant primary schools 157
Demand Confirmed wider development 136
Sub-total +21
From proposed development, taking account of current 36 cross-catchment trends
Resulting surplus / deficit capacity - 15 Source: Turley analysis, August 2017
Point of Challenge 5: Wiltshire Council’s supply-demand position is challengeable 2.31 By 2021, it is forecast that there will be 21 surplus places across the primary geography after accounting for permitted wider development. Therefore of the 36 pupils generated by the proposed development, 21 could be accommodated by existing primary provision. This would result in unmet demand for 15 primary places.
Summary
Wiltshire Council requests developer contributions based only on the two nearest schools to the proposed development, Southwick CoE Primary School and North Bradley CoE Primary School. Neither of these schools have space on site to expand; therefore the Council’s request for contributions will be pooled towards the provision of a new primary school. The Council present a confused basis for determining the appropriate geography, since they state that Trowbridge Town is also relevant to this assessment. Our assessment has used both geographies combined as Wiltshire Council indicates contributions will go
23 A total of 5 primary schools are within a 2 mile walking distance of the proposed development. Of these, 3 are included in the Trowbridge Town area. The remaining two are
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towards this wider geography.
• Wiltshire Council states that 1,002 primary children will be generated by wider development coming forward. This level of wider development also reflects the wider area which Wiltshire Council considers relevant to this assessment.
• However, the Council’s assessment of wider development does not take into account that only 439 dwellings have been granted planning permission. Therefore, only 136 primary children, of the 1,002 are guaranteed to come forward within a reasonable timeframe.
• Wiltshire Council fails to mention that 2 new primary schools will be provided on site, accommodating 840 primary pupils, at the Ashton Park development, should this scheme be awarded planning permission. Therefore, if this development comes forward, it will able to accommodate the pupils generated by the development (705 pupils) and have space for a further 135 pupils for other wider development that may come forward. However, at this time, this scheme is uncertain so these numbers have not been used in this assessment.
• Wiltshire Council has estimated that 38 primary pupils will be generated by the proposed development. However, this does not take account of cross- catchment movements. Taking account of current cross-catchment trends, it is reasonable to deduct Wiltshire Council’s calculation of 38 pupils by 92.8%, equating to 36 pupils.
The supply-demand section summarises this analysis, finding that the current primary provision will be unable to accommodate all of the demand generated by the proposed development, after taking into account confirmed wider development. The expected deficit is of 15 places by 2020-2021.
Therefore, this assessment concludes that the request for developer contributions is justified as the contributions will be needed to provide to accommodate all the demand generated by the proposed development. However, it is considered reasonable that 21 of the 36 primary aged children generated by the proposed development will be able to be accommodated in existing provision. Therefore, this assessment considers it reasonable to only contribute for 15 primary places.
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3. Secondary education
Context
3.1 The proposed development is situated within the ‘Trowbridge Secondary’ School Planning Area. This School Planning Area comprises St Augustine’s Catholic School, Clarendon Academy and The John of Gaunt School. The John of Gaunt School has been identified as the nominal catchment school by Wiltshire Council, although the Council has specified that all 3 schools are relevant24.
3.2 These schools are listed in the table below, which shows that the Clarendon Academy is the closest to the proposed development.
Identifying Relevant Schools
3.3 The Education Act 199625 suggests that a distance of 3 miles for a child over 8 years old can be considered an appropriate maximum distance for a local school. All three secondary schools are within a 3 mile walking distance; therefore they are considered appropriate schools for this assessment. Further analysis of Edubase finds that there are no other secondary schools within a 3 mile walking distance of the proposed development. We therefore agree with Wiltshire Council’s identification of relevant secondary schools.
3.4 The John of Gaunt and The Clarendon Academy were both ranked as ‘Good’ in the latest Ofsted inspections. St Augustine's Catholic College has not been inspected since the school converted to an Academy, but was awarded as ‘Outstanding’ in the last inspection before the conversion26.
Table 3.1: Secondary education provision within a 3 mile radius of the proposed development
School Name Type of School Straight line Walking distance Relevant to distance from from the Proposed this Proposed Development assessmen Development t The John of Academy 1.6 miles 2.1 miles Gaunt School Converter St Augustine's Academy 1.6 miles 2.0 miles Catholic Converter College The Clarendon Academy Sponsor 1.3 miles 1.7 miles Academy Led Turley analysis of Edubase, August 2018 and Wiltshire Council Planning Consultation Response, May 2017
24 Wiltshire Council, Planning Consultation Response for Wynsome Street, Southwick, 2nd May 2017 25 The Education Act, 1996 sets out recommended travel to school distances for pupils under and over the age of 8 26 Turley analysis of Ofsted website, August 2017
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Figure 3.1: Map of secondary provision within a 3 mile walking distance of the proposed development
Source: Turley analysis, August 2017
Current Context
3.5 Wiltshire Council recognises that there is currently surplus capacity across the 3 secondary schools relevant to this assessment. The Planning Consultation Response information, provided by Wiltshire Council, using the October 2016 School Census data, states that the capacity for years 7-11 is currently 3,375 secondary places and that the NOR is currently 2,502, equating to 873 surplus places. Correspondence with Wiltshire Council has indicated that the council defines ‘secondary’ as the academic years 7-11 only, and does not include sixth form. Therefore, the latest January 2017 School Census data has not been used as this does not provide a year-by-year breakdown.
3.6 It is noted that there is a slight discrepancy between the figures quoted by Wiltshire Council in the pre-planning application information and the dataset provided by Wiltshire Council. The figures as in the dataset have been used in this assessment because they are the most up to date data as provided by Wiltshire Council.
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Table 3.2: Current capacity - secondary provision
Name of School Capacity Number on Roll Surplus / Deficit Capacity The John of Gaunt 1325 968 + 357 School
The Clarendon 1250 774 + 476 Academy
St. Augustine's 800 763 + 37 Catholic College
Totals 3375 2505 + 870
School Census data, October 2016
3.7 The NOR is on a downward trajectory for all 3 secondary schools, with the pupil numbers declining. For St. Augustine’s Catholic College, the NOR for years 7-11 has fallen from 770 in 2011 to 763. For The Clarendon Academy, the NOR for years 7-11 has fallen from 939 in 2011 to 774 in 2016. Similarly, for The John of Gaunt School, the NOR for years 7-11 has fallen from 1074 in 2011 to 968 in 201627.
Table 3.3: NOR at the 3 secondary schools, 2011 - 2016
NOR
Name of School 2011 2012 2013 2014 2015 2016
John of Gaunt 1,074 1,094 1,096 1,100 1,022 968 School
The Clarendon 939 883 806 765 763 774 Academy
St. Augustine's 770 773 750 760 764 763 Catholic College
Source: Wiltshire Council, August 2017
Future Context (2020-2021)
3.8 Data provided by Wiltshire Council indicates the projected forecast number on roll for each individual school for the years 7-11 for the 3 secondary schools relevant to this assessment28. These forecasts include housing developments which have already been granted planning permission and which have begun construction or been completed.
27 Data provided by Wiltshire Council, 11th August 2017 28 Forecast data provided by Wiltshire Council, 11th August 2017
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The John of Gaunt School 3.9 Data provided by Wiltshire Council projects The John of Gaunt School to have a surplus capacity of 109 places in 2021.
Table 3.4: Forecast position at The John of Gaunt School
Current Forecast
Year 2016 2017 2018 2019 2020 2021
Capacity 1,325 1,325 1,325 1,325 1,325 1,325
NOR 968 990 1,021 1,076 1,137 1,216
Surplus 357 335 304 249 188 109 capacity
Source: Wiltshire Council data, 11th August 2017
The Clarendon Academy 3.10 The Clarendon Academy is projected to have surplus capacity by 2021, of 206 places. According to the data provided by Wiltshire Council, there will be surplus capacity at The Clarendon Academy each academic year for as long as the data is projected (2028). This is the largest surplus capacity of the three schools, meaning that the most capacity is within the closest school to the proposed development.
Table 3.5: Forecast position at The Clarendon Academy
Current Forecast
Year 2016 2017 2018 2019 2020 2021
Capacity 1,250 1,250 1,250 1,250 1,250 1,250
NOR 774 815 890 970 992 1,044
Surplus 476 435 360 280 258 206 capacity
Source: Wiltshire Council data, 11th August 2017
St. Augustine’s Catholic College 3.11 Data provided by Wiltshire Council indicates that St. Augustine Catholic College is projected to have surplus capacity for 4 places in 2020 and a deficit of 1 place by 2021,29 as shown in the following table.
29 Ibid
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Table 3.6: Forecast position at St. Augustine’s Catholic College
Current Forecast
Year 2016 2017 2018 2019 2020 2021
Capacity 775 800 800 800 800 800
NOR 763 771 782 790 796 801
Surplus 12 29 18 10 4 - 1 /deficit capacity
Source: Wiltshire Council data, 11th August 2017
3.12 The trend for all 3 secondary schools is for increasing demand; however, together the 3 schools are projected to have a forecast surplus capacity of 314 places in 2021, with the most surplus capacity at the closest school, as shown in the following table.
Table 3.7: Forecast position showing surplus / deficit capacity for all 3 secondary schools to 2021
Current Forecast
Year 2016 2017 2018 2019 2020 2021
The John of 357 335 304 249 188 109 Gaunt School
The Clarendon 476 435 360 280 258 206 Academy
St. Augustine’s 12 29 18 10 4 - 1 Catholic College
Total 845 799 682 539 450 314
Source: Turley analysis of Wiltshire Council data, August 2017
3.13 The Planning Consultation Response, provided by Wiltshire Council30 indicates that the for the period May 2016 to September 2028, the peak forecast will be in September 2025, when it is expected that 3,165 pupils will be on roll across ‘Trowbridge secondary’ schools. The ‘Trowbridge Secondary’ school planning area comprises only the 3 secondary schools as discussed above. As the capacity of the 3 schools for the years 7- 11 is together 3,375 pupil places, this indicates that even at the peak forecast, there will be surplus capacity of 210 places.
30 Wiltshire Council, Planning Consultation Response for Wynsome Street, Southwick, 2nd May 2017
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3.14 This figure includes approved housing which is already built or an element of which is completed31, and does not include wider development coming that has been granted planning permission but where construction has not yet begun. We consider this below.
Wider Development
3.15 Wiltshire Council has stated that wider residential development, currently in the pipeline, will generate 738 secondary pupils. It asserts that due to the number of secondary pupils from wider development, there will be no capacity at the 3 schools to accommodate the demand generated by the proposed development32. However, this is based on all wider developments which have been registered by the Council.
Point of Challenge 6: The inclusion of non-approved schemes is hypothetical and leads to an overestimation of future demand 3.16 It is not certain that all registered residential dwellings will be granted planning permission; some may be refused planning permission and some may be withdrawn by the applicant. Wider residential development should only be taken account into the forecast position when permission has been granted. Therefore, Wiltshire Council’s method of including all registered wider residential development overestimates future demand and does not present an accurate future position.
3.17 Of all the wider development, as indicated by Wiltshire Council, totalling approximately 3,350 dwellings, only 439 dwellings have been granted planning permission at this time. The wider permitted development will result in 102 secondary pupils. The remaining wider development has been registered with Wiltshire Council but can reasonably be deducted as it cannot be guaranteed if these sites will be approved planning permission, or over what timeline they may come forward. As noted in the chapter on primary provison, this is a reasonabkle approach taken by other Councils33.
Table 3.8: Wider development – secondary level
Site of wider development Resulting pupil yield Approved wider development
439 dwellings already with planning permission, yet to be built 102
Registered, but not approved, wider development
Ashton Park 501
West of Drynam Lane and Eagle Park 17
Elizabeth Way 36
31 Ibid 32 Ibid 33 For example, Leicestershire County Council
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Land South West of Ashton Road 50
Land South of Blind Lane 20
St George’s Works and Town Park, Silver Street 8
Clarks Mill and Mill House 4
Sub – total 636
Total (approved and registered) 738
Total pupil yield (discounting registered development) 102
Wiltshire Council, 11th August 2017
Demand from Proposed Development
3.18 Wiltshire Council has reduced, by 30%, the number of affordable units that qualify for contributions. Therefore, of the total 140 units, Wiltshire Council has only assessed 123 units. We agree with this approach.
3.19 Wiltshire Council’s calculations use the secondary level general multiplier which is 0.22 multiplied by the number of assessed units (123), which results in 27 secondary places generated by the proposed development.
Table 3.9: Demand generated by the Proposed Development, secondary level
Number of dwellings Number of dwellings General multiplier for Resulting for assessment secondary level secondary yield
140 123 0.22 2734
Wiltshire Council, pre-application correspondence, May 2017
Point of Challenge 7: Not all pupils from the proposed development will attend secondary school within Trowbridge 3.20 Cross-catchment data indicates that a proportion of secondary school children travel elsewhere to attend school. Based on these trends, it is not reasonable to assume that all secondary pupils generated by the proposed development will attend any of the 3 secondary schools. This is detailed below.
3.21 The Clarendon Academy is closer to the proposed development. Therefore the catchment population of Clarendon Academy can be considered to more accurately reflect the catchment population of the proposed development. Of the 1,778 children living in the catchment population of the Clarendon Academy, 597 children, or 33.6% attend that school. A further 545 secondary aged children attend The John of Gaunt
34 Wiltshire Council have rounded down 27.06 to 27 pupils
23
School, equivalent to 30.7%. A further 212 children attend St Augustine’s Catholic School, equivalent to 11.9% of the catchment population. These trends are shown in the table below.
3.22 Therefore, on average, 76.2% of the catchment population currently attends either one of the 3 secondary schools which Wiltshire Council has stated are relevant to this assessment.
Table 3.10: Cross catchment movement, Clarendon Academy population
Name of School Number of catchment % of catchment population attending population attending schools schools
Clarendon 597 33.6
John of Gaunt 545 30.7
St Augustine’s 212 11.9
Bradford on Avon St Laurence 281 15.8
Lavington 48 2.7
Melksham Oak 38 2.1
Special Schools (various) 13 0.7
Westbury Matravers 12 0.7
Warminster Kingdown 7 0.4
Corsham Secondary 6 0.3
Bishop Wordsworth Grammar 4 0.2
South Wilts Grammar 3 0.2
Chippenham Sheldon 3 0.2
Amesbury Stonehenge 2 0.1
Pewsey Vale 2 0.1
Marlborough St John’s 2 0.1
Salisbury 6th Form College 2 0.1
Chippenham Hardenhuish 1 0.1
Total living in Clarendon 1,778 100.0 Catchment
Total catchment population 452 76.2% attending the 3 relevant secondary schools
Source: Wiltshire Council data, 11th August 2017
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3.23 Around three quarters (76.2%) of secondary aged children living in the catchment area closest to the proposed development currently attend any of the 3 secondary schools relevant to this assessment. Therefore, of the 27 secondary aged children generated by the proposed development, it is reasonable to expect 76.2% equivalent to 21 pupils, to attend one of the 3 schools named in this assessment35.
Table 3.11: Secondary demand created by the proposed development, taking into account cross-catchment patterns
Source Method Resulting number secondary pupils generated by the proposed development
Wiltshire Council Using general multipliers 27
Turley Using general multipliers and 21 cross-catchment trends
Source: Turley analysis, August 2017
Supply - demand balance
3.24 All 3 secondary schools considered relevant to this assessment currently have surplus capacity and are forecast to have a combined surplus capacity of 314 places in 2020- 2021. Wider development coming forward, which has been granted planning permission, is expected to generate 102 secondary pupils. We discount all registered but not approved development, as that which has not been granted planning permission is considered hypothetical and may not come to fruition.
3.25 Wiltshire Council has calculated that the proposed development will generate 27 secondary pupils, but taking into account current cross-catchment movement trends, it is reasonable to expect that only 76.2% of the pupils will attend any of the three schools relevant to this assessment. This is equivalent to 21 of the 27 secondary pupils attending any of the 3 schools, with 6 pupils attending school elsewhere.
3.26 Summarising these trends in the table below shows a forecast position to 2020-2021 and indicates that there will be 191 surplus places across the 3 schools, even after taking account of approved wider development and the proposed development. Wiltshire Council has indicated that at the peak position, in 2025, it is estimated that there will be 3,165 secondary pupils on roll across the three schools. Considering that the schools together have a capacity of 3,375, this indicates that there will be surplus capacity of 210 places. Likewise, this will be able to accommodate the demand from wider approved developments and the proposed development.
3.27 Therefore it is reasonable that the 3 schools will be able to accommodate the demand generated by the proposed development, and it is concluded that the request for secondary contributions are unjustified.
35 20.5 pupils rounded up to 21 pupils
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Table 3.12: Supply-Demand Balance, secondary provision to 2020-2021
Supply and demand changes Impact on pupil numbers
Supply Forecast surplus capacity for all 3 secondary schools 314
Demand Confirmed wider development 102 From proposed development, taking account of current 21 cross-catchment trends
Resulting surplus capacity +191
Turley analysis, July 2017
Point of Challenge 8: Wiltshire Council consider that there will be no surplus capacity at secondary level but the data indicates surplus to accommodate demand 3.28 Due to Wiltshire Council’s approach which overestimates the future position by 1) including all wider development that may not may not come forward and 2) not accounting for cross-catchment trends, the Council has arrived at an incorrect conclusion that the 3 schools will not be able to accommodate the secondary pupils generated by the proposed development.
3.29 A more reasonable approach, used in this assessment, indicates a surplus position in future. Therefore, this assessment concludes that no contribution towards secondary provision is required.
Summary
There are 3 secondary schools within a 3 mile radius of the proposed development which are relevant to this assessment. All 3 secondary schools currently have surplus capacity. Together, the surplus capacity is equal to 961 secondary places.
Combined forecast data for the 3 individual schools, provided by Wiltshire Council, shows that there will be a total surplus capacity of 314 places by 2020- 2021.
Wiltshire Council’s calculation for requesting developer contributions takes into account all wider development proposed. However, of the 738 secondary pupils that will be generated by all wider development, only 102 are guaranteed, as only 439 dwellings have been granted planning permission at this time. Therefore, the Council’s approach overestimates the future position.
Wiltshire Council has estimated that 27 secondary pupils will be generated by the proposed development. However, this calculation does not take account of cross-catchment movements. Currently, 76.2% of the catchment population attend any of the 3 secondary schools. Therefore it is reasonable to expect that of the 27 pupils generated by the proposed development, 76.2% will attend these schools. This is equivalent to 21 pupils.
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Therefore, taking into account the forecast position to 2020-2021 it is expected that the 3 schools will have surplus capacity to accommodate the proposed development, after taking into account confirmed wider development.
This assessment therefore considers the request for developer contributions for secondary provision to be unjustified.
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4. Developer Contributions Requested
4.1 This chapter assesses the approach set out by Wiltshire Council with regards for requests for S106 contributions.
4.2 The pre-planning application advice, provided by Wiltshire Council, states that Trowbridge currently has surplus capacity at both the primary and secondary level, but that the large number of wider residential developments coming forward are projected to put pressure on both primary and secondary schools, resulting in deficit capacity.
Primary School Contributions
4.3 The requests for developer contributions for S106 are set out in the Planning Consultation Response, provided by Wiltshire Council on 2nd May 2017 and sent to Gladman Developments, and are as follows:
Primary - £17,545 per place with an estimated 38 places generated by the proposed development. This is equivalent to £666,710.
4.4 Wiltshire Council has stated that there is a lack of spare capacity at primary level, particularly because both Southwick CoE Primary School and North Bradley Primary School have no space on site to be able to expand capacity. Therefore, Wiltshire Council indicated that the proposed development is likely to be refused planning permission unless a site can be found for a new school. The pre-planning application advice states:
“There is no spare capacity available at Southwick CE Primary, the nominal designated area school or at its neighbour, North Bradley CE. Places in Trowbridge at primary level are also already effectively over-subscribed. We therefore require a full developer contribution towards the provision of the 38 new places that this development generates a need for at £17,545 per place = £666,710 (subject to indexation).
However, both Southwick and North Bradley CE Primary Schools cannot be expanded on their existing sites, and further housing development continues to come forward/ be anticipated in the Trowbridge area.
The Council therefore needs to secure a new primary school site, minimum area 1.2ha with an option to secure a further 0.6Ha land to facilitate expansion should further housing development be registered/approved in the village of Southwick, or a larger 1.8Ha site now, with an appropriate time limited reverter clause on the additional area above 1.2ha. The site requirements are in addition to the financial contributions pertinent to individual development sites.
But at this time, and until a site for a new school is successfully secured, the Council has no alternative but to object to this application as it is unable to provide the primary places required in the Trowbridge locality. Were the new primary school site issue to be resolved, then all contributions, both land if applicable and financial, would apply as
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detailed above and be secured by an S106 to which the Council’s standard terms will apply.36”
4.5 Wiltshire Council’s School Places Strategy echoes the need the increased primary provision, and details the need for two new primary schools in the long term:
“Assuming the birth rate continues at the average rate for the past four years and the housing is delivered as planned there will be a significant shortfall of places by 2026 with pressure on places in the town schools likely to begin as early as academic year 2017/18. It is expected that this increase in demand can be contained within existing schools in the short term, with expansion and additional accommodation provided where necessary. The precise shortfall will depend on the final mix of dwelling sizes, social housing & windfall sites actually built. The later stages of housing development in Trowbridge will require two new primary schools which will be provided through Section 106 agreements with the developer(s)37”.
4.6 The Council has stated that if a site for a new primary school is provided, then “all requests for developer contributions for the proposed development would be applicable and financial”38.
4.7 We make the following points of challenge with regards to this approach:
Point of Challenge 9: The School Places Strategy acknowledges that additional provision is required but does not indicate this should be a reason to not meet housing need 4.8 The School Places Strategy identifies the need for additional primary school provision but does not suggest that this is a reason to halt housing growth or that additional school provision cannot be provided. As the main school planning document for the area, Wiltshire Council has formally indicated that provision will be met through additional facilities. The Planning Consultation Response therefore conflicts with the Council’s strategic position. Refusal on the basis of the need for a new school is therefore not robust or joined up.
Point of Challenge 10: The deficit in demand is not sufficient in scale to warrant provision of a new school in the Southwick area and therefore finding a site for a new school should not be used as a reason for refusal 4.9 Our analysis of the supply-demand balance identified that there is only a deficit in places of 15 places across the schools included in this assessment39. This level of surplus is not sufficient in scale to require a new school and should instead be met through expansion of existing schools.
Point of Challenge 11: Limited options for expansion are considered by the Council 4.10 Wiltshire Council has indicated that expansion is not possible at Southwick CoE Primary or North Bradley CoE Primary. However, there are 3 further schools within a 2 mile
36 Wiltshire Council, Pre-Planning Application Advice, 2nd May 2017 37 Wiltshire Council, School Places Strategy, 2015-2020 38 Wiltshire Council, Pre-Planning Application Advice, 2nd May 2017 39 Primary schools included in this assessment are: Southwick CoE Primary School, North Bradley CoE Primary School and the 11 schools within the Trowbridge Town area
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walking distance which should be considered for expansion40. Further to this, given that the Council considers the wider Trowbridge Town area to be a relevant geography for provision of a new school to meet Southwick needs, consideration must be given to the potential for expansion in all of these schools.
4.11 Wiltshire Council has presented insufficient expansion evidence to conclude that a new school is required or that this is a robust reason for refusal of the proposed development.
Secondary School Contributions
4.12 Requests for developer contributions for secondary education are set out in the Planning Consultation Response, provided by Wiltshire Council on 2nd May 2017 and sent to Gladman Developments, and are as follows:
Secondary - £21,747 per place with an estimated 27 places generated by the proposed development. This is equivalent to £629,532.
4.13 Wiltshire Council has indicated that the request for contributions for the secondary level would be used to fund an expansion at John of Gaunt Secondary School, or towards the provision of a new school for Trowbridge, dependent on the timing of the proposed development. Correspondence with Wiltshire Council indicates that there are no other secondary schools planned for expansion. The pre-planning application advice states:
“There is no spare capacity available across the Trowbridge secondary schools. We therefore require a developer contribution towards the provision of the full 20 secondary places that it generates a need for. Using the current capital cost multiplier: 27 x £23,316 per place = £629,532 (subject to indexation).This contribution would be secured by a Section 106 agreement, to which standard payment terms would apply41.”
4.14 We make the following points of challenge with regards to this approach:
Point of Challenge 12: There is sufficient capacity within the area to accommodate additional pupil growth 4.15 Wiltshire Council concludes that there is no capacity at the secondary level to accommodate pupils generated by the proposed development. However, their method overestimates the future position in two ways.
• First, all wider development coming forward is included in forecasts assessments, but we consider that only development which has been granted permission is guaranteed to come forward. All other wider development is considered hypothetical.
• Second, the council does not take into account that some children travel elsewhere for secondary school. Our assessment takes into account current cross catchment patterns, finding that only 21 of the 27 as calculated by Wiltshire Council would attend any of the 3 secondary schools in this assessment.
40 These schools are: Holbrook Primary School, The Grove Primary School and Studley Green Primary School. 41 Wiltshire Council, Pre-Planning Application Advice, 2nd May 2017
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4.16 Taking these into account, our assessment finds that there will be surplus capacity to accommodate the secondary pupils generated by the proposed development. Furthermore, the Council fails to mention that the most significant development listed, at Ashton Park, will be required to provide a secondary school on site if it is granted planning permission. Therefore, the site will be able to accommodate the pupils generated by the Ashton Park development, and still have 249 surplus places, which may accommodate other wider development that has been registered ahead of Wynsome Street.
Summary
Wiltshire Council has requested contributions as follows:
Primary - £17,545 per place with an estimated 38 places generated by the proposed development. This is equivalent to £666,710.
Secondary - £21,747 per place with an estimated 27 places generated by the proposed development. This is equivalent to £629,532.
Wiltshire Council’s position is that there will not be capacity to accommodate the pupils generated by the proposed development at both the primary and secondary levels, mainly to due significant level of wider development coming forward.
Wiltshire Council indicated that there is no space to expand capacity at two primary schools (Southwick CoE Primary School and North Bradley Primary School) and therefore funds are being requested for the provision of a new primary school.
For the secondary level, contributions are requested to either fund an expansion of the John of Gaunt Secondary School or contribute towards the provision of a new secondary school in the area.
However, our assessment finds that the Councils method overstates the future position on two counts: first by including all registered wider development in their assessment, rather than just development that is approved, and second by not taking into account cross-catchment patterns. They also fail to take into account new school provision which would come forward as part of wider proposed developments which would take up some of this demand.
Our analysis indicates that there is sufficient capacity for secondary demand while the need for a new school has not been sufficiently evidenced through a robust consideration of the ability of existing local schools to expand.
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5. Establishing Appropriate Contributions
Identifying Appropriate Contributions
5.1 The CIL Regulation 122 test is used to ensure that planning obligations are:
Necessary to make the development acceptable in planning terms;
Directly related to the development; and
Fairly and reasonably related in scale and kind.42
5.2 We consider that the present approach to S106 contributions for the proposed development requested for education is not in line with CIL Regulation 122 for the following reasons:
For primary provision, it is considered justified that Wiltshire Council request developer contributions. However, Wiltshire Council’s calculations are based on all wider development coming forward, when only 136 of the 1,002 primary places should be considered, reflecting the fact that planning permission has been granted for 439 dwellings at the time of writing. When this is taken into account, the primary schools relevant to this assessment will have surplus capacity of 21 places in 2021. Therefore, some of the demand generated by the proposed development will be able to be accommodated within existing primary provision.
Wiltshire Council’s calculations do not take into account that some primary pupils travel elsewhere for school. Currently, 92.8% of children from the Southwick catchment area attend any of the schools relevant to this assessment. The Council, using general multipliers, calculate that 38 primary children will be generated by the proposed development but taking account of cross catchment patterns results in 36 children attending any of these schools.
Considering that the schools will have 21 surplus places, this means that developer contributions can only be reasonably requested for 15 places. This is equivalent to £263,175, or 20.3% of the total request of £1,296,242.
For secondary provision, Wiltshire Council’s data shows that there will be surplus capacity across the 3 secondary schools considered relevant to this assessment in 2020-2021. As the proposed development may come forward within by this date, this is considered a reasonable timeframe. Even taking into account wider development that has been granted planning permission, it is expected that there will be room to accommodate the proposed development within these schools. Therefore, this assessment considers the request for secondary contributions to be unjustified. We consider it appropriate to remove the total request for secondary contributions, currently at £666,710. The developer contributions for secondary provision should therefore be nil.
42 Regulation 122(2) of the Community Infrastructure Levy Regulations, 2010
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5.3 Based on this approach, the contributions would be £263,175, or 20.3% of the total request of £1,296,242.
5.4 There are no grounds to refuse the application on the basis of the need for a new primary school site given that this does not reflect the position presented in the Council’s own School Places Strategy, nor has the Council explored opportunities to expand other primary schools within the wider geography it considers relevant to the geography of demand.
Summary
This assessment finds that a request for primary contributions is justified as the forecast position shows that the schools are not able to accommodate all demand generated by the proposed development. However, the future position finds that 21 primary school children generated by the proposed development will be able to be accommodated.
We consider it reasonable to deduct the request for contributions to take into account cross-catchment trends, which indicate that 92.8% of the primary aged children generated by the proposed development will attend the schools in this assessment. Wiltshire Council calculation that 38 primary children would be generated by the development; our calculations which take into account cross- catchment trends find that 36 is a more reasonable calculation. Therefore we recommend that the request for contributions be deducted to take into account that 2 pupils will attend school elsewhere as well as the 21 who can be accommodated within existing provision. This is equivalent to a reduction by 60.5% for the primary level, or, using the cost per pupil, a reduction of £403,535 from the request of £666,710.
For the secondary level this assessment finds that the request for contributions is unjustified. Using Wiltshire Councils data indicates that there will be surplus capacity across the 3 school indicated by the council as being able to absorb demand generated by the proposed development. Therefore, the full £629,532 request is not warranted and should be reduced to nil.
Therefore we find that a request of contributions at £263,175 is more a reasonable contribution. This is equivalent to a deduction of 79.7% from the total request of £1,296,242.
Wiltshire Council does not have grounds to refuse the application on the basis of the need for a new primary school site. This position is not supported by the School Places Strategy and the Council has not fully considered the ability for other relevant primary schools to accommodate growth through expansion.
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Appendix 1: Correspondence with Wiltshire Council
From: Maxine Kennedy Sent: 20 July 2017 09:10 To: [email protected] Cc: Amy Gilham; Fiona Elton Subject: Education Impact Assessment - Southwick
Dear Clara,
Following on from my our conversation earlier in the week, please see below the queries I have regarding education provision in the local area to the proposed development at Wynsome Street, Southwick, Trowbridge (17/03269/OUT).
I appreciate that you have indicated that we are not likely to receive a response until the 11th August; I look forward to hearing from you then.
Primary provision
1. I am aware of Wiltshire Council’s School Places Strategy 2015 – 2020, which sets out current and forecast capacity by planning group. Are pupil and school place forecasts available for individual primary schools? If so, would it be possible to provide me with the information for the following schools: The Grove Primary School Holbrook Primary School Newtown Community Primary School North Bradley CofE Primary School Oasis Academy Longmeadow St John's Catholic Primary School Southwick Church of England Primary School Studley Green Primary School Walwayne Court School
2. The consultation response indicates that there are 952 primary places required by housing either registered or approved but not yet included in forecasts. It is possible for you to provide the breakdown of the 952 by applications registered and approved?
3. The response also indicates that at combined peak forecasts, there is a shortfall of 29 primary places. Can you confirm the timeline of this peak forecast?
Secondary provision
4. The addendum to the School Places Strategy 2015-2020 ‘Explanation of the differences between Wiltshire Community Areas and Wiltshire School Planning Areas’ document provides a list of schools within the School Planning Area. Can you confirm that ‘The Clarendon College’ (listed in the text above the table) is the same as ‘The Clarendon Academy’ listed in the table, or if these are two separate schools?
5. Can you provide school place forecasts for individual secondary schools, namely: The Clarendon College / The Clarendon Academy The John of Gaunt School St. Augustine’s Catholic School and Technical College
6. The response indicates a combined peak figure/forecast for the period from May 2016 to September 2028 of 3165 – can you indicate at which point in time the peak will be reached? Does the 3165 indicate Number on Roll or capacity?
7. It is indicated that there will be demand for 677 additional pupil places resulting from residential development already registered/approved. Can you provide the breakdown for those registered and approved?
Cost per pupil
8. The School Places Planning Consultation Response document dated 2nd May 2017 indicates a cost per pupil of £17,545 for primary and £21,747 for secondary education. Can you provide a summary of the method used to arrive at these figures?
Wider development
9. A general question on the impact of wider development – do the forecasts provided for both primary and secondary account for this proposed development of 140 dwellings at Wynsome Street, Southwick?
Cross-catchment movement
10. Do you have the following breakdown of students attending the Southwick CE Primary, North Bradley CE, John of Gaunt, Clarendon and St Augustine for: Number who live in catchment (total) Number of pupils who live in catchment and attend the school Number of pupils who live out of catchment and attend the school (including where they live if available) Number of pupils who live in catchment and attend school elsewhere (including where they attend if available)
11. What is the average proportion of pupils attending schools outside of their catchment, for primary and secondary, for Wiltshire?
School expansion
12. Can you confirm the level of education to be provided at the new Ashton Park School (primary or secondary or both?)
13. What is the approximate timeline for completion of Ashton Park School?
14. Are there any other plans for expanding any of the schools mentioned above or indeed to reduce capacity in these schools? Likewise, are there any other plans for new school provision in the area?
As mentioned in my previous email, I have spoken with my colleague Fiona Elton. I have not included here questions which overlap with Fiona’s previous request for information. Of the points listed above, numbers 1, 5 and 8 can be prioritised, if needed.
Many thanks in advance,
Maxine
Dear Maxine
I have now a chance to consider your questions and can provide the responses below and attachments.
Kind regards
Clara Davies
School buildings and primary place planning coordinator
School Buildings and Places Team
Wiltshire Council
Tel: 01225 713872
Email: [email protected]
From: Maxine Kennedy [mailto:[email protected]] Sent: 20 July 2017 09:10 To: Davies, Clara Cc: Amy Gilham; Fiona Elton Subject: Education Impact Assessment - Southwick
Dear Clara,
Following on from my our conversation earlier in the week, please see below the queries I have regarding education provision in the local area to the proposed development at Wynsome Street, Southwick, Trowbridge (17/03269/OUT).
I appreciate that you have indicated that we are not likely to receive a response until the 11th August; I look forward to hearing from you then.
Primary provision
15. I am aware of Wiltshire Council’s School Places Strategy 2015 – 2020, which sets out current and forecast capacity by planning group. Are pupil and school place forecasts available for individual primary schools? If so, would it be possible to provide me with the information for the following schools: The Grove Primary School Holbrook Primary School Newtown Community Primary School North Bradley CofE Primary School Oasis Academy Longmeadow St John's Catholic Primary School Southwick Church of England Primary School Studley Green Primary School Walwayne Court School Please find attached the Southwick and North Bradley forecasts. As for the Trowbridge schools, just sending you the forecasts for the above schools and missing out some of the town schools,
would give you an incorrect picture of the situation across the town. In East Trowbridge all of the schools are full and most of the housing is in this area. Most of the Trowbridge schools on your list above are within 2 miles of those housing sites and therefore those housing sites also have a call on surplus places at those schools. To provide you with the complete Trowbridge picture I have instead attached a Trowbridge town forecast which summarises the picture across all the town schools. This does not include Southwick and North Bradley as we don’t class those as town schools therefore those forecasts are attached separately.
16. The consultation response indicates that there are 952 primary places required by housing either registered or approved but not yet included in forecasts. It is possible for you to provide the breakdown of the 952 by applications registered and approved? The Trowbridge town forecast attached shows that there are 439 houses with planning permission (all listed on the town forecast) which generates a need for 136 primary places. In addition to these the following sites were registered prior to Wynsome Street and therefore have priority for any surplus places:
Ashton Park - 705
West of Drynam Lane & Eagle Park – 24 places
Elizabeth Way – 51 places
Land South West of Ashton Road – 71 places
St George’s Works & Town park, Silver Street – 9 places
Clarks Mill & Mill House – 6 places
Total = 1002
This differs from the figure quoted in the consultation response because we were erroneously advised by Planning that the Land South West of Ashton Road site had been withdrawn when it fact it hadn’t been. In addition there have been other sites that have recently been refused at appeal or withdrawn e.g. Land at the Grange which have now been removed from our calculation. The number of 1 bed units/affordable units has also changed at a few sites slightly altering the pupil places generated. The figures above are the latest available. An updated consultation response has been attached containing the latest figures. This will also be sent to the planner dealing with the application.
17. The response also indicates that at combined peak forecasts, there is a shortfall of 29 primary places. Can you confirm the timeline of this peak forecast? The shortfall of 29 places would have been in 2019. However we are now in the process of expanding Castlemead School so across the area we are forecasting surplus places (as shown in forecasts provided). However these are more than accounted for by the applications that are approved and registered before Wynsome Street (as above), therefore there are still no surplus places remaining for the Wynsome Street development. The latest figures are now shown in the amended consultation response attached.
Secondary provision
18. The addendum to the School Places Strategy 2015-2020 ‘Explanation of the differences between Wiltshire Community Areas and Wiltshire School Planning Areas’ document provides a list of schools within the School Planning Area. Can you confirm that ‘The Clarendon College’ (listed in the text above the table) is the same as ‘The Clarendon Academy’ listed in the table, or if these are two separate schools? This is the same school.
19. Can you provide school place forecasts for individual secondary schools, namely: The Clarendon College / The Clarendon Academy The John of Gaunt School St. Augustine’s Catholic School and Technical College All attached
20. The response indicates a combined peak figure/forecast for the period from May 2016 to September 2028 of 3165 – can you indicate at which point in time the peak will be reached? Does the 3165 indicate Number on Roll or capacity? As you will be able to see from the forecasts, the peak of number on role of 3165 is reached in Sept 2025.
21. It is indicated that there will be demand for 677 additional pupil places resulting from residential development already registered/approved. Can you provide the breakdown for those registered and approved?
The forecasts attached shows that there are 462 houses with planning permission in the combined secondary catchment areas (all listed on the forecasts) which generates a need for 102 secondary places. In addition to these the following sites were registered prior to Wynsome Street and therefore have priority for any surplus places:
Ashton Park – 501 places West of Drynam Lane & Eagle Park – 17 places Elizabeth Way – 36 places Land South West of Ashton Road – 50 places Land South of Blind Lane - 20 St George’s Works & Town park, Silver Street – 8 places Clarks Mill & Mill House – 4 places
Total = 738
This differs from the figure quoted in the consultation response for the same reasons explained above. We have also begun including the cumulative pupil product from small approved sites (less than 10 houses) in secondary assessments where the aggregated total is substantial as it is here. These small approved sites are all now listed in the secondary forecasts you have been sent (included within the 102 places above).
Cost per pupil
22. The School Places Planning Consultation Response document dated 2nd May 2017 indicates a cost per pupil of £17,545 for primary and £21,747 for secondary education. Can you provide a summary of the method used to arrive at these figures?
The latest cost mulitpliers are now £17,545 for primary and £23,316 for secondary. An independent firm of Quantity Surveyors annually calculate the primary and secondary cost multipliers based on the actual cost of school expansion projects we have completed in Wiltshire. Their latest analysis is attached. These multipliers will now be used for S106 agreements signed during this financial year. The £21,747 for secondary was actually last years multiplier but is now out of date and superseded by the £23,316.
Wider development
23. A general question on the impact of wider development – do the forecasts provided for both primary and secondary account for this proposed development of 140 dwellings at Wynsome Street, Southwick? No, this development does not have planning permission so is not included in the forecasts – the same is true of all the other developments that pre-date Wynsome Street but don’t yet have planning approval.
Cross-catchment movement
24. Do you have the following breakdown of students attending the Southwick CE Primary, North Bradley CE, John of Gaunt, Clarendon and St Augustine for: Number who live in catchment (total) We can only provide information on the number of children who attend Wiltshire schools. If they attend private or out County schools we would not have them on our records. Therefore the information below only refers to the number of children in catchment who attend a Wiltshire school. It is correct as at January 2017 and uses pupils addresses at that time, not when they would have made their school application.
Southwick – 166 (in years R to 6)
North Bradley – 171 (in years R to 6)
Clarendon - 1778 (in years 7 to 14)
John of Gaunt – 1380 (in years 7 to 14)
St Augustine’s – This is a Catholic School which doesn’t have a traditional catchment area. Their “catchment” is based on ecclesiastical parishes. A map on the schools website can be seen here - https://www.st- augustines.wilts.sch.uk/admissions/catchment-area/. It is not possible for us to calculate the children who live within this area as some of the area is outside of Wiltshire. All of their catchment area overlaps with non-catholic schools like John of Gaunt and Clarendon so this would also be double counting.
Number of pupils who live in catchment and attend the school Southwick – 104 North Bradley – 107 John of Gaunt -529 Clarendon – 597 St Augustine’s – see above Number of pupils who live out of catchment and attend the school (including where they live if available)
Number of pupils who live in catchment and attend school elsewhere (including where they attend if available) Please find attached a spreadsheet which answers the above 2 questions, there is a separate tab for each school.
25. What is the average proportion of pupils attending schools outside of their catchment, for primary and secondary, for Wiltshire? Unknown, we don’t have this calculation.
School expansion
26. Can you confirm the level of education to be provided at the new Ashton Park School (primary or secondary or both?) - Nothing has been secured as yet, however we are requesting sites to enable 2 2FE primary schools and one 750 place secondary school. Financial contributions will be sought towards these additional places from the Ashton Park development and other developments in the area.
27. What is the approximate timeline for completion of Ashton Park School? Unknown at present, there are ecology issues on the housing site which has caused delays. The site does not yet have planning permission. The timings for the handover of any school site/s on the Ashton Park development would be dependent on the terms set in the S106 which have yet to be discussed.
28. Are there any other plans for expanding any of the schools mentioned above or indeed to reduce capacity in these schools? Likewise, are there any other plans for new school provision in the area? There are no plans to extend or reduce capacity at any of the schools you have listed above. Most would have insufficient site area anyway. As previously mentioned we are in the process of expanding Castlemead Primary School in east Trowbridge. This school was originally built with the potential to be expanded.
As for new schools, we have no sites currently secured to enable new schools to open. We are actively seeking school sites on all sizable developments in the area and until some are secured this is a significant issue for new housing in the town.
As mentioned in my previous email, I have spoken with my colleague Fiona Elton. I have not included here questions which overlap with Fiona’s previous request for information. Of the points listed above, numbers 1, 5 and 8 can be prioritised, if needed.
Many thanks in advance,
Maxine
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From: Maxine Kennedy Sent: 16 August 2017 17:12 To: 'Davies, Clara' Subject: RE: Education Impact Assessment - Southwick
Hi Clara,
Apologies to have to come back to you on this, is it possible you can send the cross-catchment data for 3 more schools:
The Grove Primary School Studley Green Primary School Holbrook Primary School
Many thanks, apologies for the inconvenience,
Maxine
From: Davies, Clara [mailto:[email protected]] Sent: 16 August 2017 14:07 To: Maxine Kennedy Cc: Medland, Clare; Ashton, Sarah Subject: RE: Education Impact Assessment - Southwick
Hi Maxine
The schools that we classify as Trowbridge town schools are as follows:
Bellefield Primary
Castlemead Primary
Grove Primary, Trowbridge
Holbrook Primary, Trowbridge
Newtown Community Primary
Paxcroft Primary, Trowbridge
St John's Catholic School
Studley Green Primary
The Mead
Oasis Academy Longmeadow
Walwayne Court School
Many thanks
Clara
From: Maxine Kennedy [mailto:[email protected]] Sent: 16 August 2017 14:01 To: Medland, Clare Cc: Ashton, Sarah; Davies, Clara Subject: RE: Education Impact Assessment - Southwick
Dear Clare,
I understand that Clara is away on annual leave at the moment; I just wanted to clarify which schools comprise the Trowbridge town forecast?
Thanks,
Maxine
Maxine Kennedy Consultant, Economics
From: Maxine Kennedy Sent: 17 August 2017 08:01 To: 'Davies, Clara' Subject: RE: Education Impact Assessment - Southwick
Hi Clara,
At the start of the revised pre-app response, it states that it has been calculated that there will be 27 secondary pupils generated by the proposed development (123*0.22= 27) however later on it states 20 pupils and gives the request for contributions accordingly. Can you confirm if Wiltshire Council is requesting contributions for 27 or 20 secondary pupils?
I also wanted to ask if you could send the forecasts for the 5 primary schools (Southwick, Holbrook, Studley Green, the Grove and North Bradley). I will need to reference them in my assessment.
Thanks,
Maxine
From: Davies, Clara [mailto:[email protected]] Sent: 17 August 2017 11:18 To: Maxine Kennedy Cc: Medland, Clare; Ashton, Sarah Subject: RE: Education Impact Assessment - Southwick
Hi Maxine
We can’t produce that data for St Augustine’s because as a Catholic school they don’t have the same type of catchment area. Our data systems allocate each postcode to a catchment area, so for example the whole Trowbridge area is allocated to either John of Gaunt or Clarendon. We only have 2 secondary catholic schools in Wiltshire so effectively the St Augustine’s “catchment” is half the County plus some of Somerset in this case. It would also be double counting as all Trowbridge area pupils are already allocated to either John of Gaunt or Clarendon..
If however you could tell me every postcode within the St Augustine’s “catchment” area then I could try and work it out!
Many thanks Clara
From: Maxine Kennedy [mailto:[email protected]] Sent: 17 August 2017 11:08 To: Davies, Clara Subject: RE: Education Impact Assessment - Southwick
Hi Clara,
The cross catchment data for St. Augustine’s School seems to be missing the second portion which the other schools include (“Where do children (yrs 7 to 14) living in St Augustine’s catchment attend school) – is it possible you can send this over?
Thanks very much,
Maxine
Maxine Kennedy Consultant, Economics
From: Maxine Kennedy Sent: 17 August 2017 12:46 To: 'Medland, Clare'; Ashton, Sarah Cc: 'Davies, Clara' Subject: FW: Education Impact Assessment - Southwick
Dear Clare and Sarah,
Apologies for getting in touch again, but I was hoping if you would be able to help me with my query below?
1. Is it possible to clarify if Wiltshire Council are requesting contributions for 20 or 27 secondary school places. Both numbers are mentioned in the attached. 2. I would be grateful if you could send the forecast data for the individual schools for the following primary schools: Holbrook, The Grove and Studley Green. 3. Many thanks,
Maxine
From: Davies, Clara [mailto:[email protected]] Sent: 17 August 2017 16:33 To: Maxine Kennedy Cc: Medland, Clare; Ashton, Sarah Subject: RE: Education Impact Assessment - Southwick
Hi Maxine
Thanks for picking up on that – it should be 27 secondary pupils. I have updated the consultation response accordingly, new version attached.
I have also attached the 5 primary school forecasts as requested. As discussed yesterday though, these schools are within 2 miles of other housing developments not shown on their individual forecasts (and schools with more pupils forecast than places available) and therefore their future numbers will be higher than shown in the individual forecasts. That is why we plan at town level and I previously sent you the town forecast setting out the overall position.
Many thanks
Clara
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