CITY OF CARDIFF COUNCIL CYNGOR DINAS CAERDYDD
CABINET MEETING: 17 JULY 2014
SCHOOL ORGANISATION PROPOSALS: RECOMMENDATIONS RELATING TO THE SITING OF EASTERN HIGH FOLLOWING CONSULTATION
REPORT OF DIRECTOR OF EDUCATION AND LIFELONG LEARNING AGENDA ITEM: 11
PORTFOLIO: EDUCATION AND SKILLS (COUNCILLOR JULIA MAGILL)
Reason for this Report
1. This report is to inform the Cabinet of the responses received following consultation on two options for a site on which to construct a new build 11-16 Eastern High in conjunction with the construction of post 16 facilities, and to recommend a preferred site.
Background
2. At its meeting on 10 October 2013 the Cabinet received a report outlining recommendations to hold a public consultation on potential options for a site on which a new build state of the art 11-16 school (Eastern High) with post 16 provision being delivered by Cardiff and Vale College (CAVC) would be constructed. The 11-16 school would replace the existing facilities for Eastern High currently located on the site formerly known as the Rumney High School site. It was also proposed to demolish the existing CAVC facilities and construct new post 16 facilities to be managed by CAVC.
3. Two sites were selected as suitable options on which to consult. These are (in alphabetical order):
• Cardiff and Vale College site located at Trowbridge Road, Rumney • The site of the former Llanrumney High School located at Ball Road, Llanrumney
4. A map showing the location of the two sites is at Appendix 1.
5. The consultation ran from 12 December 2013 to 22 January 2014. Parents and others in the local community were invited to respond to the consultation. The consultation process involved:
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• Distribution of a Consultation Document, outlining background, rationale and implications. This document was distributed to parents, Heads and Chairs of Governors of nearby schools, Members, local residents and other stakeholders.
• One public meeting at which the proposal was explained and questions answered.
• 9 public drop in sessions where officers were available to answer questions relating to the Consultation Document.
• Meetings with pupils from Greenway Primary School, Rumney Primary School, Meadowlane Primary School, Glan yr Afon Primary School, Trowbridge Primary School, Willowbrook Primary School, Pen y Bryn Primary School, Bryn Hafod Primary School and Oakfield Primary School to involve them in the consultation and to obtain their thoughts and views. Details of the sessions can be seen at Appendix 2.
• A meeting with pupils from Eastern High to involve them in the consultation and to obtain their thoughts and views. Details of the session can be seen at Appendix 3.
• A consultation response slip for return by post or e-mail, attached to the consultation document.
6. The Consultation Response form asked respondees to consider how important each of the following 5 factors were to them when considering where to build the new school (Level of importance 1-5 with 1=High 5= Low):
• Access to/impact on the use of off-site playing fields • Disruption to sites that would be occupied during construction • Net cost, taking account of estimated capital receipts and thus affordability • Potential for future development including possible co-location of other community facilities • Proximity to pupil population
7. The views expressed at Council organised meetings and on paper or electronically through the appropriate channels, have been recorded. In total, one public meeting and 9 drop in sessions were held as part of the consultation to allow for a wide and proper process of engagement.
8. In total, only 36 individual responses were received. Of these, 31 had completed the 5 factor section of the Consultation Response form. Subsequently a 105 signature petition proposing that the existing high school site (Rumney High) should be the permanent site for Eastern High was received. Additionally the petition proposed the existing high school site (Rumney High) be included in consultation and that this site should not be earmarked for housing to finance the new school.
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Pupil Consultation
9. Officers from the Cardiff Youth Service met with pupils from Eastern High to explain the proposal and to ascertain their views on the site options. The site options were explained to 244 Year 7 – 10 pupils from the 960 pupils attending the school.
10. Sessions were also held with pupils from Greenway Primary School, Rumney Primary School, Meadowlane Primary School, Glan yr Afon Primary School, Trowbridge Primary School, Willowbrook Primary School, Pen y Bryn Primary School, Bryn Hafod Primary School and Oakfield Primary School to explain the proposal and ascertain their views on the site options.
11. The pupils were asked to identify and prioritise which of the five factors were important to them using 5 coloured dots each.
12. In addition to the five factors listed a number of pupils stated that having access to a school bus was an important factor, with a small number of pupils stating that access to post 16 options was of importance to them.
13. Responses on how important each of the five factors were considered have been analysed and the order of importance has been established by reference to the average ‘score’ for each factor. The lower the score the greater the importance. It has not been possible to apply an average ‘score’ to the primary pupil responses as this information was collected using an age appropriate method which does not allow for this.
14. Table 1 below sets out the average ‘score’ and the resulting ranking alongside a ranking of the primary pupil responses.
Primary Pupils Importance Ranking Public Average Eastern High **(Primary aged Score Pupils Average Collective pupils at 9 Factors/Level of *(31 of 36 Importance Score Importance Average Importance primary importance responses) Ranking (244 pupils) Ranking Score Ranking schools) Access to/impact on the use of off-site playing fields 1.39 1 2.92 4 2.75 3 2 Disruption to sites that would be occupied during construction 2.00 4 2.93 5 2.83 5 3 Net cost, taking into account of estimated capital receipts and thus affordability 1.74 3 2.91 3 2.78 4 4 Potential for future development inc possible co-location of other community facilities 1.48 2 1.89 1 1.84 1 5 Proximity to pupil population 4.16 5 1.89 1 2.15 2 1
* 5 respondees did not complete the 5 factor section of the consultation response form.
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Consultation Responses
15. The majority view expressed throughout the consultation both at meetings and in written correspondence is one of support for establishing a new build school in the East of Cardiff.
16. Concerns expressed regarding the proposal are set out below along with responses to each.
17. Traffic, transport and parking
• Concerns raised regarding increased traffic and potential ‘nuisance’ parking around the new school site impacting on local residents; • Travelling distance for pupils to and from school; • Request for transport to and from school to be provided for pupils living in St Mellons/Llanrumney; • Road safety concerns for pupils travelling to school. Request for a pedestrian crossing for pupils crossing the busy Newport Road travelling from Old St Mellons; • Request for parking for parents picking up and dropping off.
18. It is recognised that there would be potential traffic congestion around the school site at the beginning/end of the school day. However, the Council would work with the Governing Body of the school to develop a Travel Plan to minimise any potential disruption. Traffic and transport implications would be considered as part of the Transport Assessment that would be required in order to achieve planning consent for building works.
19. Cardiff’s Supplementary Planning Guidance (Access, Circulation and Parking Standards 2010) sets out that all new or expanded schools are required to develop a Travel Plan for submission with a planning application. 20. A Travel Plan is a policy and action plan to: • manage transport efficiently • improve access by all means of travel for employees, visitors, parents and students • encourage sustainable transport – walking, cycling, public transport and car sharing • reduce car use.
21. A School Travel Plan is specifically designed to address the transport needs of pupils and staff and will vary according to the nature of the education being provided, any community facilities on site and the catchment area of a school.
22. Cardiff’s transport network is under pressure and experiences congestion from commuters driving into the city and people making short local trips by car. Traffic associated with the school run adds to congestion. Cardiff Council’s policy is to encourage and promote the increased use of
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sustainable travel modes and to promote independent travel to school wherever possible. This is particularly pertinent to pupils at Key Stages 3 and 4 as this age group is generally more able to undertake unaccompanied travel.
23. Emphasis is placed on travel by active modes where this is possible and on providing the facilities and opportunities at school for students to travel by walking, cycling and public transport. Encouraging active travel to school is a very important means of increasing levels of physical activity in children and tackling the growing problem of childhood obesity. Reducing congestion at the school gate is key to ensuring the safety of pupils and to mitigating impacts on the local neighbourhood.
24. In the Consultation Document it stated that no pupils living within the proposed catchment area would qualify for free transport as all pupils live within 3 miles walking distance to either the CAVC site or the Llanrumney High School site.
25. Pupils may only qualify for free home to school transport if their homes are along country lanes where there are no footpaths if these are classed as unavailable walking routes. Some pupils may qualify for free transport regardless of the distance involved as they do not have access to an available walking route to either site. In these cases an assessment based on the number of traffic movements and availability of step offs will need to be undertaken on an individual basis when a pupil starts at or applies to start at the school. Currently, this mainly affects pupils living in some parts of the Wentloog area, old St Mellons area off Bridge Road/Began Road and Druidstone Road.
26. Either site may require additional school safety zones on the roads immediately outside the site to cater for the additional pupil numbers attending. The school safety zones relate to parking, road speeds and pedestrian safety issues that would need to be improved to reduce the road speeds of vehicles and increase the visibility of pedestrians by improving the facilities such as zebra crossings, raised speed humps, increased signage and road markings. The costs and requirements are likely to be similar for both sites between £50-100k (this would be Capital funded).
27. Provision of parent parking places is generally not supported by Cardiff Council. This is because such provision would promote travel to school by car, generate local traffic, contribute to congestion and reduce pupil safety. Parking facilities provided at schools are generally only for staff and to meet operational needs.
28. Disruption to sites that would be occupied during construction
Disruption to sites that would be occupied during construction.
29. Cardiff Council has experience in the successful delivery of building projects on occupied sites resulting from the progression of a growing school organisation programme. Any building works carried out on an
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occupied site would be managed effectively in consultation with the school/college management to ensure that the full curriculum/courses continue to be delivered and that high education standards and safety standards are maintained.
30. Rumney High School site
The wrong sites have been chosen- Rumney High School site is the better option;
31. Rumney High School was discounted as a viable option on which to site the new build school and these reasons were explained in the Consultation Document. Concerns around the use of the Rumney Recreation Ground for off-site playing field provision if the new build school was on the Rumney High School site and the net cost of building the school on the Rumney High School site being in excess of resources available were considered to be disadvantages of such significance as to not include it as an option for consultation.
32. The financial modelling for all options relies on the disposal of the two sites not used for the new build school i.e. the Rumney High School site and either the CAVC site or the Llanrumney High School site.
33. The nature of any development on sites to be disposed of would be subject to planning requirements and any associated consultation processes.
34. Flooding
Concerns that the chosen new site (depending on which site is chosen) may be subject to flooding;
35. All sites that were considered as potential sites for the new build Eastern High were screened for flood risk. Cardiff Council commissioned a Site Feasibility Appraisal Report which advised that the Llanrumney High School site lies in the flood plain of the river Rhymney although it currently benefits from flood defences. However, these defences are considered to be susceptible to breach, so works to reinforce the defences would be likely to be required in order to meet TAN 15 requirements. The Site Feasibility Appraisal Report advised that some parts of the CAVC site are susceptible to surface water flooding. However, it is considered that for a new build development, this risk should be manageable through the design of the drainage system and the alignment of the buildings and design of overland flow paths through the site.
36. Impact on local area
Concerns from residents living opposite Llanrumney High School site that the proposed site has no “playground” and that pupils would be able to leave the school site during break periods and wander around the local area.
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Concerns that there would be an increase in litter and requests for the Council or students to routinely clear pupil dropped litter from the local area;
37. Recreational space for pupils would be part of either site and the school would work with pupils to address any incidents of anti-social behaviour during break times and before and after school. Concerns raised by local residents regarding littering would be a matter for the school management and the school would work with pupils to try and establish a sense of personal responsibility to minimise littering by pupils within the local area.
38. Off site playing fields
Concerns regarding the possibility of off-site playing fields ;
39. These issues are addressed at paragraphs 46, 47 and 48.
Summary
40. In total, only 36 individual responses to the consultation were received. These were submitted by 26 individuals from the Llanrumney area, 4 from the St Mellons area, 3 from the Old St Mellons area and 3 from the Rumney area. The two factors rated of highest importance by these respondees were access to/impact on the use of off-site playing fields followed by potential for future development including possible co- location of other community facilities.
41. Views were obtained from 244 of the 960 year 7-10 pupils of Eastern High. The two factors rated of highest importance by these pupils were potential for future development including possible co-location of other community facilities followed by proximity to pupil population. These two factors rank as the most important collectively, given the high proportion of responses from pupils.
42. Views were also obtained from pupils at the Eastern High partner primary schools. The two factors of most importance were proximity to pupil population followed by access to/impact on the use of off-site playing fields.
43. Three of the five factors feature twice in the two most important factors from the three groups. None of these rates as the most important for more than one group. However the average score for the Eastern High pupil group was identical when expressed to two decimal points.
44. A 105 signature petition was also subsequently received. This is summarised in paragraph 8 with a response in paragraphs 31, 32 and 33.
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Evaluation
45. The three factors that feature in consultation responses as the two most important from the three groups are evaluated below, in alphabetical order, by reference to the Cabinet report dated 10 October 2013.
Access to/impact on the use of off-site playing fields
46. The CAVC site would require the use of Greenway Park which is a short distance across a relatively minor road which accesses residential areas. The use of Greenway Park is considered to be of potential benefit to the community as the fields currently have no changing facilities and are not used for any organised sport.
47. The Llanrumney High School site would require some use of adjacent fields such as those used by Cardiff University and/or Rumney Rugby Football Club. This is not considered problematic. It should also be noted that should this site not be chosen for the new build the grassed areas would be made available to the community.
48. As concluded in the previous Cabinet report either of the two sites would be suitable.
Potential for future development
49. The previous Cabinet report concluded that either of the two sites offered sufficient potential for the school to expand to 11 FE plus post 16 facilities.
50. The developable ‘footprint’ for each site allows for similar potential to develop community facilities.
Proximity to pupil population
51. Table 2 below presents an analysis of distance by safe walking routes from the homes of pupils attending Llanrumney and Rumney High Schools from within their catchment areas as at March 2013.
52. The detailed location of pupils’ home addresses will change from year to year but the table is considered to represent an appropriate measure based on recent preferences. If the table were to be based on primary school or pre school cohorts it would not be known which addresses to discount on the basis of parental preference. It would be reasonable to note however that recent preferences for attendance at either of the two high schools are likely to reflect fairly consistent patterns of distribution across the communities.
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Table 2 Source data: EMS One Live, March 2013
East sites: home to Pupils on roll resident within Eastern High catchment area school safe walking route Llanrumney High site Cardiff and Vale College site distances (2 entrances) (2 entrances) Number of pupils % Number of pupils % < 0.5 mile 74 7.4% 167 16.6% ≥ 0.5 mile 932 92.6% 839 83.4% Total pupils 1006 100% 1006 100%
< 1 mile 348 34.6% 490 48.7% ≥ 1 mile 658 65.4% 516 51.3% Total pupils 1006 100% 1006 100%
> 3 miles 0 0% 0 0%
Llanrumney High site Cardiff and Vale College site (2 entrances) (2 entrances) Average distance (miles) 1.34 0.97 Minimum distance (miles) 0 0 Maximum distance 2.842 1.792 (miles)
53. In terms of average distance of travel for pupils the table shows that the Llanrumney High School site is considerably further away from where pupils live being on average 38% further away compared to the CAVC site.
54. In terms of the maximum distance the CAVC site is 37% closer than the Llanrumney High School site to the addresses measured.
55. Based on recent pupil demographics within the proposed catchment, approximately 1/3 of the new school population live on the Llanrumney side of Newport Road and 2/3 live on the Rumney, Trowbridge and St Mellons side of Newport Road
56. If the new school is located on the CAVC site this would enable a large proportion of pupils to either walk to school or catch the local service buses that operate along Greenway Road.
57. As there are no direct bus services from the Burnham Avenue area of Llanrumney across to the CAVC site some future pupils could in theory have to walk up to 2.4 miles. However double the number of pupils living in the St Mellons area would face similar issues if the school were to be located on the Llanrumney High School site as there are no direct public bus services from their area across to the Llanrumney High School site.
58. If supported bus services were required to help reduce congestion and improve access for pupils then the costs would be approximately double to transport pupils from the St Mellons area across to the Llanrumney High School site, compared to the costs of transporting pupils from the Burnham Avenue area across to the CAVC site (CAVC site £70k approximately for two buses, Llanrumney High School site £140k approximately for four buses).
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59. It is therefore considered that the CAVC site is best located to serve the proposed Eastern High catchment area with the Llanrumney High School site being less suitable by a significant measure.
Conclusion
60. Of the three factors rated most important by the groups it is considered that proximity to pupil population is the only one for which a substantial difference can be discerned between the two sites.
61. The evaluation identifies clear advantages of the CAVC site over the Llanrumney High School site in terms of shorter average distances of travel for pupils and fewer additional buses potentially needed.
62. These advantages are considered to be of significant benefit towards contributing to achieving high levels of pupil attendance, safer routes to school, reduced carbon emissions and viability of future community facilities.
63. The Cabinet report of 10 October 2013 showed the estimated net capital requirement for the CAVC site to be £2.783m higher than for the Llanrumney High School site. It also stated that the analysis showed ‘…that based on current estimates and known figures there would be sufficient resources to cover the cost of construction etc on either the CAVC or the Llanrumney High School site …’. This report shows that the estimated net cost of the CAVC site has risen to £3.675m higher than for the Llanrumney High School site as a result of updated Capital expenditure and Capital receipt estimates (Note that this difference does not include the calculation of VAT liability). However, there are still sufficient resources to cover the cost of construction. Given that this increase of £0.892m represents around only 2% of the total estimated capital expenditure and there are sufficient resources to meet this, it is considered that the impact of this estimated increase does not constitute sufficient reason to conclude otherwise than is outlined in paragraphs 60- 62 above.
64. It is therefore concluded that the CAVC site be recommended for selection for the new build Eastern High and replacement all weather pitch in conjunction with the construction of post 16 facilities.
Reasons for Recommendations
65. To enable the Cabinet to make a decision on a site for the new build Eastern High in conjunction with the construction of post 16 facilities and to authorise officers to take the necessary steps to progress the project.
Procurement
66. A range of procurement routes for the appointment of a contractor for the construction of a new Eastern High have been investigated. These include the use of a stand-alone OJEU process, the use of a regional framework, and the use of national frameworks. The WG preferred
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approach is that local authorities in South East Wales are expected to utilise the regional framework, SEWSCAP (or undertake their own OJEU compliant tender process) where 21 st Century school funded schemes are concerned. Officers are progressing matters in line with this preferred approach. It should be noted, however, that delivery of the project for September 2016 is now extremely challenging. This report therefore recommends that a Project Manager is appointed as soon as possible in order to obtain expert advice on the methodology of procurement, to enable a consistency of management to be achieved across the project and to ensure that the project progresses in the most timely and cost efficient manner. It is estimated that this would cost in the region of £200k and is allowed for within the estimated project fees.
Value Added Tax (VAT)
67. Broadly speaking, there are two approaches that can be taken in terms of managing the potential VAT liability connected with the proposal.
68. One option would be to continue with attempts to arrive at a VAT free solution. This, if achievable, would entail CAVC limiting their occupation of the proposed building(s) so that no more than 5% of the total floor area is assigned to what is classified as their ‘commercial activity’. This would significantly restrict the scope of CAVC’s activities beyond courses attended only by students covered entirely by Welsh Government grant. This would therefore significantly restrict the ability of collaboration between the CAVC and Eastern High and as such would limit opportunities for shared facilities with a consequent negative impact both on capital and future revenue costs. With this option it would also most likely take at least six months to establish whether HMRC is satisfied and would require an annual audit for a period of 10 years. It should be noted that if the 5% limit is breached in any of the following 10 years then a VAT liability would arise that would be payable to HMRC.
69. The alternative, and preferred option, is to calculate and allow for the VAT at the outset based on the currently estimated percentage of CAVC use of the proposed building(s). The estimated worst case liability has been incorporated into and is affordable within the financial model for the project. This approach would enable agreements on collaboration, shared occupation of premises and CAVC ‘commercial activity’ to be based on and responsive to educational, training and wider community needs rather than being restricted by the 5% limit referred to in the previous paragraph. This, in turn, would facilitate optimisation of capital and revenue costs as well as enabling the project to progress within a clear strategy of risk management.
70. The financial model for the proposal has been adjusted to take account of design work to date and now allows only for the minimum overall school floor areas recommended in the new Building Bulletin (103) which reduces overall secondary floor areas by around 15%. The effects of this reduction can potentially be mitigated by the greater flexibility available for shared use of spaces afforded by the preferred approach to VAT but would need to be modelled carefully to ensure that curriculum and other
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needs are suitably provided for. It is therefore proposed that any apparent balance in the model, once VAT has been accounted for, is kept as an increased contingency which also acknowledges that designs not currently finalised and capital receipts are based on estimates that are subject to market forces. It is also to be noted that the resources available for the proposal includes a contribution of (up to) £500k, approved by CAVC governing body at its meeting on 3 July, towards its share of the VAT costs.
71. In conclusion, it is considered that the preferred approach to VAT is the only way in which the vision for the East can be developed as originally envisaged, including provision of a range of opportunities for higher education provision, adult learners not funded by grant and community use of premises. It is also considered that this approach best protects the potential for future development which (including possible co-location of other community facilities) was one of the three factors that featured twice in consultation in the two most important factors from the three groups referred to in paragraphs 40-42.
Legal Implications
72. As explained in the October report the consultation undertaken was not a statutory consultation required in accordance with the School Organisation Code which came into force on the 1st October 2013. However the consultation was necessary and the decision maker must be able to demonstrate that it has given due and proper consideration to the responses received and taken them into account in making any decision.
73. The Authority has to satisfy its public sector duties under the Equalities Act 2010 (including specific Welsh public sector duties). Pursuant to these legal duties Authorities must in making decisions have due regard to the need to (1) eliminate unlawful discrimination, (2) advance equality of opportunity and (3) foster good relations on the basis of protected characteristics
74. Protected characteristics are: • Age • Gender reassignment • Sex • Race – including ethnic or national origin, colour or nationality • Disability • Pregnancy and maternity • Marriage and civil partnership • Sexual orientation • Religion or belief – including lack of belief
75. An Equality Impact Assessment is undertaken to ensure that the decision maker has understood the potential impacts of any decision in terms of equality. This assists the decision maker to ensure that it is making proportionate and rational decisions having due regard to the public sector equality duty.
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76. The October report referred to the Initial Equality Impact Assessment which had been carried out on this proposal which concluded that providing new premises for Eastern High would not adversely affect a particular group in society. The Equality Impact Assessment has been updated as mentioned in paragraph 115.
77. The decision maker must satisfy itself that the public sector equality duty is being met when making decisions and must therefore have regard to the Equality Impact Assessment attached as well as the other matters referred to in the Statutory Screening Tool at Appendix 4.
78. In undertaking the development of the design and procurement of a contractor it is necessary for the Authority to comply with its procurement duties pursuant to the Public Contracts Regulations 2006 as amended.
79. In relation to land dealings an Authority has to comply with its duties to obtain best consideration in accordance with Section 123 of the Local Government Act 1972. The arrangements should also reflect its fiduciary duty (as the holder of public funds), its duty to make arrangements for continuous improvement in the performance of its functions and the duty not to provide any unlawful state aid.
80. The VAT liability is that of CAVC but is currently proposed to be reimbursed by the Council as part of the transaction to utilise the land and as a cost of the project to deliver the intended purposes.
81. The decision maker will need to be satisfied that in so far as:
a. it is intended to rely upon the Council’s well-being power (section 2 Local Government Act 2000) to provide such reimbursement; or b. the additional cost of the VAT is forming part of agreed consideration for the transfer of the land which causes that consideration to exceed the reasonable value of the transfer and such approach is reliant on demonstration of well-being under the General Disposal Consent;
that it has carefully considered and identified the well-being (social, economic or environmental) of its area which will be directly promoted by such approach, that it is in accordance with the Council’s community strategy (“What Matters”) and that such approach is not in contravention of any other limitation or restriction which prevents the use of such power.
Financial Implications
82. At its meeting on 10 October 2013, the Cabinet instructed Officers to consult upon two options for a site on which to build a new state of the art 11-16 school (Eastern High), with post 16 provision to be delivered by Cardiff and Vale College (CAVC).
83. This current report presents the outcome of the consultation, and recommends that the new school is sited at the CAVC site in Trowbridge.
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84. The October 2013 Cabinet report estimated that the Net Capital Requirement of the new build being sited on the CAVC site would be £17.342 million. This was considered broadly in line with the Net Capital Requirement of previous proposals budgeted for within the SOP Financial Model, and was therefore considered manageable within existing resources (noting that opting to build upon the Trowbridge site allowed the Authority to realise the current Rumney site as a Capital receipt, which had not previously been assumed within the Financial Model).
85. Since October 2013, in addition to the Consultation exercise, there has been further progress in three areas which have had a material impact upon the Financial Implications:
• Updated Building Bulletin Guidelines (impacting upon the Design and thus the Capital Expenditure estimates);
• Updated Capital receipt estimates and some minor changes to interim costs;
• Discussions with HMRC around VAT implications of the collaborative arrangements between the Authority and Cardiff & Vale College.
86. Before considering the updated VAT implications, it should be noted that the first two points above have reduced the Net Capital Requirement estimate of the CAVC site to £13.620 million. An updated summary of the Net Capital Requirement (before consideration of VAT) of the two sites considered as part of the consultation are illustrated in the table below:
Llanrumney High Cardiff and Vale School site College site £million £million
Capital Expenditure 44.755 45.070
Specific Resources (34.810) (31.450)
Net Capital 9.945 13.620 Requirement
87. The Capital Expenditure figures above include the ‘Project’ costs of site specific works – which are relevant for the calculation of VAT implications at paragraph 94 below – and additional costs which fall outside the VAT calculation, for example interim costs at Llanrumney / Rumney, and provision of a Youth Centre.
88. It should also be noted that the effect of the revised Capital receipts would have had an adverse effect on the previous proposal (to build at the former Rumney High School site).
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89. £1.750 million of 21st Century Schools grant has already been approved and provided by Welsh Government, to support the interim works needed at the current Eastern High School.
90. The Net Capital Requirement – as calculated in paragraph 866 above – assumes a significant amount of further 21st Century Schools grant from Welsh Government. The approval of this grant is subject to submission of a Strategic Outline (Business) Case to WG.
91. The Directorate, in consultation with Financial Services, Legal Services and Procurement, will need to ensure that an appropriate procurement route is followed which does not put at risk the approval of the Strategic Outline Case (and thus put at risk the grant funding). Expectations arising from this report will need to be managed appropriately by the Directorate, until the full grant approval is received.
92. Recommendation 2 of this report requests that Officers are authorised to appoint a Project Manager. The report indicates that the role is likely to cost circa £200,000. The appointment is likely to be necessary before full grant approval is received from WG. There is a risk that the Project Management costs may therefore become abortive Revenue costs – falling upon the SOP Reserve – should the Council’s Business Case not be subsequently approved by WG.
93. The Council and Cardiff & Vale College have differing VAT statuses for VAT recovery purposes, hence it has been necessary for the Authority and the College to seek advice – in consultation with HMRC – on the potential options for collaboration. Specifically, in relation to the CAVC site, options for the transfer of land from the College to the Authority have been considered.
94. The Council will provide a construction service to the College for an estimated level of occupation (by the College). The irrecoverable VAT cost of this supply will be determined by whether the College is able to issue a zero rated certificate to the Council. The ability of the College to issue this certificate will be determined by the courses they wish to provide – classified as either business or non-business from a VAT perspective. Detailed analysis of the courses to be delivered is ongoing, however for the purposes of this report the worst case liability is considered to be £3.320 million. This is based upon an estimated ‘Project’ Capital cost of £39.103 million, a total occupancy (by the College) of 42.50%, and the VAT rate of 20%.
95. Additionally, the College has stated its commitment to funding £500,000 of the irrecoverable VAT liability, should it arise. Therefore, the net maximum liability for the Council – assuming neither the Project costs nor the College occupancy increase from the figures used within the calculation – should be £2.820 million.
96. As highlighted in paragraph 866 above, the estimated Net Capital Requirement of the scheme has reduced by £3.722 million since the October 2013 Cabinet report, therefore the indicative maximum VAT
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liability is considered affordable within the budget provision previously identified.
97. EU legislation advises that the irrecoverable VAT element would need to be repaid to HMRC as soon as the freehold has been transferred from the College to the Council from the beginning of the project. Arrangements will also need to be discussed with HMRC on how any over or under recovery of irrecoverable VAT will need to be treated at the end of the project should project costs increase or decrease respectively.
98. In the event that the College is successful in issuing a zero rated certificate in full for its occupied space, the liability may be nil.
99. The VAT implications considered above are specific to the CAVC site. The implications would be different in the event that the former Llanrumney High site were the preferred option, however the maximum VAT liability in that scenario is considered to be greater than the maximum liability on the CAVC site.
100. As per the October 2013 Cabinet report, the collaborative arrangements of working with CAVC will need to be agreed. The Directorate should include Officers from Finance in such discussions, to ensure that Best Value is achieved.
101. It should be noted that the financial analysis undertaken for the purposes of this Cabinet report is based upon construction of an 8FE school with post 16 provision. The report contains references to the potential to expand to 11FE in the future, though the cost implications have not been quantified. No budget provision currently exists for any Capital investment required for an expansion.
Human Resources Implications
102. The report concludes that the CAVC site be selected as the location of Eastern High and the HR implications arising from this are minimal. Over time, it is possible the relocation of the school to a new build state of the art building could result in an increase of admissions to the school which will need to be reflected in staffing levels.
103. The CAVC site is in close proximity to the site currently occupied by Eastern High and therefore there would be minimal disruption to travel arrangements for staff. The CAVC site is also fully accessible for staff by public transport and these transport links together with its close location to the M4 may also assist any future recruitment need of the school.
104. Communication with staff will need to be maintained on a regular basis to keep them informed of the transition arrangements from the current site to its new location.
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Traffic and Transport
105. The majority of pupils living within the catchment area would not qualify for free transport as they live within three miles walking distance to the CAVC site.
106. Pupils may only qualify for free home to school transport if their homes are along country lanes where there are no footpaths if these are classed as unavailable walking routes. Some pupils may qualify for free transport regardless of the distance involved as they do not have access to an available walking route. In these cases an assessment based on the number of traffic movements and availability of step offs would need to be undertaken on an individual basis when a pupil starts at or applies to start at the school. Currently, this mainly affects pupils living in some parts of the Wentloog area, Old St Mellons area off Bridge Road/Began Road and Druidstone Road.
107. Cardiff’s transport network is under pressure and experiences congestion from commuters driving into the city and people making short local trips by car. Traffic associated with the school run adds to congestion. Cardiff Council’s policy is to encourage and promote the increased use of sustainable travel modes and to promote independent travel to school wherever possible. This is particularly pertinent to pupils at Key Stages 3 and 4 as this age group is generally more able to undertake unaccompanied travel.
108. Emphasis is placed on travel by active modes where this is possible and on providing the facilities and opportunities at school for students to travel by walking, cycling and public transport. Reducing congestion at the school gate is key to ensuring the safety of pupils and to mitigating impact on the local neighbourhood.
109. There would be a requirement to improve and provide additional pedestrian crossing facilities along Newport Road (£75k approximately (this would be Capital funded)).
110. As the majority of pupils live on the Rumney, Trowbridge and St Mellons side of Newport Road, locating the new school on the Cardiff and Vale College site this would enable a large proportion of these to either walk to school or catch the local service buses that operate along Greenway Road.
111. As there are no direct bus services from the Burnham Avenue area of Llanrumney across to the Cardiff and Vale College site some pupils would have to walk up to 2.4 miles.
112. If supported school bus services were required to help reduce congestion and improve access for pupils then the cost of transporting pupils from the Burnham Avenue area across to the Cardiff and Vale College site would be £70k approximately for 2 buses. This would be Revenue funded which would need to be considered as part of the medium term financial plan.
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113. There may be a requirement for an additional school safety zone on the road immediately outside the site to cater for the additional pupil numbers attending. The school safety zone relates to parking, road speeds and pedestrian safety issues that would need to be improved to reduce the road speeds of vehicles and increase the visibility of pedestrians by improving the facilities such as zebra crossings, raise speed humps, increase signage and road markings. The costs and requirements are likely to be between £50-100k (this would be Capital funded).
Statutory Screening Tool
114. This is attached at Appendix 4 and includes the Equality Impact Assessment and Strategic Environmental Assessment.
Equality Impact Assessment
115. Following the October Cabinet report, an equality impact assessment was carried out on the two site options that were to be subject to public consultation. To update the Equality Impact Assessment following consultation, paragraphs 18 and 26 of this report have been copied into the relevant equality sections. These paragraphs cover the Council’s responses to views expressed by consultees on matters that might have equality implications. The responses expand on points made in the public consultation document, statutory screening tool and the previous Equality Impact Assessment and the conclusion remains that the proposal would not adversely affect a particular group in society.
116. At the design stage for the new build school, a further equality impact assessment would be undertaken on the accessibility of the new build accommodation. The equality impact assessment would take into account policies such as the Equality Act 2010, TAN 12: Design June 2009 as well as building regulations such as, BS8300 and Part M together with the appropriate Building Bulletins.
Environmental Assessment
117. Following public consultation, the Strategic Environmental Assessment (SEA) on the sites has been updated by copying in paragraph 35 of this report. Paragraph 35 expands on points made in the previous SEA. The assessment would be included as an appendix to the planning application environmental assessment for the new build school.
RECOMMENDATIONS
The Cabinet is recommended to:
1. approve the non-statutory transfer of Eastern High to the CAVC site in Trowbridge with effect from the completion of the new build;
2. authorise officers to appoint a Project Manager and to proceed with the necessary design work to deliver the project for a new build school and
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replacement all weather pitch in conjunction with the construction of post 16 facilities on the CAVC site in Trowbridge;
3. delegate authority to the Director of Education and Lifelong Learning in consultation with the Cabinet Members for Education and Skills and Corporate Services and Performance, the County Solicitor and the Corporate Director for Resources, subject to compliance with the Cabinet decision of 7 November 2013, to authorise officers to proceed with initial design works for 21st Century schools schemes up to 5% of project value and not to commit the Council to any other financial obligations, ahead of full approval of grant funding:
a. to secure the necessary agreements to ensure appropriate arrangements are in place for occupation and service delivery by Eastern High, CAVC and any other providers who will deliver education and/or training on/from the site; b.b.b. subject thereto to make the necessary arrangements for the use of Greenway Park as playing fields for the new build Eastern High in conjunction with post 16 facilities.
4. following full approval of the 21 st Century Schools grant, delegate authority to the Director of Education and Lifelong Learning in consultation with the Cabinet Members for Education and Skills and Corporate Services and Performance, the County Solicitor, and the Corporate Director for Resources, to determine all aspects of the procurement process to appoint a contractor for the construction of a new Eastern High and replacement all weather pitch in conjunction with the construction of post 16 facilities on the CAVC site in Trowbridge.
NICK BATCHELAR Director 11 July 2014
The following Appendices are attached
Appendix 1 Sites location map Appendix 2 Primary age pupil consultation Appendix 3 Eastern High pupil consultation Appendix 4 Statutory Screening Tool including the Equality Impact Assessment and Strategic Environmental Assessment
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1.
2.
Map: Indicative catchment area arrangements Reproduced from the Ordnance Survey mapping with the permission of the Controller of Her Majesty's Indicative Eastern High catchment area Stationery Office c Crown Copyright. (combined former Rumney High School and Llanrumney High School catchment areas) Unauthorised reproduction infringes Crown Copyright and may lead to prosecution or civil proceedings.
This copy is produced specifically to supply Council 1. Former Llanrumney High School site 2. Cardiff and Vale College site information. No further copies may be made. CARDIFF COUNTY COUNCIL Licence no.LA09005L.
Eastern High Pupil Consultation January 2014 Appendix 3
12345LEVEL OF IMPORTANCE
A 67 35 55 24 63 Access to/impact on the use of off-site playing fields.
B 54.9 52 48.7 37.9 54.4 Disruption to sites that wouild be occupied during construction.
C 55 52 48 37 52 Net cost, taking into account of estimated capital receipts and thus affordability.
D 117 68 24 20 11 Potential for future development inc possible co-location of other community facilities.
E 138 42 34 13 17 Proximity to pupil population.
Appendix 4 Cardiff Council Statutory Screening Tool Guidance
If you are developing a strategy, policy or activity that is likely to impact people, communities or land use in any way then there are a number of statutory requirements that apply. Failure to comply with these requirements, or demonstrate due regard, can expose the Council to legal challenge or other forms of reproach.
For instance, this will apply to strategies (i.e. Housing Strategy or Disabled Play Strategy), policies (i.e. Procurement Policy) or activity (i.e. developing new play area).
Completing the Statutory Screening Tool will ensure that all Cardiff Council strategies, policies and activities comply with relevant statutory obligations and responsibilities. Where a more detailed consideration of an issue is required, the Screening Tool will identify if there is a need for a full impact assessment, as relevant.
The main statutory requirements that strategies, policies or activities must reflect include:
• Equality Act 2010 - Equality Impact Assessment • Welsh Government’s Sustainable Development Bill • Welsh Government’s Statutory Guidance - Shared Purpose Shared Delivery • United Nations Convention on the Rights of the Child • United Nations Principles for Older Persons • Welsh Language Measure 2011 • Health Impact Assessment • Habitats Regulations Assessment • Strategic Environmental Assessment
This Statutory Screening Tool allows us to meet all the requirements of all these pieces of legislation as part of an integrated screening method that usually taken no longer than an hour.
The Screening Tool can be completed as a self assessment or as part of a facilitated session, should further support be needed. For further information or if you require a facilitated session please contact the Policy, Partnerships and Citizen Focus Team on 2078 8563 e-mail: [email protected] . Please note:
- The completed Screening Tool must be submitted as an appendix with the Cabinet report. - The completed screening tool will be published on the intranet.
Statutory Screening Tool
Name of Strategy / Policy / Activity: Date of Screening: A new build state of the art, 11-16 school constructed to replace the April 2014 existing facilities for Eastern High currently located on the site formerly known as Rumney High School site, with post-16 provision delivered by Cardiff and Vale College and potentially other providers such as St.David’s College.
Service Area/Section: Education Lead Officer: Nick Batchelar Attendees: Assessment bringing together information provided by relevant service areas.
What are the objectives of the Policy/Strategy/Project/Procedure/ Please provide background information on the Service/Function Policy/Strategy/Project/Procedure/Service/Function and any research done [e.g. service users data against demographic statistics, similar EIAs done etc.]
A new build state of the art, 11-16 school constructed to replace the Providing new build premises for Eastern High is an important strand of the existing facilities for Eastern High currently located on the site formerly wider Education Improvement Partnership (EIP) which focuses on known as Rumney High School site, with post-16 provision delivered by improving quality in leadership, teaching and learning as well as the quality Cardiff and Vale College and potentially other providers such as of the learning environment. St.David’s College.
Two sites had been selected as suitable options on which to consult:
- Cardiff and Vale College (CAVC) site located at Trowbridge Road, Rumney - The site of the former Llanrumney High School located at Ball Road, Llanrumney
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Part 1: Impact on outcomes and due regard to Sustainable Development
Please use the following scale when considering what contribution the activity makes: + Positive Positive contribution to the outcome
- Negative Negative contribution to the outcome ntrl Neutral Neutral contribution to the outcome Uncertain Not Sure Uncertain if any contribution is made to the outcome
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn 1.1 People in Cardiff are healthy; - See 1.2 below – encouraging walking, cycling and use of Consider the potential impact on public transport • the promotion of good health, prevention of damaging - See 1.3 below re crime prevention (Secure by Design) and behaviour, promote healthy eating/active lifestyles etc, addressing anti-social behaviour
• vulnerable citizens and areas of multiple deprivation • Addressing instances of inequality in health 1.2 People in Cardiff have a clean, attractive and sustainable - It is proposed that the design achieves BREEAM Excellent environment; or above. Consider the potential impact on - Where possible Passivhaus design principles and • the causes and consequences of Climate Change and methodology would be applied and adopted which result in creating a carbon lite city facilitating most of the school classroom windows facing North/South orientation, limiting and optimising summer and winter sun respectively. This minimises the use of energy for heating or cooling a room. - The wall construction and key junction details would be carefully developed to achieve a highly air tight building. - Wherever possible the design would promote, specify and use locally sourced materials which have a commitment to sustainability and the environment. • encouraging walking, cycling, and use of public transport - Limited scope for parking would encourage walking and and improving access to countryside and open space cycling to school.
- A travel plan would be submitted along with the planning application, detailing proximity to public transport and walking and cycling routes. Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 3 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn
- Emphasis is placed on travel by active modes where this is possible and on providing the facilities and opportunities at school for students to travel by walking, cycling and public transport. Encouraging active travel to school is a very important means of increasing levels of physical activity in children and tackling the growing problem of childhood obesity. Reducing congestion at the school gate is key to ensuring the safety of pupils and to mitigating impacts on the local neighbourhood.
- Provision of parent parking places is generally not supported by Cardiff Council. This is because such provision would promote travel to school by car, generate local traffic, contribute to congestion and reduce pupil safety. Parking facilities provided at schools is generally only for staff and to meet operational needs.
- Cardiff’s Supplementary Planning Guidance (Access, Circulation and Parking Standards 2010) sets out that all new or expanded schools are required to develop a Travel Plan for submission with a planning application. A Travel Plan is a policy and action plan to: o manage transport efficiently o improve access by all means of travel for employees, visitors, patients and students o encourage sustainable transport – walking, cycling, public transport and car sharing o reduce car use.
- A School Travel Plan is specifically designed to address the transport needs of pupils and staff and would vary according to the nature of the education being provided and the catchment area of the school.
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn • reducing environmental pollution (land, air, noise and water) Builders would be encouraged to minimise air, light and noise pollution during the construction period.
As part of the BREEAM process, an acoustic report would be prepared to ascertain the site acoustic levels and the acoustic impact of the school. A further report shall be prepared for the proposals in line with the BB93 Acoustics for School requirements.
• reducing consumption and encouraging waste reduction, Measures that would be considered in the design of the scheme reuse, recycling and recovery • Αchieve BREEAM Excellent or above • Sustainable urban drainage system • Solar hot water
• Photovoltaic • Natural Ventilation
• Control of solar gains
• Rainwater Harvesting • A or A+ rated materials in accordance with BRE Green Guide to Specification
Cardiff Council, Waste Management are consulted on the provision of waste and recycling collection on a school site. The level of waste would be assessed and an appropriately sized bin store provided. Further consultation would be held to ascertain recyclable facilities requirements and composting on site.
• encouraging biodiversity Initial evaluation concludes some mitigation may be needed on both the Llanrumney High School and Coleg Glan Hafren sites. A Strategic Environmental Assessment has been carried out. 1.3 People in Cardiff are safe and feel safe; The South Wales Police’s Crime Prevention Design Advisor Consider the potential impact on would be consulted on the project and the recommendations • reducing crime, fear of crime and increasing safety of considered and incorporated where practicable. It is the aim that the project would build to a Secure by Design standard. individuals
• addressing anti-social behaviour
• protecting vulnerable adults and children in Cardiff from Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 5 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn harm or abuse Recreational space for pupils would be part of either site and the school would work with pupils to address any incidents of anti- social behaviour during break times and before and after school. Concerns raised by local residents regarding littering would also be a matter for the school management and the school would work with pupils to try and establish a sense of personal responsibility to minimise littering by pupils within the local area. 1.4 Cardiff has a thriving and prosperous economy; See 1.5 below - a new build school and post 16 provision would Consider the potential impact on help people in Cardiff achieve their full potential and as a result
• economic competitiveness (enterprise activity, social would have a positive impact on the economy.
enterprises, average earnings, improve productivity) Consideration to be given to using local sub-contractors and • Assisting those Not in Education, Employment or Training suppliers. • attracting and retaining workers (new employment and training opportunities, increase the value of employment,) • promoting local procurement opportunities or enhancing the capacity of local companies to compete 1.5 People in Cardiff achieve their full potential; Age 11 – 16 Consider the potential impact on • promoting and improving access to life-long learning in - A school with the potential to expand to 11 Forms of Entry
Cardiff - Creation of a viable school able to deliver a full curriculum - A state of the art new build fit for the 21 st Century and • raising levels of skills and qualifications designed with the diverse needs of the modern day • giving children the best start curriculum in mind • improving the understanding of sustainability - A pupil learning experience that benefits from access to the • addressing child poverty (financial poverty, access poverty, latest technology and modern facilities participation poverty) - Facilities that enable the effective delivery of the Education • the United Nations Convention on the Rights of a Child and Improvement Partnership (EIP) Principles for Older persons - Minimised disruption to ongoing school activities during construction
Age 16+
- 21 st Century learning environment and facilities - On site post-16 provision - Improved life chances for young people by providing “ An
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn appropriate range of relevant courses and qualifications and high quality, employer informed, vocational learning routes targeted at pupils of all abilities, whilst maintaining GCSE, AS/A level and other established courses, as required under the Learning and Skills (Wales) Measure 2009 for 14-19 year old learners” (pg.13, Section 1.9, School Organisation Code July 2013) - Increased participation in learning by pupils beyond compulsory school age
All ages (where relevant)
- 21st Century learning environment and facilities - An exciting and attractive career proposition for high quality school leaders and teachers - Life-long learning opportunities - An inclusive school that is able to support the particular needs of pupils and their families - Investment in buildings enables schools to be best placed to provide the opportunities for learners to achieve their potential.
Providing new build premises for Eastern High is an important strand of the wider Education Improvement Partnership (EIP) which focuses on improving quality in leadership, teaching and learning as well as the quality of the learning environment. 1.6 Cardiff is a Great Place to Live, Work and Play Consider the potential impact on Both sites: • promoting the cultural diversity of Cardiff • encouraging participation and access for all to physical There are no known cultural heritage receptors recorded on the activity, leisure & culture online sources examined within or in close proximity to the site • play opportunities for Children and Young People of the proposed development. • protecting and enhancing the landscape and historic heritage of Cardiff Llanrumney High School site: • promoting the City’s international links The landscape would be protected as the site is an existing Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 7 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn school site which is relatively flat. This would enable the construction of the new build without the need to significantly change the topography of the site. The current conceptual plan places the new build school on the part of the site that the existing Llanrumney High School buildings occupy.
At risk of flooding from river without defences. Although area with defences along the western boundary of the site. Risk category: Medium
CAVC site:
The landscape would be protected as the site is an existing school site which is relatively flat. However the sports areas may have to be platformed and levelled by a cut and fill exercise.
At risk of flooding from estuary without defences. However, the site benefits from flood defences. Risk category: Low/medium
1.7 Cardiff is a fair, just and inclusive society. Consider the potential impact on See Equality Impact Assessment below. • the elimination of discrimination, harassment or victimisation for equality groups
• has the community or stakeholders been engaged in - Statutory public consultation on the proposal to provide a developing the strategy/policy/activity? new build premises for Eastern High has been carried out • how will citizen participation be encouraged (encouraging and implementation approved. actions that consider different forms of consultation, - A stakeholder engagement exercise was carried out on all through more in depth engagement to full participation in possible sites for a school. service development and delivery)? - Public consultation has been held on the two possible sites in order to find out what is important to stakeholders when considering a site on which to build the new school. - Future engagement with pupils and staff on the design of the new build school
- The Design Commission for Wales (DCfW) Review Panel Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 8 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn would be engaged - Design Equalities Advisory Group (including representatives from external groups) would be given the opportunity to comment - Relevant departments in the Council (e.g. Youth Service) - South Wales Police’s Crime Prevention Design Advisor - Ecological Appraisal - external surveyors
Consideration to be given to using local sub-contractors and suppliers.
Equality Impact Assessment Please give details/consequences of the differential impact (positive Will this Policy/Strategy/Project have a differential impact on and negative), and what action(s) can you take to address any any of the following: negative implications?
• Age (including children and young people aged 0-25 and Assessment of building a new school premises older people over 65 in line with the United Nations Conventions) Age 11 – 16
- Creation of a viable school able to deliver a full curriculum - A state of the art new build fit for the 21 st Century and designed with the diverse needs of the modern day curriculum in mind - A pupil learning experience that benefits from access to the latest technology and modern facilities - Facilities that enable the effective delivery of the Education
Improvement Partnership (EIP) - Minimised disruption to ongoing school activities during construction
Age 16+
st - 21 Century learning environment and facilities - On site post-16 provision - Improved life chances for young people by providing “ An appropriate range of relevant courses and qualifications and Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 9 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn high quality, employer informed, vocational learning routes targeted at pupils of all abilities, whilst maintaining GCSE, AS/A level and other established courses, as required under the Learning and Skills (Wales) Measure 2009 for 14-19
year old learners” (pg.13, Section 1.9, School Organisation Code July 2013) - Increased participation in learning by pupils beyond compulsory school age
All ages (where relevant)
- 21st Century learning environment and facilities - An exciting and attractive career proposition for high quality school leaders and teachers - Life-long learning opportunities - An inclusive school that is able to support the particular needs of pupils and their families
Redeployment
There may still be a perception that redeployment opportunities could be affected by age.
The Council’s procedure for managing staffing changes arising from reorganisation would be used in implementing any changes as a result of this proposal. This would ensure that good
practice is followed, including the application of the Council’s policies on equal opportunities.
Assessment of the two possible sites (Llanrumney High School Site and CAVC site
Availability of local secondary places for pupils aged 11-16
and 16+:
Both sites offer sufficient potential for the school to expand to 11 Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 10 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn FE plus post 16 facilities.
The developable ‘footprint’ for each site allows for similar potential to develop.
Impact on the viability of other schools providing education
to 11-16 year olds:
It is expected that the outflow of pupils to English-medium
secondary schools in other areas of Cardiff, which in January
2013 amounted to 137 pupils aged 11-16, would be significantly
reduced as a result of the new build school whichever site it is
constructed on. The number of these pupils attending those
schools are small and widely spread and the impact upon each
of those schools is therefore expected to be minimal and would
be mitigated by the projected increase in the pupil population in
those areas.
Should the outflow of pupils from English-medium community
primary schools to faith secondary schools reduce then it may
be necessary for the new Eastern school to be expanded. Either
of the two sites is considered to offer sufficient potential for the
school to expand to 11FE plus post 16 facilities.
Admissions to both St Teilo’s Church in Wales High School and
St Illtyd’s Catholic High school are determined by the Governing
Body of the individual school. Each of these schools has been
fully subscribed at entry for a number of years and this is
projected to continue in future years.
The demand for Welsh-medium places at Ysgol Gyfun Gymraeg
Bro Edern, which also serves the area, has grown since 2011
and the school has received investment. It is projected that
should this proposal be implemented demand for places at
Ysgol Gymraeg Bro Edern will continue to rise.
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn Therefore, it is not anticipated that there will be any impact on outcomes, provision or leadership and management at other schools serving the proposed catchment area of Eastern High arising out of a decision to build on one site or the other. Proximity of the sites to the pupil population and transport implications
The vast majority of pupils would not qualify for free transport living within the proposed catchment area as all pupils live within 3 miles walking distance to either the CAVC site or the Llanrumney High School site.
Pupils may only qualify for free home to school transport if their homes are along country lanes where there are no footpaths if these are classed as unavailable walking routes. Some pupils may qualify for free transport regardless of the distance involved as they do not have access to an available walking route to either site. In these cases an assessment based on the number of traffic movements and availability of step offs would need to be undertaken on an individual basis when a pupil starts at or applies to start at the school. Currently, this mainly affects pupils living in some parts of the Wentloog area, old St Mellons area off Bridge Road/Began Road & Druidstone Road. (More detail is provided in respect of Gypsy Traveller pupils under Race in this equality impact assessment).
It is recognised that there would be potential traffic congestion around the school site at the beginning/end of the school day. However, the Council would work with the Governing Body of the school to develop a Travel Plan to minimise any potential disruption. Traffic and transport implications would be considered as part of the Transport Assessment that would be required in order to achieve planning consent for building works. Either site may require additional school safety zones on the Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 12 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn roads immediately outside their site to cater for the additional pupil numbers attending. The school safety zones relate to parking, road speeds and pedestrian safety issues that would need to be improved to reduce the road speeds of vehicles and
increase the visibility of pedestrians by improving the facilities such as zebra crossings, raised speed humps, increased signage and road markings. The costs and requirements are likely to be similar for both sites (between £50-100k – this would be Capital funded).
Cardiff’s transport network is under pressure and experiences congestion from commuters driving into the city and people making short local trips by car. Traffic associated with the school run adds to congestion. Cardiff Council’s policy is to encourage and promote the increased use of sustainable travel modes and to promote independent travel to school wherever possible. This is particularly pertinent to pupils at Key Stages 3 and 4 as this age group is generally more able to undertake unaccompanied travel.
Emphasis is placed on travel by active modes where this is possible and on providing the facilities and opportunities at school for students to travel by walking, cycling and public transport. Encouraging active travel to school is a very important means of increasing levels of physical activity in children and tackling the growing problem of childhood obesity. Reducing
congestion at the school gate is key to ensuring the safety of pupils and to mitigating impacts on the local neighbourhood.
Provision of parent parking places is generally not supported by Cardiff Council. This is because such provision would promote travel to school by car, generate local traffic, contribute to congestion and reduce pupil safety. Parking facilities provided at schools is generally only for staff and to meet operational needs.
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn Cardiff’s Supplementary Planning Guidance (Access, Circulation and Parking Standards 2010) sets out that all new or expanded schools are required to develop a Travel Plan for submission with a planning application. A Travel Plan is a policy and action
plan to: • manage transport efficiently • improve access by all means of travel for employees, visitors, patients and students • encourage sustainable transport – walking, cycling, public transport and car sharing • reduce car use.
A School Travel Plan is specifically designed to address the transport needs of pupils and staff and will vary according to the nature of the education being provided and the catchment area of the school.
Table 1 on page 24 of this screening tool presents an analysis
of distance by safe walking routes from the homes of pupils attending Llanrumney and Rumney High Schools from within
their catchment areas as at March 2013.
The detailed location of pupils’ home addresses will change from year to year but the table is considered to represent an appropriate measure based on recent preferences. If the table
were to be based on primary school or pre school cohorts it
would not be known which addresses to discount on the basis of parental preference. It would be reasonable to note however that recent preferences for attendance at either of the two high schools are likely to reflect fairly consistent patterns of distribution across the communities.
In terms of average distance of travel for pupils the table shows that the Llanrumney High School site is considerably further away from where pupils live being on average 38% further away compared to the CAVC site. Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 14 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn
In terms of the maximum distance the CAVC site is 37% closer than the Llanrumney High School site to the addresses measured.
Based on recent pupil demographics within the proposed catchment, approximately 1/3 of the new school population live on the Llanrumney side of Newport Road and 2/3 live on the Rumney, Trowbridge and St Mellons side of Newport Road.
If the new school is located on the CAVC site this would enable a large proportion of pupils to either walk to school or catch the local service buses that operate along Greenway Road.
It is therefore considered that the CAVC site is best located to serve the proposed Eastern High catchment area with the Llanrumney High School site being less suitable by a significant measure. As there are no direct bus services from the Burnham Avenue area of Llanrumney across to the CAVC site some future pupils could in theory have to walk up to 2.4 miles. However double the number of pupils living in the St Mellons area would face similar issues if the school was located on the Llanrumney High School site as there are no direct public bus services from their area across to the Llanrumney High School site.
If supported bus services were required to help reduce congestion and improve access for pupils then the costs would be double to transport pupils from the St Mellons area across to the Llanrumney High School site, compared to the costs of transporting pupils from the Burnham Avenue area across to the CAVC site (CAVC site £70k approx for two buses, Llanrumney High School site £140k approx for four buses). This would be revenue funded which would need to be considered as part of the medium term financial plan. Provision of these additional Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 15 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn services would be subject to affordability.
Both the CAVC site and the former Llanrumney High School site are in close proximity to the site currently occupied by Rumney High School and therefore there would be minimal disruption to travel arrangements for staff. Both sites are also fully accessible for staff by public transport and these transport links together with the close location of both sites to the M4 may also assist any future recruitment needs of the school.
Youth services
Regardless of site chosen the cost of a replacement Llanrumney Youth Centre is allowed for.
• Disability Assessment of building a new school premises
An equality impact assessment would be carried out at the design stage on the accessibility of the new build
accommodation. The equality impact assessment would take into account policies such as the Equality Act 2010, TAN 12: Design June 2009 as well as building regulations such as, BS8300, Part M and relevant Building Bulletin guidelines.
The design stage would give consideration to future proofing the
building in terms of accessibility. For example, space could be provided to enable accessible toilets to be modified without significant structural changes being required. A higher specification accessible toilet as has been installed recently in Llanishen High School and the required space to provide a Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 16 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn Changing Spaces toilet if the need arises, will be factored into the initial designs for the new build school.
The new school would be designed to meet the needs of the
following:
- Those with a hearing impairment – e.g. appropriate acoustics, British Sign Language images/symbols and portable/static hearing loops.
- Those with a visual impairment - e.g. the use of colour to
differentiate between the function of spaces, tactile maps and Braille language on signs.
- Those with a physical impairment – e.g. level threshold doors, lifts with disabled access
- Those with learning disabilities – e.g. quiet spaces
Assessment of the two possible sites (Llanrumney High School Site and CAVC site
The CAVC site would need to remain occupied during construction of new facilities. The logistics of doing so would take into account the need to maintain accessible routes to the entrances of buildings.
The Llanrumney High School site would potentially be vacant but may still at this stage house youth and/or all weather pitch facilities. The logistics of building a new build school on a site which is partially occupied / used would take into account the need to maintain accessible routes to these facilities.
Access to offsite playing fields
An equality impact assessment would be carried out at the
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn design stage on the accessibility of the new build accommodation. The equality impact assessment would take into account policies such as the Equality Act 2010, TAN 12: Design June 2009 as well as building regulations such as,
BS8300, Part M and relevant Building Bulletin guidelines.
Both sites would be able to accommodate the buildings to be constructed but each would need to access at least some off site playing field facilities should the school grow to 11FE or accommodate significant community facilities.
The CAVC site would require the use of Greenway Park which is a short distance across a relatively minor road which accesses residential areas the scale of which could increase depending on the outcome of consultation on the Local Development Plan.
The use of Greenway Park is considered to be of potential benefit to the community as the fields currently have no changing facilities and are not used for any organised sport. The Llanrumney High School site would require some use of adjacent fields such as those used by Cardiff University and/or Rumney Rugby Football Club. This is not considered to be problematic. It should also be noted that should this site not be chosen for the new build the grassed areas would be made available to the community.
It is therefore considered that the facilities for off site playing fields in relation to the CAVC and Llanrumney High School sites would be suitable.
Access to off-site playing fields for pupils with a disability
The needs of pupils with a disability would be considered by the school on a case by case basis and if required, arrangements put in place.
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn • Gender Reassignment If the proposal proceeds, the privacy of changing and toilet facilities would be considered at the design stage. The assessment would refer to policies such as the Equality Act 2010, TAN 12: Design June 2009 as well as building regulations such as, BS8300, Part M and Building Bulletin guidelines.
The Council’s recruitment process would ensure that good practice is followed, including the application of the Council’s policies on equal opportunities. • Marriage & Civil Partnership N/A • Pregnancy & Maternity An equality impact assessment would be carried out at the design stage on the accessibility of the new build accommodation. The equality impact assessment would take into account policies such as the Equality Act 2010, TAN 12: Design June 2009 as well as building regulations such as, BS8300, Part M and Building Bulletin guidelines.
• Race Assessment of building a new school premises
The proposal would not have a differential impact upon one particular ethnic group as the provision would be available to all.
The following support offered would not be adversely affected when Eastern High transfers to the new build premises:
Gypsy Traveller Community
Support from the Traveller Education Service (TES) is provided based on the individual needs of the pupil, resources available to the school and to the TES. Currently, the TES provides 3 days support from 2 TES teachers and has trained and placed one volunteer at Rumney High School. This level of support would continue and 0.4 is the indicative allocation for the replacement school. This has been generated via the Needs Assessment Survey.
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn EU ROMA
Currently there is additional support for EU ROMA of 2 days of Bilingual Teaching Assistant support which is assessed and allocated at least termly.
Black Caribbean Project
The Black Caribbean Project works in Eastern High (formerly known as Rumney High School) for one day a week with one member of staff. This is a flexible arrangement depending on need.
Assessment of the two possible sites (Llanrumney High School Site and CAVC site
The vast majority of pupils would not qualify for free transport living within the proposed catchment area as all pupils live within 3 miles walking distance to either the CAVC site or the Llanrumney High School site.
Pupils may only qualify for free home to school transport if their homes are along country lanes where there are no footpaths if these are classed as unavailable walking routes. Some pupils may qualify for free transport regardless of the distance involved as they do not have access to an available walking route to either site. In these cases an assessment based on the number of traffic movements and availability of step offs would need to be undertaken on an individual basis when a pupil starts at or applies to start at the school. Currently, this mainly affects pupils living in some parts of the Wentloog area, old St Mellons area off Bridge Road/Began Road & Druidstone Road.
Shirenewton Site and Wentloog level farm sites
Pupils from these sites would have to travel further to attend a school on the Llanrumney High School site as opposed to the Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 20 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn CAVC site.
Some pupils from the Shirenewton Farm site and the Wentloog Level farm sites would be eligible for free transport if the school was on the Llanrumney High School site. For those without free transport, there is no direct public transport from these sites to Llanrumney High School site and the journey would require catching two buses. The alternative would be to use the existing walking route. A full assessment of the key junctions would need to be carried to ascertain the facilities required to improve the walking route.
Pupils from all of the Shirenewton sites would not be eligible for free transport to the CAVC site and therefore would use the walking route available. A full assessment of the key junctions is to be carried to ascertain the facilities required to improve the walking route and a proposal is to be put forward for an existing bus service to operate a two way service. This would provide a link to existing bus services or other walking routes closer to the CAVC site. Welsh Government legislation/guidance is due to change in the near future with regard to the requirements of a walking route and this may mean that the existing walking route is no longer suitable. If this is judged to be the case then options would be considered to address issues raised.
Rover Way Site
Although pupils from the Rover Way site would have to travel further to attend a school on the Llanrumney site as opposed to the CAVC site, they would not be entitled to free transport to either site regardless of the distance, as they would be attending a school other than the nearest appropriate catchment area school for their address. Willows High School is the appropriate catchment area English medium community school for their address.
There is no public transport or safe walking route from the Rover
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Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn Way site to either of the proposed school sites as there are no footpaths. Rover Way has been deemed as not suitable to walk along due to the number and category of vehicles that travel along it. Free home to school transport has been agreed to be provided to pupils living at Rover Way who attend their nearest appropriate catchment area schools; however if parents chose to send their children to a school other than the nearest appropriate catchment area school then they are responsible for any transport costs incurred in-order that their children attend school on a regular basis regardless of the distance involved.
• Religion/Belief The senior staff in a school would be best placed to manage diversity in terms of belief. (e.g. provision of a space for prayer). If the proposal were to proceed, group rooms provided as part of the design could be used to meet this need. • Sex The Council’s recruitment process would ensure that good practice is followed, including the application of the Council’s policies on equal opportunities.
The school would continue to admit pupils of both sexes.
The Council’s procedure for managing staffing changes arising from reorganisation would be used in implementing the changes in this proposal. This ensures that good practice is followed, including the application of the Council’s policies on equal opportunities.
• Sexual Orientation Fears that recruitment opportunities could be affected by sexual orientation.
Evidence collated by the Stonewall lobby group alleges that LGB people are likely to be discriminated against in workplace recruitment.
The Council’s recruitment process would ensure that good practice is followed, including the application of the Council’s Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 22 of 33
Has the Strategy/Policy/Activity considered how it will Please Tick Evidence or suggestion for improvement/mitigation Un- Ntrl impact one or more of Cardiff’s 7 Citizen focused Outcomes? + - Crtn policies on equal opportunities.
The Council’s procedure for managing staffing changes arising from reorganisation would be used in implementing the changes in this proposal. This ensures that good practice is followed, including the application of the Council’s policies on equal opportunities.
• Welsh Language Proposals relating to English-medium or Welsh-medium educational provision are put forward in response to parental choice.
Signage and other way finding techniques would be considered at the design stage.
It is Cardiff Council policy to provide signage in English and Welsh but not in other spoken languages. Therefore, additional way-finding methods would be considered including the use of colour to differentiate between the function of spaces, tactile maps, Braille language on signs and British Sign Language images/symbols. 1.8 The Council delivers positive outcomes for the city and its Providing new build premises for Eastern High is an important citizens through strong partnerships strand of the wider Education Improvement Partnership (EIP) Consider the potential impact on which focuses on improving quality in leadership, teaching and
• strengthening partnerships with business and voluntary learning as well as the quality of the learning environment.
sectors Potential for partnerships/shared services/efficiency savings that • the collaboration agenda and the potential for shared arise from constructing a high school and post-16 facilities on services, cross-boundary working and efficiency savings the same site.
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Table 1 (as referenced under Age (page 9) in the Equality Impact Assessment above)
An analysis of distance by safe walking routes from the homes of pupils attending Llanrumney and Rumney High Schools from within their catchment areas as at March 2013.
Source data: EMS One Live, March 2013
East sites: home to Pupils on roll resident within Eastern High catchment area school safe walking Llanrumney High site Cardiff and Vale College site route distances (2 entrances) (2 entrances) Number of % Number of % pupils pupils < 0.5 mile 74 7.4% 167 16.6% ≥ 0.5 mile 932 92.6% 839 83.4% Total pupils 1006 100% 1006 100%
< 1 mile 348 34.6% 490 48.7% ≥ 1 mile 658 65.4% 516 51.3% Total pupils 1006 100% 1006 100%
> 3 miles 0 0% 0 0%
Llanrumney High site Cardiff and Vale College site (2 entrances) (2 entrances) Average distance 1.34 0.97 (miles) Minimum distance 0 0 (miles) Maximum distance 2.842 1.792 (miles)
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SUMMARY OF APPRAISAL (highlight positive and negative effects of the policy / plan / project being assessed, demonstrating how it contributes to the economic, social and environmental sustainability of the city):
Economic/Educational/Social
Age 11 – 16
- Creation of a viable school able to deliver a full curriculum - A state of the art new build fit for the 21 st Century and designed with the diverse needs of the modern day curriculum in mind - A pupil learning experience that benefits from access to the latest technology and modern facilities - Facilities that enable the effective delivery of the Education Improvement Partnership (EIP) - Minimised disruption to ongoing school activities during construction
Age 16+
- 21 st Century learning environment and facilities - On site post-16 provision - Improved life chances for young people by providing “ An appropriate range of relevant courses and qualifications and high quality, employer informed, vocational learning routes targeted at pupils of all abilities, whilst maintaining GCSE, AS/A level and other established courses, as required under the Learning and Skills (Wales) Measure 2009 for 14-19 year old learners” (pg.13, Section 1.9, School Organisation Code July 2013) - Increased participation in learning by pupils beyond compulsory school age
All ages (where relevant)
- 21st Century learning environment and facilities - An exciting and attractive career proposition for high quality school leaders and teachers - Life-long learning opportunities - An inclusive school that is able to support the particular needs of pupils and their families
Secure by Design
The South Wales Police’s Crime Prevention Design Advisor would be consulted on the project and the recommendations considered and incorporated where practicable. It is the aim that the project would build to a Secure by Design standard.
Recreational space for pupils would be part of either site and the school would work with pupils to address any incidents of anti-social behaviour during break times and before and after school. Concerns raised by local residents regarding littering would also be a matter for the school management and Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 25 of 33 the school would work with pupils to try and establish a sense of personal responsibility to minimise littering by pupils within the local area.
An accessible school
An equality impact assessment would be carried out at the design stage on the accessibility of the new build accommodation. The equality impact assessment would take into account policies such as the Equality Act 2010, TAN 12: Design June 2009 as well as building regulations such as, BS8300, Part M and relevant Building Bulletin guidelines.
The design stage would give consideration to future proofing the building in terms of accessibility. For example, space could be provided to enable accessible toilets to be modified without significant structural changes being required. A higher specification accessible toilet as has been installed recently in Llanishen High School and the required space to provide a Changing Spaces toilet if the need arises, would be factored into the initial designs for the new build school.
The new school would be designed to meet the needs of the following:
- Those with a hearing impairment – e.g. appropriate acoustics, British Sign Language images/symbols and portable/static hearing loops.
- Those with a visual impairment - e.g. the use of colour to differentiate between the function of spaces, tactile maps and Braille language on signs.
- Those with a physical impairment – e.g. level threshold doors, lifts with disabled access
- Those with learning disabilities – e.g. quiet spaces
Environmental sustainability
It is proposed that the design achieves BREEAM Excellent or above
The limited scope for parking would encourage walking and cycling to school.
A travel plan would be submitted along with the planning application, detailing proximity to public transport and walking and cycling routes.
Achieved by incorporating water efficiency measures into the building design and where feasible addressing drainage through Sustainable urban drainage systems (SUDS).
WHAT ACTIONS HAVE BEEN IDENTIFIED OR CHANGES BEEN MADE TO THE POLICY / PLAN / PROJECT AS A RESULT OF THIS APPRAISAL: Recommendations made in the Equality Impact Assessment on the design of the building and any made in the Ecological Appraisal would be taken into account in the planning application Design & Access Statement and Environmental Assessment respectively. Stat Tool Process Issue Status: 02 Stat Tool Process Issue Date: 23/08/11 Stat Tool Process Owner: D. Owen Stat Tool Process Authorisation: R. Jones Page 26 of 33
Part 2: Strategic Environmental Assessment Screening
Yes No 2.1 Does the plan or programme set the framework for future x development consent? 2.2 Is the plan or programme likely to have significant, positive or x negative, environmental effects?
Is a Full Strategic Environmental Assessment Screening Yes No Needed? X If yes has been ticked to both questions 2.1 and An SEA has been 2.2 then the answer is yes undertaken.
If a full SEA Screening is required then please contact the Sustainable Development Unit to arrange (details below)
If you have any doubt on your answers to the above questions regarding SEA then please consult with the Sustainable Development Unit on 2087 3228 [email protected]
Part 3: Habitat Regulation Assessment (HRA)
Yes No Unsure
3.1 Will the plan, project or programme results in an activity x which is known to affect a European site, such as the Severn Estuary or the Cardiff Beech Woods? 3.2 Will the plan, project or programme which steers x development towards an area that includes a European site, such as the Severn Estuary or the Cardiff Beech Woods or may indirectly affect a European site? 3.3 Is a full HRA needed? x
Details of the strategy will be sent to the County Ecologist on completion of the process to determine if a Habitat Regulation Assessment is needed.
For further information please phone 2087 3215 or email [email protected]
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Appendix 1 – Statutory Requirements
It is possible that the Impact Screening Tool will identify the need to undertake specific statutory assessments:
• Equality Impact Assessment : This assessment is required by the Equality Act 2010 and Welsh Government’s Equality Regulations 2011. • Sustainable Development Bill : The Bill, when it comes into effect, will require sustainable development (SD) to be a central organising principle for the organisation. This means that there is a duty to consider SD in the strategic decision making processes. • Shared Purpose Shared Delivery - The Welsh Government requires local authorities to produce a single integrated plan to meet statutory requirements under a range of legislation. Cardiff Council must therefore demonstrate its contribution towards Cardiff’s own integrated plan; “What Matters ”. • United Nations Convention on the Rights of the Child : The Children Act 2004 guidance for Wales requires local authorities and their partners to have regard to the United Nations Convention on the Rights of a Child. • United Nations Principles for Older Persons: The principles require a consideration of independence, participation, care, self-fulfillment and dignity. • The Welsh Language Measure 2011 : The measure sets out official status for the Welsh language, a Welsh language Commissioner, and the freedom to speak Welsh. • Health Impact Assessment : (HIA) considers policies, programmes or projects for their potential effects on the health of a population • Strategic Environmental Impact Assessment: A Strategic Environmental Assessment (SEA) is an European Directive for plans, programmes and policies with land use implications and significant environmental effects. • Habitats Regulations Assessment : The Conservation (Natural Habitats, &c.) (Amendment) Regulations 2007 provides a requirement to undertake Habitats Regulations Assessment (HRA) of land use plans.
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Environmental Report (July 2014): Sustainability Appraisal (SA) Incorporating Strategic Environmental Assessment (SEA) on potential sites for the new build Eastern High.
Background
In 2008, a retrospective Strategic Environmental Assessment (SEA) of Cardiff’s 21 st Century: A Strategic Framework for a School Building Improvement Programme (published in 2006) was carried out based on the guidance that supports the European SEA Directive 2001/42/EC.
The retrospective approach to assessment was quality assured by an external consultant and their independent compliance review determined that the report detailing the assessment on the strategic framework met the key requirements set out for reporting the SEA process as required by the SEA Directive.
The retrospective assessment provides the basis for assessing current and future school organisation proposals at a strategic level.
To request a copy of the assessment on the Strategic Framework please contact Clive Bailey, 029 2087 3166, [email protected] .
Approach to assessment
This strategic assessment to be included as an appendix to the Environmental assessment submitted as part of any planning application.
Version
This assessment is an update of the SEA completed in August 2013 on the following sites:
- Land at areas 9-12, St Mellons - Trowbridge Mawr (Land west of Trowbridge Road, south of Greenway Park and north of Wentloog Road) - Colleg Glan Hafren site - Llanrumney High School Site - Rumney High School site
Consultation has now been held on building the new school on the Llanrumney High School site or the CAVC site. Please see update in the Conclusion on page 33.
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Key:
xx = very incompatible; very negative effect x = incompatible; negative effect ✔ = compatible; positive effect ✔ ✔ = very compatible; very positive effect 0 = no links; neutral effect ? = uncertain effects DNA = data not available
SEA objective Land at areas 9-12, St Mellons Trowbridge Mawr (Land west of Colleg Glan Hafren site Llanrumney High School Site Rumney High School site Trowbridge Road, south of Greenway Park and north of Wentloog Road) Rating Commentary/ explanation Rating Commentary/ explanation of Rating Commentary/ explanation of Rating Commentary/ Rating Commentary/explanation of compatibility compatibility compatibility explanation of of compatibility compatibility 1. Promote a greener ✔ Achieved by replacing a ✔ Achieved by replacing a 1960s ✔ Achieved by replacing a 1960s ✔ Achieved by replacing a ✔ Achieved by replacing a economy by delivering 1960s premises with a premises with a sustainable premises with a sustainable new 1960s premises with a 1960s premises with a
a sustainable pattern sustainable new build school. new build school. The lifespan build school. The lifespan of a new sustainable new build sustainable new build
of schools across The lifespan of a new build is of a new build is expected to be build is expected to be 50 years and school. The lifespan of school. The lifespan of a Cardiff expected to be 50 years and 50 years and would be would be designed with the diverse a new build is expected new build is expected to be would be designed with the designed with the diverse needs of the modern day curriculum to be 50 years and 50 years and would be (the phrase “promote a diverse needs of the modern needs of the modern day in mind. would be designed with designed with the diverse greener economy” day curriculum in mind. curriculum in mind. the diverse needs of the needs of the modern day describes the A new build that is BREEAM modern day curriculum curriculum in mind. aspiration to minimise A new build that is BREEAM A new build that is BREEAM Excellent or above. in mind. the combined carbon Excellent or above. Excellent or above. A new build that is footprint of Cardiff’s Achieved by designing water efficient A new build that is BREEAM Excellent or schools through new Achieved by designing water Achieved by designing water measures into the building design BREEAM Excellent or above. build, maintaining a efficient measures into the efficient measures into the and addressing drainage through above. low level of surplus building design and building design and addressing Sustainable urban drainage systems capacity, and where addressing drainage through drainage through Sustainable (SUDS). Since 2010, SUDS have possible, introducing Sustainable urban drainage urban drainage systems been compulsory for new build energy/water efficiency systems (SUDS). Since (SUDS). Since 2010, SUDS schemes. measures) 2010, SUDS have been have been compulsory for new compulsory for new build build schemes. schemes.
2. Reduce greenhouse ✔ A new build that is BREEAM ✔ A new build that is BREEAM ✔ A new build that is BREEAM ✔ A new build that is ✔ A new build that is gas emissions through: Excellent or above. Excellent or above. Excellent or above. BREEAM Excellent or BREEAM Excellent or
above. above. 0 0 0 a) A strategy to encourage the A strategy to encourage the use A strategy to encourage the use of 0 Energy efficient use of sustainable modes of of sustainable modes of sustainable modes of transport A strategy to encourage A strategy to encourage the 0 building design and transport would be outlined in transport would be outlined in a would be outline Government and as the use of sustainable use of sustainable modes
disposing of poor a travel plan as required by travel plan as required by the part of the planning application for modes of transport of transport would be quality surplus the Welsh Government and Welsh Government and as part the new school. would be outline outlined in a travel plan as accommodation as part of the planning of the planning application for Government and as required by the Welsh application for the new the new school. Council Policy on free transport for part of the planning Government and as part of b) school. children living outside of a 3 mile application for the new the planning application for Promoting sustainable Council Policy on free transport radius of a secondary school, would school. the new school. modes of transport and Council Policy on free for children living outside of a 3 apply to this proposal. integrated transport transport for children living mile radius of a secondary Council Policy on free Council Policy on free systems outside of a 3 mile radius of a school, would apply to this Consideration to be given to the transport for children transport for children living secondary school, would proposal. number of parking spaces on the living within a 2 mile within a 2 mile radius of a apply to this proposal. school site so that use of public radius of a primary primary school, would apply Consideration to be given to the transport is encouraged. school, would apply to to this proposal. Consideration to be given to number of parking spaces on this proposal. the number of parking spaces the school site so that use of School safety zones would be set up Consideration to be given on the school site so that use public transport is encouraged. to address health and safety Consideration to be to the number of parking of public transport is concerns for pedestrians and cyclists given to the number of spaces on the school site encouraged. School safety zones would be due to increased traffic flows in the parking spaces on the so that use of public set up to address health and school vicinity school site so that use transport is encouraged. School safety zones would be safety concerns for pedestrians of public transport is set up to address health and and cyclists due to increased encouraged. School safety zones would Issue Status: 02 Date: 23/08/11 Process Owner: D. Owen Authorisation: R. Jones Page 30 of 30 33
safety concerns for traffic flows in the school vicinity be set up to address health pedestrians and cyclists due School safety zones and safety concerns for to increased traffic flows in would be set up to pedestrians and cyclists the school vicinity address health and due to increased traffic safety concerns for flows in the school vicinity pedestrians and cyclists due to increased traffic flows in the school vicinity
3. Promote health and 0 The site is Council owned 0 The site is Council owned land 0 The site is not categorised as public 0 The site is Council 0/x The site is Council owned wellbeing by protecting land and is not categorised as and is not categorised as public open space. owned land and is not land and is not categorised and enhancing public public open space. open space. categorised as public as public open space. open space (POS) and ? 0 However, the school would require open space. improving access to The St Mellons site has the the use of public open space at The Rumney High School POS potential to accommodate Greenway Park which is a short However, the school site would rely quite heavily future expansion of the school distance across a relatively minor would require some use on use of the Rumney buildings and school sports road which accesses residential of adjacent fields such Recreation Ground which is requirements (as compliant areas the scale of which could as those used by a short distance away, with BB98). However, the increase depending on the outcome Cardiff University across the busy Newport use of the existing site for of consultation on the Local and/or Rumney Rugby Road. Given the history of school sports use may be Development Plan. The use of Football Club. This is this site in relation to the limited by the demands of the Greenway Park is considered to be not considered to be proposal for a new high site for existing surface water of potential benefit to the community problematic. school, the need for run off (drainage ditches). as the fields currently have no organised games during changing facilities and are not used It should be noted that much of the daytime during for any organised sport. should the Llanrumney school weeks and the High School site not be recent granting of Queen used for the new build Elizabeth II status is school, the grassed considered likely to be areas on this site would problematic. be made available to the community.
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SEA objective Land at areas 9-12, St Mellons Trowbridge Mawr (Land west of Trowbridge Colleg Glan Hafren site Llanrumney High School Site Rumney High School site Road, south of Greenway Park and north of Wentloog Road) Rating Commentary/ explanation of Rating Commentary/ explanation of Rating Commentary/ explanation of Rating Commentary/ explanation Rating Commentary/explanation compatibility compatibility compatibility of compatibility of compatibility
4. Minimise air, light 0 Builders would be encouraged 0 Builders would be encouraged to 0 Builders would be encouraged to 0 Builders would be 0 Builders would be and noise pollution to minimise air, light and noise minimise air, light and noise minimise air, light and noise pollution encouraged to minimise air, encouraged to minimise air, associated with pollution during the construction pollution during the construction during the construction period. light and noise pollution light and noise pollution building development period. period. during the construction during the construction and traffic congestion period. period.
5. Protect and enhance x/? Initial evaluation concludes x/? Initial evaluation concludes 0/? Initial evaluation concludes some 0/? Initial evaluation concludes 0/? Initial evaluation concludes biodiversity, flora and significant mitigation would be significant mitigation would be mitigation may be needed. some mitigation may be some mitigation may be fauna needed. needed. needed. needed.
6. Protect and enhance x The site slopes north to south. X The site slopes north to south but 0 The landscape would be protected 0 The landscape would be 0 The landscape would be the landscape The site is naturally grown over could still accommodate all as the site is an existing school site protected as the site is an protected as the site is an (habitats/visual with large open drainage anticipated users. The site is all which is relatively flat. However the existing school site which is existing school site which is amenities running north to south. The site naturally grown over with large sports areas may have to be relatively flat. This would relatively flat. The school is an area prone to flooding and open drainage running north to platformed and levelled by a cut and enable the construction of the playing fields are on the adjacent site to the East south. These runs create areas fill exercise. new build without the need to existing tiers to the North has the same problem. This for specific use on each side. significantly change the West of the site. The site has created natural open The drainage ditches would At risk of flooding from estuary topography of the site. The does slope to the drainage channels over the site require Environmental Agency without defences. However, the site current conceptual plan South/West corner to an running South. Such channels approval to construct or cover in benefits from flood defences. Risk places the new build school existing secondary would require Environment any way. category: Low/medium on the part of the site that the entrance (currently closed) Agency approval to construct or existing Llanrumney High to the school. cover in any way. At risk of flooding from estuary School buildings occupy. without defences. However, the The current conceptual plan At risk of flooding from estuary site benefits from flood defences. At risk of flooding from river places the new build school without defences. However, Risk category: High without defences. Although more centrally than the part the site benefits from flood area with defences along the of the site that the existing defences. Risk category: western boundary of the site. Rumney High School Medium/High Risk category: Medium buildings occupy.
No risk shown. Risk category: Low
7. Conserve water ✔ Achieved by incorporating ✔ Achieved by incorporating water ✔ Achieved by incorporating water ✔ Achieved by incorporating ✔ Achieved by incorporating resources through water efficiency measures into efficiency measures into the efficiency measures into the building water efficiency measures water efficiency measures 0 0 0 0 0 water efficiency the building design and where building design and where design and where feasible into the building design and into the building design and measures in new feasible addressing drainage feasible addressing drainage addressing drainage through where feasible addressing where feasible addressing developments including through Sustainable urban through Sustainable urban Sustainable urban drainage systems drainage through Sustainable drainage through sustainable urban drainage systems (SUDS). drainage systems (SUDS). (SUDS). urban drainage systems Sustainable urban drainage drainage systems (SUDS). systems (SUDS).
8. Promote ✔ Achieved by making schools ✔ Achieved by making schools ✔ Achieved by making schools ✔ Achieved by making schools ✔ Achieved by making regeneration by community focused by opening community focused by opening community focused by opening community focused by schools community focused delivering inclusive facilities to the public i.e. facilities to the public i.e. evening facilities to the public i.e. evening opening facilities to the public by opening facilities to the schools that will evening classes. classes. classes. i.e. evening classes. public i.e. evening classes. improve equality of ✔ ✔ ✔ ✔ ✔ opportunity and access All new builds must be DDA All new builds must be DDA All new builds must be DDA All new builds must be DDA All new builds must be DDA for all accessible. accessible. accessible. accessible. accessible.
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9. P rotect and enhance ? A cultural heritage feature is ? 2 cultural heritage features are 0 There are no known cultural heritage 0 There are no known cultural ? 3 cultural heritage features designated historic recorded on the online sources recorded on the online sources receptors recorded on the online heritage receptors recorded are recorded on the online assets examined. There is likely to be examined. There is likely to be a sources examined within or in close on the online sources sources examined. There a moderate impact on this non moderate impact on these non proximity to the site of the proposed examined within or in close would be a direct impact on designated cultural heritage designated cultural heritage development. proximity to the site of the nationally protected cultural asset by the site. assets by the site. proposed development. heritage assets by the site. There is a potential that remains associated with this feature may extend into the area of proposed development and any future groundworks in the vicinity of the Scheduled monument could disturb below ground deposits associated with the feature.
Conclusion
Observations:
St Mellons and Trowbridge Mawr sites • Environmental Agency approval required to construct or cover natural drainage ditches. • Both sites are categorised as being at high risk of flooding but the sites benefit from flood defences • Both sites are natural habitats. It is likely that significant mitigation measures would needed to be put in place to counteract the loss of habitat and any impact on protected species.
Colleg Glan Afren, Llanrumney High School and Rumney High School sites • These sites are relatively flat and the habitat is currently maintained for the purposes of delivering education • Colleg Glan Afren and Llanrumney High School are at risk of flooding but benefit from flood defences • Rumney High School is not at risk of flooding • Rumney High School - 3 cultural heritage features are recorded for this site on the online sources examined. There is a potential that remains associated with this feature may extend into the area of proposed development and any future ground works in the vicinity of the Scheduled monument could disturb below ground deposits associated with the features.
April 2014 update following consultation on building the new school on the Llanrumney High School site or the CAVC site
The following expands on what was stated in the previous SEA in August 2013 (see comments against Objective 6 above):
All sites that were considered as potential sites for the new build Eastern High were screened for flood risk. Cardiff Council commissioned a Site Feasibility Appraisal Report which advised that the Llanrumney High School site lies in the flood plain of the river Rhymney although it currently benefits from flood defences. However, these defences are considered to be susceptible to breach, so works to reinforce the defences are likely to be required in order to meet TAN 15 requirements. The Site Feasibility Appraisal Report advised that some parts of the CAVC site are susceptible to surface water flooding. However, it is considered that for a new build development, this risk should be manageable through the design of the drainage system and the alignment of the buildings and design of overland flow paths through the site.
Issue Status: 02 Date: 23/08/11 Process Owner: D. Owen Authorisation: R. Jones Page 33 of 33 33