Black Country Core Strategy Issue and Option Report

Consultation under Regulation 18 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1. Thank you for seeking the Education and Skills Funding Agency's (ESFA) views on the above document; we welcome the opportunity to contribute to the development of planning policy at the local level.

2. The Education and Skills Funding Agency (ESFA), launched on 1st April 2017, brings together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA), to create a single funding agency accountable for funding education and training for children, young people and adults. The ESFA are accountable for £61 billion of funding a year for the education and training sector, including support for all state-provided education for 8 million children aged 3 to 16, and 1.6 million young people aged 16 to 19.

3. The ESFA aims to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. As such, we would like to offer the following comments in response to the proposals outlined in the above consultation document.

General Comments on the Black Country Core Strategy Issues and Options Approach to New Schools

4. The ESFA notes that significant growth in housing stock is expected within the Black Country Core Strategy area; the Issues and Options Core Strategy (2017) confirms an Objectively Assessed Housing Need for the Black Country of 78,190 homes (para 3.13) to the end of the plan period in 2036. This will place significant pressure on social infrastructure such as education facilities.

5. The ESFA welcomes reference within the plan to support the development of appropriate social and community infrastructure, as indicated within paragraphs 5.7 and 5.8 of the document, which recognise the additional pressures that will be created by new housing. You will have no doubt taken account of key national policies relating to the provision of new school places but it would be helpful if they were explicitly referenced within the document. In particular:

- The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 72).

- The ESFA supports the principle of the Black Country safeguarding land for the provision of new schools to meet government planning policy objectives as set out in paragraph 72 of the NPPF. When new schools are developed, local authorities should also seek to safeguard land for any future expansion of new schools where demand indicates this might be necessary.- The Black Country should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on 'Planning for Schools Development'1 (2011) which sets out the Government's commitment to support the development of state-funded schools and their delivery through the planning system.

6. In light of the above, the ESFA encourages close working with local authorities during all stages of planning policy development to help guide the development of new school infrastructure and to meet the predicted demand for primary and secondary school places. We note that the four local authorities covered by the Black Country Core Strategy have published statements of community involvement. In line with the Duty to Cooperate, please add the ESFA to your list of relevant organisations with which you engage in preparation of the plan.

7. In this respect, the ESFA commends, for example, the approach taken by the London Borough of Ealing in producing a Planning for Schools Development Plan Document (DPD)2. The DPD provides policy direction and establishes the Council's approach to providing primary and secondary school places and helps to identify sites which may be suitable for providing them (including, where necessary and justified, on Green Belt/MOL), whether by extension to existing schools or on new sites. The DPD includes site allocations as well as policies to safeguard the sites and assist implementation and was adopted in May 2016 as part of the Local Plan. The DPD may provide useful guidance with respect to securing site allocations for schools in the emerging Black Country Core Strategy as well as providing example policies to aid delivery through Development Management policies. You may also be interested in Barnsley's Education Sites Development Plan Document, produced by Barnsley Metropolitan Borough Council, which seeks to provide a framework for the development of education sites within the borough. These DPDs may provide useful guidance with respect to securing site allocations for schools in the emerging Black Country Local Plan as well as providing example policies to aid delivery through Development Management policies.

8. Ensuring there is an adequate supply of sites for schools is essential and will ensure that the Black Country can swiftly and flexibly respond to the existing and future need for school places to meet the needs of the local planning authorities over the plan period.

9. While it is important to provide clarity and certainty to developers, retaining a degree of flexibility about site-specific requirements for schools is also necessary
1 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6316/1966097.pdf
2 https://www.ealing.gov.uk/info/201164/local_plans/1961/planning_for_schools_dpd

given that the need for school places can vary over time due to the many variables affecting it. The EFSA therefore recommend the Council consider highlighting in the next version of the Local Plan that:

- specific requirements for developer contributions to enlargements to existing schools and the provision of new schools for any particular site will be confirmed at application stage to ensure the latest data on identified need informs delivery; and that
- requirements to deliver schools on some sites could change in future if it were demonstrated and agreed that the site had become surplus to requirements, and is therefore no longer required for school use.

10. The ESFA would like to be included as early as possible in discussions on potential site allocations, as there are pipeline school projects in the Black Country that may be appropriate for specific designation. We would welcome the opportunity to meet with the council in the near future to discuss these projects.
Forward Funding

11. In light of the chapter Funding for Site Development and Infrastructure (page 54), emerging ESFA proposals for forward funding schools as part of large residential developments may be of interest to the Council. We would be happy to meet to discuss this opportunity at an appropriate time.

Core Strategy Issues and Options

12. The ESFA note that paragraph 5.6 of the Local Plan (Issues and Options) is considering the scope available for releasing land for Sustainable Urban Extensions (SEUs). We would request that as part of this exercise, work be undertaken to identify sites that can be safeguarded for the provision of new schools/school extensions where the proposed SEUs are likely to generate significant additional demand.

13. In terms of the Spatial Options (pages 42-43) proposed within the document, the ESFA does not favour a particular option, however, the preferred option will need to be supported by sufficient social infrastructure, in particular primary and secondary schools, to meet the demand generated by the new homes.
14. In respect of proposed Policy HOU5 Education and Health Care Facilities, the ESFA would welcome the proposed expansion of this policy to include standards aimed at ensuring new communities are well served by education facilities.
Developer Contributions and CIL

15. There is a need to ensure that education contributions made by developers are sufficient to cover the increase in demand for school places that are likely to be generated by major developments. The ESFA note that Dudley and Sandwell Councils have adopted CIL Charging Schedules, but that Wolverhampton and Walsall councils are yet to implement CIL. The ESFA support the Dudley and Sanwell's approach to ensuring developer contributions address the impacts arising from growth.
16. The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements, which will inform any CIL review and/or amendments to the Regulation 123 list. As such, please add the ESFA to the database for future CIL consultations.

Conclusion

17. Finally, I hope the above comments are helpful in shaping the Black Country Core Strategy, with particular regard to the provision of land for new schools. Please advise the ESFA of any proposed changes to the emerging Local Plan policies, supporting text, site allocations and/or evidence base arising from these comments.

18. Please do not hesitate to contact me if you have any queries regarding this response. The ESFA looks forward to continuing to work with the local authorities of the Black Country to aid in the preparation of a sound Local Plan.