Response to :
Safeguarding our rural schools and improving school consultation procedures – proposals for changes to legislation

The Scottish Parent Teacher Council welcomes the chance to respond to this consultation as we have a large number of rural schools members and are frequently asked by them for help and advice.   Moreover, school closure is always a stressful business, whether in a rural or urban area, and it is important that people have time to consider the issues and have a clear understanding of the consultation process.    

Before finalising our response, we sent information to all our members and invited them to comment on a draft version of the response that was on our website.   We also listened to an informed presentation by the Scottish Rural Schools Network.  This response takes account of input from both sources.

Please note: in the following response we include the social experience with the educational provision.  For all children, links with their peers are a very important aspect of their learning and development.  Children who do not learn how to socialise at school often find it hard to socialise successfully later in life.  Children themselves can be aware of this need for social development.   For example, senior pupils in Islay have suggested that exchange visits with an urban school would help them learn what it is like to live in a town before they go away to college/university.

Q1: Do you support the proposal to require local authorities to have regard to certain matters before they can proceed to consultation on the closure of a rural school?
We are concerned that, in the Government’s proposals, schools and children’s education appear to take second place to considerations of community survival.   Children are not always best served by keeping a small school open.  

Q2: Do you agree with the four matters we propose requiring that authorities should have regard to before proposing a rural school closure

• Alternatives to the closure of the school
  For all proposed closures – rural and urban – alternatives to closure should be considered.   We are aware that rural schools are often also the site of pre-school provisions and lunch clubs for pensioners.   However, the most important consideration should always be what alternative provision will there be for the children, if the school is closed, and whether this will, in some way, be better. 
  ,
• Likely overall impact of the school’s closure on the communities which it serves   and
• Likely impact of closure specifically on the community’s subsequent use of the school’s building facilities and grounds. 
  This consultation seems to make community viability a priority over good educational provision for children.   It starts from the presumption that the case for keeping rural schools open is different and more compelling than the case for keeping open urban schools which similarly find themselves the object of rationalisation/closure plans because a rural school is an essential dimension to the life of its community.   The consultation document paints a picture of rural communities actively using local schools as community/sports/leisure centres.    This may be true in some areas, but it is far from the truth in other areas.   Many small rural schools that might find themselves being considered for closure are in small, inadequate buildings, often with no indoor hall and with remarkably little outdoor space, let alone facilities.   Moreover, the school can be firmly shut outwith school hours (due to lack of janitorial support) and not even open in the school holidays for children’s activities.    The local shop/post office and community hall are often far more important to village life than the school.   Everyone meets in the shop and a community hall can host any number of community activities from community council meetings to regular ceilidhs.   It is wrong to romanticise and overstate the role that a school plays in community life. 
  
  The document also implies that closing rural schools would have a very negative impact on the viability of the Gaelic language.   Gaelic medium schools are all known and only a tiny proportion of the 1,000 schools, defined as rural by the document, are Gaelic medium schools.    It is not clear that the closure of a non-Gaelic medium rural school would have any impact on the viability of the Gaelic language.  Again, it is important not to overstate the case. 
  
• Likely impact that new travel to school patterns and arrangements would have on pupils and other school users and the environment
  We agree that it is essential to weigh up the benefits in terms of children’s educational/social experience with changes in travel patterns that will be required if a school is closed.   Where a school is very remote and children’s educational/ social experience is limited but the distance to the next school is considerable, then there can be no alternative but to keep the small school open.
  However, where the improved opportunities for the children are considerable but the travel distance to a new school is moderate, it is important to focus on the benefits to the children.   We recently learnt of two small schools in two rural communities that were close to each other.  The children from the two villages went to the same playgroup, the same pre-school and the same secondary school but were split up to go to the two primary schools.  This disrupted friendship patterns and parents wanted a single primary school for the two villages.  The “presumption against closure” policy operated by the local authority meant that this was not an option they were being offered.
  
  In terms of the environment, then account of existing parental choice needs to be considered.  If parents are already opting out to go to other schools, they will be taking their children by car, whereas if the children are re-zoned, the authority will have to provide the transport, assuming the distance is great enough.
  
  If environmental impact is a consideration, then the impact of heating the school that is being considered for closure has to be weighed against the impact of providing school transport, particularly if such transport can be made available to the community and so improve travel arrangement opportunities/a bus service for others in the area.
  
  Whilst many rural schools do an outstanding job, there are some that let their pupils down and many of the phone calls that we receive are to do with problems that can arise as a result. 
  1) For example, whilst composite classes of themselves do not have an adverse effect on a youngster’s education, a youngster can have a very poor educational experience if he/she has a teacher with whom he/she does not relate well but then has to have for three or four years.  
  2) Similarly, we are aware of situations where the gender imbalance is so great that it causes problems for those in the minority group.  We were recently told of parents driving around different rural schools to find one where a child of the same gender as theirs was in the same year group.  
  3) There are also situations where there are so many children from one extended family (siblings and cousins) that life is very difficult for children who do not belong to that family and situations where an outsider who does not conform to the local culture/ethos finds it very hard to fit in.
  4) All small schools, whether urban or rural, also find it harder to get adequate resources, partly because their budgets are too small to allow them to set money aside for exceptional purchases.

Q3: Do you agree that it is not appropriate to set up a rural schools fund?
We understand from the Scottish Rural Schools Network that Grant Aided Expenditure currently provides Local Authorities with specific extra funding for each school in their area that has less than 70 pupils and that an appropriate portion of this money is lost whenever a small school is closed or amalgamated with another such that the pupil numbers at the newly combined school are more than 70.  If it is Government policy to keep open rural schools that might otherwise be closed, the Government should be willing to provide/continue to provide funds to support such schools and ensure that other schools within the same authority do not have their funding reduced in order to provide money to keep the small school open.    Also, there should be money provided to ensure that youngsters at rural schools have an educational experience that matches the experience of children in more urban areas.  Parents in rural schools fundraise in order to pay for transport to activities that urban children take for granted.   For example we heard of one rural school where the parents paid for transport to take the children to the local town so that they could learn to cross roads safely.   Similarly, parents in rural areas regularly fundraise to take the children to swimming classes and other sports activities because local facilities simply do not exist.

Q4: Do you agree with the proposed definition of “rural schools”?
It is not clear what is meant by definition of “Accessible Rural - “Settlements of 3,000 people and within 30 minutes drive (our italics) of a settlement of 10,000 or more”.    This could mean essentially suburban areas/or dormitory villages that are only slightly separated from larger communities/are actually very close.   We would not accept this as “rural”.    We note that there is currently a review of rural communities and that, in some cases, two separate communities that are growing together or only minimally separated, are being re-defined as a single, larger community.   This type of adjustment and the proximity of other small rural communities should be considered with regards to rural schools.

The definitions for “Remote Rural” and “Very Remote Rural” are clearly fine.

In summary, we recognise that closing small rural schools is a sensitive matter that should not be undertaken lightly and should only be done on a case-by-case basis after careful consideration of the particular circumstances.  However, we do think that it is important to prioritise considerations of the educational provision for the children.  We are concerned that a presumption against closure will actually paralyse rural schooling and mean that existing schools will be kept regardless of the educational needs of pupils.   We note that only three schools a year have been closed in England since the presumption against closure was introduced.   This is the equivalent of less than one school every three years in Scotland.  

Reference is made to authorities “mothballing” schools when the school roll falls to zero.   This process is free of any dispute and it does allow the authority to re-open a school relatively easily if a family moves into the area.   It is the nature of rural school populations that as generations grow up move from primary to secondary and then perhaps become parents themselves, the demand for school places varies considerably.    Perhaps where there are two relatively close schools, it might be possible to consider mothballing one or other when the pupil numbers fall to single figures in either.

Q5: Do you support requiring local authorities to publish a statement setting out the educational benefit of the school closure proposal?
We are glad that this section of the consultation applies to proposed urban school closures as well as to rural school closures.   We also think that it is helpful to review and streamline the existing legislation and guidance on school closures that has been developed over time.

Q6: Do you agree that it should be left to the authority as to how it sets out an education benefit statement?
Yes; the authority is best placed to understand the particular circumstances affecting schools within their area and so are best able to write an education benefit statement that relates to the local situation.   For example, the school on Kerrera was closed when it had only one pupil.   The school could be seen as an island school, dependent on a ferry for links with the mainland.   In fact, Kerrera is situated in Oban bay and the ferry journey is short and rarely disrupted by bad weather.  It was surely better for the youngster to have school friends than be educated in isolation.   It is not possible to legislate meaningfully for every particular situation from the centre.

Q7: Do you agree that HMIe’s views should be sought in all cases?
Any advice should be totally independent and objective.  In many respects HMIe’s role is to ensure that Government policy is being implemented.   If Government’s stated policy is (as it is) a presumption against the closure of rural schools, it is hard to see how HMIe could ever come to a conclusion other than that a rural school should be kept open.   Recently there have been incidents where it would seem there was a strong educational case for closure and yet the school has been kept open.   The concern must surely be that with HMIe there to implement the Government’s presumption against closure policy, no authority will put forward any plans for closure even when these might clearly be in the educational/social interests of the pupils.

Q8: Do you support the proposed changes to the way consultations should be conducted?  These are:

• Introducing a requirement that a consultation paper should be published containing certain information;
  We note that consultation papers, whilst not required, are the normal practice and we support this being made a requirement.  However, we are concerned that, even in advance of any conclusion to this consultation, the Government requires authorities in rural areas to include a statement on how they have “had regard” to the four matters specified in Section 3.   We feel that the previous bullet point “setting out all the factors, educational, environmental and other, which the Council considers relevant to the proposal(s)” is general enough to cover such considerations.
• Establishing a mechanism for addressing allegations of factual inaccuracies in a consultation paper;
  Yes.
• Extending the list of people who must be consulted;
  It is clearly good that as many people as possible have the opportunity to comment and that includes those who, whilst not directly involved in the school closure, will benefit/lose from the proposed rationalisation process.   However, as in all areas of discussion, it should be recognised that in general people do not like change and some respondents will have a particular emotional involvement with the school which may make it difficult for them to make an objective judgement.   Long term educational planning does occasionally require hard decisions which folk agree afterwards were right, but which they opposed strongly at the time.  That is certainly the experience of a number of successful closures/rationalisations in the past, most notably the joint campuses that North Lanarkshire has developed.
• Updating the way the consultations are published;
  The most effective way of informing people of intended changes is via the school and then through word of mouth.   However, it is important that as many methods of communication as possible are used to ensure that no one is left out.
• Updating how people can respond to a consultation;
  We again support the requirement for a public meeting and the proposal that people will be able to respond electronically.   However, there should still be some mechanism to ensure that responses are coming from different people and it is not a matter of a small group responding over and over again by email.
• Extending the minimum consultation period to 6 weeks of term time;
  We strongly support this proposal.  
• Introducing a requirement that the authority publish a “Consultation Report” 28 days before the final decision is taken;
  We support this proposal.

Q9: Do you agree that Ministers should take power to issue statutory guidance to which authorities would have to have regard?
Statutory guidance offers a degree of clarity – everyone understands what is required; the disadvantage is that, if the statutory guidance is seen as having inherent problems, it is hard to change.   It is necessary to find parliamentary time, which is not always easy.   The benefits and disadvantages of using the statutory route must be carefully considered and the options of making changes built in to any statutory guidance.

Q10: Are you content with the present system of referrals of closure cases to Ministers?   and
Q11: If not, what changes would you wish to see made, and why?
We can confirm that there is confusion over the role of Ministers in cases of school closure that are referred to them; we are interested to learn that Ministers restrict themselves to considering whether due process has been followed and do not re-take the Council’s decision.  Certainly, this has not been clear from observing previous ministerial review of decisions.

If Ministers’ role is clearly and openly about ensuring that due process has been followed and is in no way about over-riding the Council’s decision, then there may still be scope for ministerial review in certain cases.   However, in the spirit of openness Ministers should, in their response to the referral, spell out exactly how the authority has failed to follow due process as laid down in legislation.

Q12: Do you agree with the proposal to place the responsibility on authorities to satisfy themselves regarding the provision of denominational education?   If so, do you agree with the proposal to continue to allow referral to Ministers if the Church or denominational body has an objection?
There must be scope for authorities to adjust the proportion of denominational places if there is a decline/increase in the number seeking denominational provision in the authority.   The ratios of denominational to non-denominational places cannot be locked forever.  

Q13: Do you agree with our proposal that in future only schools closure cases should be referable to Ministers.
We do not accept the double standards laid out in paragraph 89 that “closure cases tend to involve a wider complexity and dimension of issues beyond the essentially local and largely educational ones which are the principal focus of changes of site and catchment area proposals”.   And in paragraph 90 “While there may be local controversy around changes….the educational benefits of the change…are usually clear”.

Conclusion
We would argue that school closure should always be for the educational/social benefit of the children and should be done on an individual case-by case basis after careful consideration of the specific circumstances.   We think the important consideration in looking at any school is whether it is meeting the educational needs of the pupils and whether plans for closure or merger would enhance educational provision.   Decisions for closure or merger should not be based on financial considerations but financial considerations are relevant.  Whilst the running costs per child of a small school may be relatively high, the total running cost of a small school is itself relatively small and the financial benefits of closure to the authority’s education budget will be minimal once the cost of alternative provision and transport are taken into account.   However, the state of the school buildings is often a more significant factor in an authority’s financial considerations because an inadequate or dilapidated building can cost millions to repair or replace and it is legitimate to consider whether this is the best use of money.

Moreover, it is important for authorities to review their school estate periodically and decide whether the schools are in the best locations for the pupil population.  Plans for merger/closure can be prompted by a nearby housing development/community which means that more children have to travel to the existing school than would travel to a new school built in that newly developed area.  Indeed, it is critical that local authorities review their school estates within the context of their current/future strategic plans with particular reference to proposed housing, business and transport developments.  One respondent told us of a situation where a new housing estate, comprising 300 houses, had been developed but the local school was so overcrowded children were being taught in corridors.    One reason for the over-crowding was that the school had recently had to accommodate children from a nearby rural school that had been closed.   At present, we understand, local authorities only look at housing that currently exists, not at housing that is planned for the future.  This does not make sense.

Scottish Parent Teacher Council
August 2008

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