The Public Accounts Committee
Inquiry into 21st Century Schools and Education Programme
18 May 2018
1.
The NASUWT welcomes the opportunity to submit views to the Public
Accounts Committee (PAC) Inquiry into 21st Century Schools and
Education Programme.
2.
The NASUWT is the largest teachers’ union in Wales,
representing exclusively teachers and school leaders, and has drawn
on comments and observations made by members to inform this
submission.
GENERAL COMMENTS
3.
The NASUWT maintains that the mechanism by which state schools are
funded, including the provision of school buildings, is critical to
securing a world-class education system and a just and inclusive
society, and that there is a positive correlation between the
quality of school buildings and student attainment. Education
should meet the needs of all children and young people on a fair
and equitable basis, irrespective of where they happen to live or
be educated. The capital funding arrangements should guarantee
learner entitlements, irrespective of the institution at which they
are on roll.
4.
A National Foundation for Educational Research study found that
moving to new buildings improved pupils’ outlooks regarding
experiences of school and expectations for the future.[1]
5.
The NASUWT also asserts that the funding methodology must be clear
and transparent, and must ensure that there is good provision of
places for all pupils.
6.
The Union believes that there should also be a fair, transparent
and appropriate distribution. The mechanisms for distributing
funding to local authorities and schools should be fit for purpose,
taking account of local circumstances and needs and the
expectations on schools. The funding mechanism should promote
public and professional confidence in the system and enable fair
comparisons to be made.
SPECIFIC COMMENTS
7.
The NASUWT comments and observations which follow address the five
main areas the PAC has identified as the focus for this
Inquiry.
Setting Expectations and Targets
8.
The NASUWT notes that the guidance from the 21st Century Schools
and Education Programme Team states that local strategies should
‘Focus on improving outcomes for children’. The
Union notes, however, that one of the main priorities has been to
reduce the number of ‘surplus places’ in the school
system.
9.
The NASUWT has never agreed with this strategy, because the Union
has argued that there is little to gain from the process as schools
are, by and large, funded on a per pupil basis. The strategy
reduces capacity without the full knowledge and understanding of
the future demand.
10.
The NASUWT is very concerned that the number of pupils in Wales has
fallen by only 633 from 467,141 in 2010 to 466,508 in 2017, whereas
the number of full-time equivalent teachers has fallen over the
same period by 1,377 from 25,286.6 to 23,909.8.[2]
11.
The NASUWT is, therefore, pleased to note that the main emphasis in
Band B of the programme is to be changed to focus on the condition
of buildings rather than on surplus places.
12.
However, the NASUWT is alarmed at the nature of the suggestions
contained in the CADE/RIBA document available on the 21st Century
Schools website. The Union would have expected to see the concepts
for the education estate based on sound evidence that supports the
main principle of improving the education of learners, rather than
the experimental and untested concepts that appear to be works of
science fiction contained within the document.
13.
The Union also notes that the 21st Century Schools webpage
‘Transforming the Learning Environment’ states that
there is ‘Increasing interest in the use of larger flexible
project spaces’.[3]
The NASUWT is also aware that many of the projects agreed and built
under Band A were for ‘all-through’ 3-16 or 3-18
provision. In general, the latter were in the circumstance where a
secondary school and a primary school previously either shared a
site or were in close proximity. The NASUWT is not aware of any
evidence to show how these models contribute to the improvement of
outcomes for children and young people.
14.
The Union has received information that recently completed projects
have had mixed reviews from staff, pupils, parents, employees and
members of the local community. Issues have been raised about
quality of fittings and fixtures, with walls easily scuffed, stair
handrails working loose, and poor heating and ventilation. In some
cases, the emphasis on open-plan design has led to complaints of
noise and a lack of privacy and accommodation, particularly
regarding classroom size, connected to increased class size, and
canteen facilities. These complaints reflect the findings of
research that highlight the detrimental impact on learning and
pupil behaviour of poorly designed and organised open-plan learning
environments.[4]
15.
The increasing use of the all-through model appears to have been
perpetuated simply because projects of this type had succeeded in
gaining approval for funding by the Welsh Government. Other local
authorities then appear to have followed this model in order to
gain access to 21st Century Funding rather than considering
carefully the educational merit of their proposals or the impact on
the workforce affected by them.
16.
Indeed, the Union believes that, in many cases, such proposals have
been used cynically as a device to cut revenue costs, reduce the
number of places and secure ‘efficiencies’ by reducing
the number of teachers and support staff.
17.
The NASUWT is dismayed that too many good teachers have lost their
livelihoods as a result of these changes.
18.
The NASUWT is also concerned about the potential impact on primary
school children from feeder primary schools who would have expected
to attend one of the secondary schools involved in the
reorganisation proposals, but find that they are not included in
the transformed provision.
19.
Much has been made about the transition between primary and
secondary schools and this is often cited as a reason for moving to
allthrough provision. However, in the all-through establishments,
the intake at the Foundation Phase at the beginning of primary
education is often far smaller than the intake at the beginning of
secondary education. Other primary pupils enter the school at the
beginning of Key Stage 3. Concerns about this practice have been
raised in some consultations on transformed provision, but there
has been no research into the impact on those pupils joining the
school at this stage, when there are already
primary pupils on the site. Similarly, there are no studies on
whether there is an impact on the pupils that are already part of
the school.
20.
The Union believes that the PAC should make recommendations to the
Welsh Government and the 21st Century Schools Unit that different
forms of education provision should only be agreed if there is
clear evidence to support their use. Pupils should not be used as
guinea pigs or be subject to fads and fashions.
The Funding Model
21.
Whilst the NASUWT acknowledges that the policy of austerity adopted
by the Westminster Government has had a significant effect in
reducing the levels of capital funding available in Wales, the
Union is nevertheless disappointed that this appears to be accepted
by the Welsh Government and used in mitigation over inadequate
provision.
22.
Despite this, the NASUWT welcomes the Welsh Government’s
commitment to improving school estate, which is vital for the life
chances of learners and essential to improve the working conditions
of staff.
23.
The NASUWT believes that the Mutual Investment Model (MIM) is an
improvement on previous Private Finance Initiatives and
public-private partnerships and acknowledges the considerable
effort that the Welsh Government has put in to gain approval for
the scheme from the Office for National Statistics and others. The
Union nevertheless will continue to have concerns regarding revenue
used to provide capital funding. The PAC and the Welsh Government
will be aware that the NASUWT has calculated that the on-average,
per-pupil funding gap between maintained schools in Wales and those
in England stood at £678 for 2015-16 (the last year for which
full figures on expenditure were available). This means that there
is a total shortfall in funding of £306 million going into
school budgets in Wales compared with those in England. The Union
notes that the revenue element of the MIM is proposed to be
£500 million.
The Welsh Government plans to get better value for money by
encouraging more standardised elements to the new builds and by
standardising costs.
24.
The NASUWT believes that there are significant differences between
schools and between communities in different parts of Wales. The
Union, therefore, maintains that a ‘one size fits all’
policy could not be adopted universally and recognises that
education provision should take account of local needs. However,
the NASUWT is clear that this does not mean that elements of
provision cannot be standardised or that economies of scale should
not be pursued wherever possible.
Welsh Government consultation on the programme to date and in
planning for the future roll out
25.
The NASUWT considers that it is most regrettable that the Union has
not been party to any direct consultation by the Welsh Government
or the 21st Century Schools Unit on any aspect of the programme to
transform the school estate. The Welsh Government appears to have
focused on local authorities and the construction industry as its
consultation partners and has ignored other stakeholders. This is
despite the welcome partnership approach developed elsewhere,
particularly around workforce issues through the Workforce
Partnership Council.
26.
The NASUWT was very critical at the time of the introduction of the
School Standards and Organisation (Wales) Act 2013 and the School
Organisation Code (the Code) and continues to be so. The Union
believes that changes that were brought forward at the time were
misconceived and based on a false premise and is alarmed and
dismayed by the total disregard for the needs of the workforce.
27.
The NASUWT maintains that the previous arrangements for making
changes to school reorganisation provided a structure that was
democratic, afforded sufficient time for schools, governing bodies,
local communities and other interested parties to consider
carefully any proposals and to formulate detailed responses, and
allowed sufficient
time for the proper consideration of proposals and objections by
those charged with making decisions.
28.
The NASUWT is aware that there is a mixed picture across Wales
regarding the nature and detail of consultations at a local level.
Some local authorities involve the trade unions at an early stage
with detailed proposals and consideration of views before formal
proposals are made. With others, there is cursory consultation:
only that which is required by the Code, with little or no regard
to the views of staff or the trade unions that represent them.
29.
The process that many local authorities follow when amalgamating or
merging schools is to close the existing schools formally and to
open a new one in their place. This is claimed to be an approach
that ensures that the staff of all schools involved in the process
are given equal and fair consideration when the recruitment process
for the new school is undertaken. In practice, the NASUWT has found
this not to be the case and some staff are left unplaced and
redundant. On several occasions, the Union has had to resort to
industrial action in order to protect the jobs and livelihoods of
its members. There should not be any need to recruit new staff as
the staff already exist in the schools involved. Equally, the Union
will not accept redundancy by way of non-
appointment and believe that the staffing structures of the new
provision should be designed to ensure that all existing staff are
retained.
30.
The NASUWT is most concerned that the recent drivers for
reorganisation are more often centred on management restructuring,
reducing recurrent staffing costs and an ideological assault on
curriculum design and pedagogy by linking the programme to the
uncertainties of the new curriculum stemming from the Donaldson
reforms. The NASUWT believes this to be both short-sighted and
illconceived.
31.
The impact of The Staffing of Maintained Schools (Wales) (Amendment
No. 2) Regulations 2009 and The Staffing of Maintained Schools
(Wales)
(Amendment) Regulations 2014 is that, whilst protecting the
employment
of
headteachers and deputy headteachers, the remaining staff have no
security in employment. The NASUWT finds this to be a wholly
unacceptable, unfair and intolerable situation.
Areas to consider in the next phase of investment
32.
The NASUWT insists that the Welsh Government takes all reasonable
steps in order to manage the risks of the new type of funding in
relation to the MIM.
33.
The Union maintains that, as well as ensuring that the good
collaborative working between Welsh Government and local government
continues, there must be involvement with the trade unions at
national level over the nature and principles of the programme.
34.
In particular, whilst welcoming in part the change of principles
from a focus on reducing surplus places to one of prioritising the
condition of schools, the NASUWT insists that the most pressing
issue in relation to the condition of schools is the safe and
effective removal of asbestos.
35.
The PAC will be aware that public buildings in Wales still contain
millions of tonnes of asbestos. Over 75% of schools contain
asbestos, with up to 90% of schools in certain areas
affected.[5]/[6]
36.
Whilst in general it is accepted that good management of asbestos
reduces the risks, the NASUWT is firmly of the belief that the only
way to ensure the future health of staff and pupils is to remove
all asbestos. Nevertheless, whilst it is undoubtedly the case that
some schools will manage asbestos effectively, the Union is
concerned that there have been numerous serious instances of poor
asbestos management, which indicate inadequate management in too
many schools.
37.
This was demonstrated by a recent Department for Education survey
of schools in England, which found that nearly two fifths of
responding schools containing asbestos were not compliant with
asbestos
regulations, and 4% were sufficiently concerning to require urgent
intervention.7
38.
Given that this was a voluntary survey, and assuming that
non-compliant schools would not have responded, the NASUWT believes
that the true level of non-compliance is likely to be much
higher.
39.
Further, although these figures relate to England, the Union
maintains that it is reasonable to assume similar levels of
non-compliance exist in Wales.
40.
Given the lack of data pertaining to asbestos compliance in Welsh
schools, the NASUWT urges the PAC to press the Welsh Government to
undertake a mandatory asbestos compliance survey of all schools in
Wales.
41.
The NASUWT has long campaigned for the safe and effective removal
of asbestos from school buildings. The Union believes that
successive governments have not paid sufficient attention to the
asbestos problem in schools, preferring short-term policies rather
than embarking on a long-term strategy of asbestos removal.
42.
Whilst understanding that the costs of removal are very high, the
Union has always accepted that this could be a gradual process
aligned to the renovation and/or rebuilding of schools. It should
be noted, however, that the costs of removal can be less than the
costs of long-term management and removes all risk, rather than
simply minimising the risks on a short-term basis.
43.
The NASUWT acknowledges that the health and safety concerns of
asbestos removal are dealt with in guidance from the 21st Century
School Unit, but that this is only in regard to the generality of
the legislation to protect construction staff during renovation or
demolition.8
The guidance neither acknowledges nor recognises the need to
prioritise
7https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/5940
42/Asbestos_management_in_schools_data_collection_report.pdf
8
http://21stcenturyschools.org/guidance/statutoryrequirements/?lang=en
NASUWT
the
protection of the school workforce and children and young people
from the long-term effects of exposure to asbestos.
44.
The Committee on Carcinogenicity recently reported that children
were at a significantly higher risk of contracting asbestos-related
diseases than adults, given their longer lifespan and the long
latency period for these diseases.[7]
45.
The NASUWT therefore insists that Band B of the 21st Century School
building programme prioritises not only schools in poor condition
but also those with significant amounts of Asbestos Containing
Materials in their fabric and construction.
Rex Phillips
National Official for Wales
For further information on this written evidence, contact Rex
Phillips, National Official for Wales.
NASUWT Cymru
Greenwood Close
Cardiff Gate Business Park
Cardiff
CF23 8RD 029 2054 6080 www.nasuwt.org.uk nasuwt@mail.nasuwt.org.uk