Dear Sir/Madam,

Thank you for the opportunity to comment on the content of the school re-organisation section of the Bill.

As a result of this review, we are proposing to close a specialist provision (a primary unit) that is highly likely, by September 2013, to have a maximum of one pupil on roll. However, as things stand, we have to go through a full consultation exercise that will cost a considerable amount in terms of officer time and money.  It is stated that a change that requires the publication of proposals is “the addition or removal of provision which is recognised by the local education authority as reserved for pupils with SEN”. Would it be possible for the SEN provision regulated alteration requirement to include more detailed specific requirements which would take account of the type of proposed alteration? I appreciate that there will be a need to examine in detail each part of this as any change should not be detrimental to the standard of SEN provision provided.

I note that within the Bill mainstream schools with fewer than 10 pupils on roll can be discontinued without consultation, but the draft Bill is silent on alterations to specialist provision.  Although we realise that the position of specialist provision is not directly comparable with small mainstream schools, I do feel that there are thresholds that could perhaps be set to improve the current procedure so that there is a more proportionate system in place.

In relation to transport issues currently, within mainstream provision proposals, consideration should be given to the welfare of children if the journey to school exceeds 45 minutes for primary pupils and one hour for secondary pupils. It also states that additional consideration should be given to the welfare of pupils with ALN, yet this additional consideration for ALN pupils does not give any guidelines.  Where a mainstream school is subject to closure the pupils will transfer to another school in their locality which will be within a suitable distance. For pupils in specialist placements subject to closure it is accepted that travelling distance may be increased. An agreed distance could be specified to address this issue.

In relation to changes to the designation of provision it would be very useful to have detailed clarification on what is classed as a prescribed change for specialist provision.   For example, what procedure is required to change the designation and subsequently the management arrangements of provision from a unit to a resource base where the pupil population is unchanged.

It is understood that there are many different kinds of specialist provision and there is every likelihood of small numbers within these, but as things stand, there is very little flexibility when there is a need to reorganise such provision. Consideration of the points listed above and at the end of this letter could mean that future proposals for developing provision in response to local needs could be much speedier and a more efficient process.

Further issues for consideration are outlined in the following list

§ If past, current and projected numbers on roll within a specialist provision are very low, with the result that the provision is not viable the local authority/governing bodies may undertake a specified curtailed procedure to bring about official closure which consists solely of the issue of the notice of closure. The requirement for consultation would be waived. Objections could be made and stakeholders could be given an opportunity to make their views known, but the issue would be determined in all cases by the proposer.

§ The above could be further determined through an assessment of the following:

· whether there is surplus SEN provision in the area as a whole;

· if the proposal will improve standards and accommodation for pupils with SEN; and

· whether there is an impact on home to school transport.

Thank you for your consideration of these views.  Please do not hesitate to contact me if you have any queries in relation to the content of this letter.

Regards,

Sylvia Lindoe

Director of Education and Leisure Services

Cath Tetley

PA to Sylvia Lindoe

Director of Education and Leisure Services

Blaenau Gwent County Borough Council

Central Depot

Barleyfields Industrial Estate

Brynmawr

Blaenau Gwent

NP23 4YF

Telephone: (01495) 355337

Fax:  (01495) 355468

E-mail:  education.department@blaenau-gwent.gov.uk

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