Chapter 10: Detailed comments on the 2010 Act
149. Roll projections have a clear and important purpose in understanding the future need for a particular school. Nevertheless, they are often a highly contested aspect of closure proposals and this is in part due to the difficulty of accurately projecting numbers of children in a small community more than a very few years ahead. Other factors include uncertainty over future development and unmet housing need in the area, and significant levels of placing requests both into and out of small schools.
150. Particular difficulties arise where only one source of information is used for projections or local knowledge is not taken into account. From the evidence the Commission has heard, best practice in roll projections would include regular and transparent reviews of roll projections for all schools, informed by community knowledge and experience, as well as using other relevant data from a range of sources.
Achahoish Primary School (Argyll and Bute)
Highland Council draws on a wide range of information to produce school roll projections. Projections are based on NHS records of pre-school children and the latest pupil census but also take into account other factors which have an impact on pupil numbers including: placing requests, house building, and population modelling. Area and regional education officers are actively involved in the forecasting process. The local authority considers its roll projections to be valid up to ten years into the future and they are available to the public on the Highland Council website.
Potential issues highlighted by roll projections, such as over capacity or significantly falling rolls, are discussed further at a local level and projections may be revised based on information received during these discussions. In order to improve accuracy, Highland Council reviews roll projections against actual rolls once available and discusses significant variances with area education managers. This can identify reasons for variances and provides an opportunity to refine the methodology for the projections if necessary.
151. The Commission found that placing requests were a particularly difficult aspect of roll projections and it would be helpful for the numbers of placing requests both in and out of the area to be clearly shown in regular analysis of rolls. This will help understand where and why particular trends are emerging. It may be an issue of perceived quality; concern at (or desire for) a low roll; additional support for learning; or the needs of childcare or employment, all of which deserve attention from the education authority in judging how best to maintain schooling in the area.
152. The Commission heard various views in relation to the timescales prescribed in the 2010 Act for consultation, and while there were some concerns from local authorities that the process was too time consuming, these were more than balanced by parents' and communities' desire that school closures be given proper consideration and not rushed. There was some support for longer time periods, but valid concerns that prolonged uncertainty around a school closure was unhelpful and almost as damaging as a closure decision. On balance, the Commission recommends no change to the consultation timescales set down in the 2010 Act. It would be helpful if a simple timeline showing all the stages of the closure proposal was provided to assist authorities and communities.
153. Finally, parents had a strong and reasonable view that school closures should be made at natural breaks in the education year, with a strong preference for this being at the end of the summer term. It is in pupils' best interests to have at least a term's notice of their future school and for the community to have the opportunity to mark the school's closure in an appropriate manner.
There should be no change to the consultation timescales set down in the 2010 Act. The Scottish Government should provide a clear timeline for closure consultations to assist authorities and communities.
The definition of a rural school
154. Much of the 2010 Act focuses on rural schools, as does the Commission's remit, and section 14 of the 2010 Act contains the key provision which designates a school as "rural" or not. It prescribes that Scottish Ministers should maintain a list of rural schools for the purpose of the 2010 Act. Scottish Ministers chose to devise this list using the Scottish Government Urban Rural Classification, and define a rural school as one in any of the three categories of "rural" in this 8-fold classification. This means that schools in settlements of less than 3,000 people are classified as rural, including 41% of Scotland's primary schools and 23% of Scotland's secondary schools.
155. The Commission considered evidence that there are a number of difficulties with the current definition. From local authorities' perspective, the number of schools classified as rural and with a presumption against closure is very high, including not just those schools in remote or fragile communities but the majority of schools in some rural authorities. This was reflected in communities' surprise that schools in relatively large rural centres were designated in the same way as very remote ones, and the terms of the definition were found to be relatively clunky and hard to relate to. Nevertheless, it was acknowledged that an objective methodology was required and few alternatives were offered.
156. A more specific concern with the designation of rural schools relates to its dependence on postcode classification according to population density, leading to occasional anomalous classifications where a school is on the outskirts of a settlement, or a settlement has expanded since the postcode classification was revised. In these cases it seems perverse that the rural school legislation applies to a school that is to all intents and purposes an urban one and is not significantly different to its urban neighbours.
157. The Commission gave careful consideration to using a narrower definition of rural school, which might specifically designate those schools which serve remote rural communities and are a significant distance from their neighbours. While that option has some merit, the Commission concluded that until other aspects of the 2010 Act were working, it would be premature to amend the definition. The Commission was particularly persuaded by a view that rather than placing an additional and inappropriate burden for those schools which are classified as "Accessible Rural", the consideration required for rural schools was close to the best practice which an education authority should aspire to for any significant changes to its school estate, rural or urban. The level of consideration should naturally reflect the degree of rurality given that proposals concerning more remote schools should give rise to more substantive concerns through application of the matters of "special regard", e.g. regarding community impact and different travelling arrangements.
158. Notwithstanding this, the Commission would recommend that Scottish Ministers review their current list of rural schools in conjunction with local authorities to address the anomalies identified.
The current definition of a rural school should not be altered. The Scottish Government should carry out a narrow and restricted review in conjunction with local authorities to address any anomalies that arise from the current definition.
159. The term 'mothballing' is used, according to Scottish Government guidance, to refer to a temporary decision to close a school where the roll has fallen to zero. It recognises the permanent impact on a community of closing the school and seeks to avoid that final decision until there is sustained evidence of no demand. It can be an appropriate and positive step where there is some prospect of revival in a community. Mothballing might be expected to be a much more frequent occurrence for early years provision which by its nature serves smaller numbers than a primary school, and serves very young children for whom travel is more onerous and a personal burden to their family.
160. The guidance assumes that mothballing would only be considered when the roll has fallen to zero. However, in practice, mothballing is also taking place when the roll is very low and the local authority considers the school (or early years provision) not to be viable for such low numbers on grounds of cost; or where either the local authority or parents consider the low numbers to not be in the educational interests of the children. Given that mothballing in these circumstances is a less permanent step than closure and responds to very low roll projections in a way that is reversible, it might be a welcome option for communities. The difficulty is that there is no legal process for mothballing - compared to the detailed requirements relating to closure - and an extension of its use without any safeguards could amount to permitting school closure by the backdoor. Where communities and parents disagree with the course of action, they will also be concerned that temporary closure is likely to undermine future demand. For example, where pre-school provision at a school is mothballed while low demand still exists, it may reduce the likelihood that those children return to their catchment primary school, and mothballing would be likely to reduce awareness and support for a school.
Mothballing, rather than closing a school, gives the opportunity for it to re-open it should circumstances change. Highland Council successfully mothballed very remote rural primary school in 2002 and reopened it in 2005. When the roll of the school fell to one pupil the community were consulted on mothballing of the school, and the subsequent agreement to mothball it meant that the community was almost 25 miles away from the nearest primary school.
Three years later the community approached the local authority to ask it to reassess the school's mothballed status because of an increase in the number of school age children in the area. Following discussion, Highland Council reopened the school with a roll of three pupils in the primary school and two in the nursery. It remains open to this day.
The increase in children is a result of increased employment opportunity at the local estate which is the only employer in the area.
161. The Commission suggests that the Scottish Government provides more guidance on mothballing and the safeguards necessary to ensure that any greater use of this approach is appropriate and in keeping with the presumption against closure.
The Scottish Government should provide more guidance on mothballing schools, including the safeguards necessary to ensure that any greater use of this approach is appropriate and in keeping with the presumption against closure.