Pembrokeshire Schools

Regulated Alteration to increase the number of pupils for whom the school makes provision - Portfield School

Consultation Report

July 2022

Foreword

Pembrokeshire County Council is responsible for promoting high educational standards and for delivering efficient primary and secondary education. Having the right schools in the right places and ensuring that they are fit for the 21st century learner is a challenge facing councils across Wales.

Meeting this challenge involves reviewing the number and type of school the Council has in its area and assessing whether or not best use is being made of its resources and facilities.
The Council reviews its provision on the basis of:

  • Quality and future sustainability of educational provision
  • Sufficiency and accessibility of school places
  • The condition, suitability and standard of school buildings
  • Value for money

This Consultation Report sets out the findings of the statutory consultation undertaken with regard to the proposal to increase the number of pupils for whom Portfield School makes provision. All responses received during the consultation period are recorded, together with a summary of each of the issues raised by consultees. These are accompanied by a clarification or rejection (as appropriate) of any concerns.
Pembrokeshire County Council will consider this Consultation Report at its meeting on 14th July 2022.

Steven Richards-Downes

Director of Education

Introduction

Distribution of consultation report

Consultation Arrangements

Consultation Correspondence

Consultation Responses

Appendix one

Appendix two

Introduction

Pembrokeshire County Council has a statutory duty to secure sufficient and suitable school places in its area and to determine whether it is making the best use of the resources and facilities to deliver the opportunities that children deserve.

At its meeting on 14th October 2021, Pembrokeshire County Council considered a report which outlined a proposal to proceed with a re-development of the Portfield School campus as part of the Council’s 21st Century Schools Programme; consequently this would result in an increase in the number of pupils for whom the school makes provision. The decision of Council was as follows:

The subsequent statutory consultation was undertaken during the period 15th March to 29th April 2022.

This document represents the County Council’s responsibility as part of the School Standards and Organisation (Wales) Act 2013 to publish a consultation document. This document:

  • Summarises each of the issues raised by consultees;
  • Responds to these issues by means of clarification or rejection of the concerns with supporting reasons, and
  • Sets out Estyn’s view of the overall merits of the proposal.

That the Director for Education be authorised to undertake statutory consultation on a regulated alteration to Portfield School in order to increase the number of pupils for whom the school makes provision

Distribution of consultation report

This Consultation Report will be distributed to the following:

The Governing Bodies, Parents/Carers/Guardians and Staff of:
  • Portfield School
  • Ysgol y Preseli
  • Tenby VC School
  • Pembroke Dock Community School
  • Monkton Priory Community School
  • Ysgol Harri Tudur / Henry Tudor School
  • Gelliswick VC School
  • Johnston CP School
  • Fenton CP School
  • Waldo Williams CP School
  • Ysgol Glannau Gwaun
  • Ysgol Bro Gwaun
The following elected members:
  • Paul Davies MS – Constituency
  • Samuel Kurtz MS - Constituency
  • Cefin Campbell MS – Regional
  • Joyce Watson MS – Regional
  • Eluned Morgan MS – Regional
  • Jane Dodds MS - Regional
  • Stephen Crabb MP
  • Simon Hart MP
  • Cllr. Tim Evans
  • Cllr. Anji Tinley
  • Cllr. David Bryan
  • Cllr. Tom Tudor
  • Cllr. John Cole
  • Cllr. Andrew Edwards
Diocesan Directors of Education:
  •  St David’s
  • Menevia
Others
  • Haverfordwest Town Council
  • Merlin’s Bridge Community Council
  • NEU
  • NASUWT
  • UCAC
  • ATL
  • NAHT
  • ASCLE
  • UNISON
  • UNITE
  • GMB
  • Hywel Dda Health Board
  • SNAP Cymru
  • National Autistic Society
  • Dyfed Powys Police and Crime Commissioner
  • The Welsh Ministers
  • Estyn
  • The Welsh Language Commissioner
  • Partneriaeth Addysg De Orllewin Cymru - Regional Education Consortium
  • Pembrokeshire College
  • Carmarthenshire County Council
  • Ceredigion County Council

In addition, this report will be distributed to all consultees who have specifically requested to be advised of its availability.

Consultation Arrangements

General Arrangements

The Consultation Document was published on 15th March 2022 and this date also represented the beginning of the statutory consultation period. The consultation period ended 29th April 2022,

The Consultation Document was distributed / links sent to all statutory consultees listed on Page 5 of that document.

The Consultation Document was made available on the County Council’s website at Have your say 


Consultation Correspondence

Volume and Profile of Responses Received

A total of 15 responses were received via the online web link, general and 'pupil-friendly' response forms, emails and letters. The breakdown is as follows:

The profile of respondents is given below and reflects all descriptions given. This profile indicates respondents’ role as part of the consultation and may indicate multiple roles, e.g. parent, staff and local resident; as a result the total does not equal the total number of responses received.

Profile
Number
 Pre-school parent  0
 Parents  9
 Staff  2
 Governors  2
 Residents  4
 Portfield school  3

Consultation Responses

General Consensus

Where respondents chose to utilise the online or hard-copy form provided, they were asked to respond to a single question in order to establish which of the following statements best reflected their views. The findings are as follows:

Please indicate which of the following reflects your views on the proposal:

To make a regulated alteration to Portfield School in order to increase the number of pupils for whom the school makes provision

Statement
Number
%
I do not feel strongly one way or the other 0 0
I support the proposal 14 93
I do not support the proposal 1 7
Total 15 100
Comments made during consultation

A list of all comments received during the consultation period is attached as appendices; Appendix A1 for general comments, Appendix A2 for Estyn comments. In relation to the latter, Estyn’s overall conclusion of the proposal is as follows:

“The proposal is by Pembrokeshire County Council to make a regulated alteration to Portfield School to increase the number of pupils for whom the school makes provision.
Estyn considers that the proposal is likely to at least maintain the standard of education provision and outcomes for pupils”

Response to comments / observations made

The School Organisation Code requires that the consultation report provides a summary of each of the issues raised by consultees and that these are responded to by means of clarification, amendment to the proposal or rejection of the concerns. The following table outlines the Council’s response to the various comments made.

Comments/observations

Estyn
In considering the impact of the proposal on travel arrangements, the council refers to its school transport policy in relation to learners with additional learning needs and disabilities. It reasonably concludes that the proposal will not impact on transport provision, other than accommodating additional learners. The proposal does not address the additional travelling time that pupils from outside the normal school catchment may have.

Response

As outlined in the Consultation Document, Portfield School is the county’s only designated Special School. The proposal is not one to re-locate the current provision, merely one to expand the provision and to redevelop the Portfield School site. As the only Special School in Pembrokeshire, its ‘catchment’ is the whole of Pembrokeshire and the proposal will not result in additional travelling time, beyond what can be expected currently.

Comments/observations

Estyn
The council refer the high number of specialist professionals required to work within a specialist provision. However, no detail is provided on the recruitment of additional staffing required as a result of increasing capacity. The proposal would be further strengthened by more information relating to the specialist staffing of the increased capacity school.

Response

Class sizes generally in Special school range from between 8-15 learners within a class, depending on the type and complexity of need.
Welsh Office Circular 58/90 recommend the following Bands and staffing ratio’s.
PMLD (Teacher 1:5) (LSA 1:3)
Communication (1:6) (1:10)
BESD (1:7) (1:7)
SLD (1:8) (1:8)
MLD (1:10) (1:10)
Classes are usually supported by one qualified teacher and 2-3 classroom assistants, although this number can increase with some children often requiring ratio’s of 2:1 support.
Teachers in special school are generally paid UP3 plus an additional SEN allowance
Increassing the current provision by an additional four classes is likely to add approximately 10 non teaching staff and four full time teachers.
The additional capacity will also have an impact on ancillary and specialist health services, such as physio therapy, occupational thrapists and speech and language.

Comments/observations

Estyn
The council has suitably considered the likely impact of building on a ‘live education site and has stated that this will be managed in line with established project planning principles. However, there is no consideration on the impact of the building process on learners with additional learning needs who may be sensitive to noise, smells or change. The council has stated that young people will be able to participate in this consultation and as a result, this may be an opportunity to prepare the learners for any changes which may take place.

Response

It is recognised that a redevelopment of Portfield School presents additional challenges to those which might be expected at other mainstream schools. The Headteacher / school SLT will be valuable members of the Project Team and will be involved in all aspects of the project. It is anticipated that the Headteacher will appropriately involve learners in this process and consultants and contractors will be required to respond to any concerns raised.

Comments/observations

General
Whether Portfield can make use of the Haverfordwest High VC site once vacated

Response

The proposal will capitalise on the adjacency of Portfield School with other buildings on the site. The ‘H’ block which is currently used by Haverfordwest High VC School will become a Portfield School building. Simiarly, it is proposed to extend the current Holly House in order to provide much needed residential capacity for Portfield pupils.

Comments/observations

General
More fit for purpose secondary LRC units in Haverfordwest schools or build a new fit for purpose secondary SEN school in Haverfordwest

Response

Under the ALN Code, there is a general duty to favour mainstream provison. LRC classes provide this opportunity for learners with identified ALN to be taught at a mainstream school. The Council has recently expanded its secondary LRC provision by opening a new class in Greenhill School Tenby. We now have 3 sites to provide the geographical spread to meet the needs of learners across the County.
A separate SEN Secondary School is not a preferable option. Split sites do not always work well for learners or staff. It increases management costs and provides unnecessary transitions for learners who already struggle to adapt to change.

Comments/observations

General
Whilst this is very much needed. The provision by the school also needs to be extended for all holistic needs provided. Ie Holly house needs extending to provide more spaces. There needs to be more around creating an environment around the school, almost to build a little community. Ie practice shops, practie home living accomodation, specific sensory areas, more lifeguards, more holistic support workers such as music and dance therapies. More numbers is great, but the resourses around the children also need to grow.

Response

Holly House is included in the Council’s proposal. The Portfield site already accommodates an adult learning 

Day Centre and Norman Industries, which provides training and work opportunities for disabled people and those with learning difficulties. Social care have a respite facility on site which enables learner’s short breaks and in some cases emergency accomoodation.
There is a need to prevent unnecessary cliff edges for young people, to support transitions from education to training and work and supported accommodation towards independence.
The new curriculum for specialist schools needs to be diverse and recognise the unique challenges to provide the life skills and non academic elements of the curriculum to develop confident individuals who will be equipped with the skills and competencies to enable students to contribute economically within their Community. Many new Special schools will offer this breadth of provision, teaching students the life skills to cook and care for themselves independently and provide opportunities to learn skills such as handling money and finding supported employment and training opportunities.
More complex learners also require adapted environments and specialist areas such as rebound therapy, sensory rooms, hydro therapy and a life skills department.

Appendix one

Portfield School:

Regulated alteration to increase the number of pupils for whom the school makes provision

Ref 2: 

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

(comments redacted for the purposes of this document - respondent does not want their comments to be made publically available)

Ref 3: 

Q3: Please provide any other comments on the proposal.

This is really needed for so many children.

Ref 4: 

Q2: Please provide any alternatives you have to the proposal.

I wonder with HHVC moving could portfield make use of the site that HHVC was on?!

Q3: Please provide any other comments on the proposal.

The lower school most definitely needs modernisation

Ref 6:

Q2: Please provide any alternatives you have to the proposal.

More fit for purpose secondary LRC units in Haverfordwest schools or build a new fit for purpose secondary SEN school in Haverfordwest

Ref 8:

Q3: Please provide any other comments on the proposal.

Whilst this is very much needed. The provision by the school also needs to be extended for all holistic needs provided. Ie Holly house needs extending to provide more spaces. There needs to be more around creating an environment around the school, almost to build a little community. Ie practice shops, practie home living accomodation, specific sensory areas, more lifeguards, more holistic support workers such as music and dance therapies. More numbers is great, but the resourses around the children also need to grow.

Ref 9:

Q3: Please provide any other comments on the proposal.

Definitely needed

Ref 13:

Q2: Please provide any alternatives you have to the proposal.

No - improvement is needed

Q3: Please provide any other comments on the proposal.

Hopefully the school’s enhancement will not be compromised by limitations being placed on the site at Haverfordwest High. Space is paramount for the needs for Portfield pupils

Ref 14:

Q2: Please provide any alternatives you have to the proposal.

No alternative happy with the proposal.

Q3: Please provide any other comments on the proposal.

Pembrokeshire College welcomes the opportunity to continue to work closely with Portfield School.

Q4: Please tell us what your interest is in the consultation? (Please tick all that apply) (Other (please specify))

The College is a transition partner with Portfield and already works strategically with the school and the Local Authority.

Appendix two

Estyn’s response to the regulated alteration of Portfield School

Introduction

This report has been prepared by Her Majesty’s Inspectors of Education and Training in Wales.
Under the terms of the School Standards and Organisation (Wales) Act 2013 and its associated Code, proposers are required to send consultation documents to Estyn. However, Estyn is not a body which is required to act in accordance with the Code and the Act places no statutory requirements on Estyn in respect of school organisation matters. Therefore as a body being consulted, Estyn will provide their opinion only on the overall merits of school organisation proposals.
Estyn has considered the educational aspects of the proposal and has produced the following response to the information provided by the proposer.

Summary/ Conclusion

The proposal is by Pembrokeshire County Council to make a regulated alteration to Portfield school to increase the number of pupils for whom the school makes provision.
Estyn considers that the proposal is likely to at least maintain the standard of education provision and outcomes for pupils.

Description and benefits

The council has presented a clear rationale for the proposal to undertake improvements to the school site and buildings. It presents well the background information relating to the proposal including pupil numbers, forecasts, school capacity and buildings. Using this information, the council demonstrates appropriately the need for increasing the number of pupils for whom the school makes provision.
The council has usefully provided a detailed description of the proposal. This includes extending the existing upper school building to accommodate lower school pupils, utilising an adjacent building on the site and an addition to an adjacent building to provide additional and full-time residential care places for Portfield school learners. In addition, it has provided the timeline for the statutory process that it expects to follow in respect of this proposal.

The council has clearly set out the strengths and weaknesses of the current situation and considered appropriately the advantages and one disadvantage relating to the proposed regulated alteration. The advantages relate to increasing the capacity of the school, improving buildings in poor condition, and maximising the use of current adjacent buildings. The one disadvantage identified relates to the disruption caused to pupils and staff during the building phase. However, the council asserts that their project teams are well versed in these projects and the disruption will be managed in line with established project planning principles and full engagement and cooperation with the Headteacher. This seems to be a reasonable assertion.

The council has suitably considered four main risks that are associated with the proposal. These include failure to obtain timely relevant statutory notice approvals and the impact on the proposal of delays in reaching decisions related to this proposal. The council has identified suitable counter measures that could help to mitigate against these risks.
As part of this consultation process, the council has considered a range of alternative options. These include the option of doing nothing or undertaking a new build of the lower school building. The council have discounted the alternative options and have provided seemingly appropriate reasons for doing so.

In considering the impact of the proposal on travel arrangements, the council refers to its school transport policy in relation to learners with additional learning needs and disabilities. It reasonably concludes that the proposal will not impact on transport provision, other than accommodating additional learners. The proposal does not address the additional travelling time that pupils from outside the normal school catchment may have.
The council presents a reasonable argument that it is difficult to project demand for special education because of the variations and complexity in individual needs required for each learner. However, it has set a nominal capacity for Portfield school at 155 pupils and the projected demand for this school’s specialist provision is predicted to be 170 in September 2022. This number is likely to increase in future years.
As part of the proposal, the council has provided a relevant Welsh language impact assessment. It concludes that the proposal does not have any impact on the Welsh language as there is no proposal to change the provision, merely to improve and extend the learning environment. Welsh medium provision is provided from satellite provision (Y Porth) at Ysgol y Preseli. In addition, the Welsh language impact assessment states that the proposal fits in with outcome 6 of the Welsh in Education Strategic Plan 2022-2031.


The council has suitably listed the financial costs of the proposal to be £20.3m. Capital investment is being sought from band B of the council’s 21st Century Schools Programme which will cover 75% of the cost. The remaining 25% will be funded by the council itself. The council suggests that it is unlikely that any significant revenue savings will arise from this proposal.

Educational aspects of the proposal

The school has suitably considered the impact of the proposal on the quality and standards in education. It has done this through considering statements in the most recent Estyn inspection report and adding a comment as to what impact the proposal will have on each of the inspection areas.

ID: 8840, revised 04/07/2022
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