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Objection Report

Consultation Process

  • This would have been a very unfair and biased consultation process had it been undertaken during “normal times”, but conducting it at the height of a pandemic where the majority of the consultation period was during “lockdown” is nothing short of shocking and scandalous. Many people were confined to their homes, unable to meet and discuss the proposition in detail and unable to appropriately respond to the consultation, for the authority to push on with this proposition despite these circumstances really is bewildering.
  • The consultation report is based on a consultation that provided inaccurate and misleading information. This concern was raised early in the consultation, but was not responded to, and accurate documents were not provided and consultees were not made aware of the inaccuracies.  In my view, the consultation report does not adequately address these concerns.
  • Every school’s circumstances in regard of its community, its needs and its physical estate is different. Offering the same set of options to the three different schools, rather than exploring different options for each, was both misleading and inappropriate.
  • There are thousands of people in the valley, all with ideas and views. Your approach has been to try and limit their voice which is the complete wrong way around it.
  • It was also difficult to come to a conclusion on a report that contained inaccuracies.
  • These concerns were discussed in the report but then dismissed. Dismissing concerns just because you don’t agree with them, is not the same as addressing them.
  • The consultation result seemed predetermined with only information to support the recommendation included. Much of the information from Estyn was included in small snippets which could be used out of context to support an argument or was out of date
  • The 21st Century School programme is meant to improve education, not provide funding for leisure services. This proposal is not purely educational in focus, and the reference to the development of leisure facilities in the consultation was inappropriate.
  • This reports that queries and comments have ben responded to. I have not received any feedback to my comments and queries!
  • If this decision is ratified without a proper public debate where questions can be asked and answered demanded, it will be irrational, unfair, discriminatory and illegal and the LA will leave itself open to the community seeking a Judicial Review, which of course will cost the public money.

Officer Response

Consultation on the proposal to establish an English-medium 3-11 school to replace Alltwen, Godre’rgraig and Llangiwg primary schools has followed the procedures required under the Welsh Government’s School Organisation Code which specifies the type of school organisation activity on which the Council is required to consult and the process to be followed in conducting consultation. 

Despite Covid 19 this consultation has been conducted following Welsh Government guidelines and has adhered fully to the Code. In some aspects this consultation process has given consultees greater opportunities to engage as the option to respond online has not been used previously.  

Objections have been received which state that undertaking a consultation during the pandemic has prevented public discussion and debate on the matter. It is recognised that the current restrictions in place have prevented face to face meetings, however this has been mitigated by officers being available to answer queries and concerns by email or phone, enabling consultees with individual concerns to have specific answers. The Code specifies that there is no requirement to hold consultation meetings. Meetings are not a substitute for written responses – where meetings have been held in the past attendees have still been urged to respond in writing to the consultation, as notes taken at meetings do not constitute formal responses.

It is also the case that this proposal has generated significant interest in the area and much wider afield, demonstrated from the objections received from across Wales and beyond. References to social media action groups would suggest that much debate has gone on through this platform and officers therefore do not support the view that the pandemic has prevented discussion.

Objections have been received which state individual feedback or responses to comments were not received. The consultation document outlined how the consultation would be conducted, stating  ‘All responses to this consultation will be considered when making its decision and a consultation report will be published following the end of the consultation period. The consultation report will summarise the issues raised by consultees and include a response. (Consultation Document p.39) A comprehensive 63 page Consultation Report was published on 28th May 2021 which contained a summary of the comments received, along with officer responses. Individuals who contacted Strategic School Improvement Programme officers with queries to enable them to make an informed response to the consultation were provided with a direct response. 

The Consultation Report has set out in some detail the views of the consultees who responded and the officer responses to their comments.  Some comments received have highlighted concerns that will need to be addressed should the proposal be implemented, one example being the issue of ensuring that transition work is undertaken in a timely manner to ensure that good relationships are created between the staff, pupils and parents of the three schools in advance of the new school opening.   This does not mean the proposal should be abandoned but rather that care should be taken to ensure that these issues are noted and addressed if the proposal is progressed.  This matter has been reported and has in turn been fully considered by Members when making their decision to publish the statutory notice.  It is, therefore, not the case that these comments have been ignored or not taken into consideration. At no time has the Council sought to limit views or ideas.  Alternative proposals received from consultees during the consultation period were reviewed and assessed and the Consultation Report provided information on the findings.

All information provided by officers has been as accurate as possible and while objectors have commented that incorrect answers and information have been given,  it is the case that in most cases specific detail of these suggested inaccuracies has not been provided, making it impossible, therefore, to clarify or address any errors, if these have indeed been made. Where further clarification has been sought this has been provided, both in response to direct requests, through the consultation report and during Cabinet scrutiny meetings.

It is impractical to include the entire content of reports by Estyn or other bodies in a consultation report, however all references to reports were provided, allowing the reader to further investigate the source as required and to better understand the context. Equally this information makes it clear when a report was published, as some of the more thematic reports are not revisited and therefore provide the most up to date information available. For clarity at no point in the Consultation Report were the three current schools referred to as ‘small schools’ as defined by Estyn ‘School Size and Education effectiveness’ December 2013; however it is the case that they are clearly smaller than the proposed new school.

The proposal being considered relates to the establishment of a new 21st century school, and as such it is not clear why it has been suggested that three separate consultations should have been undertaken for each of the three affected schools. The proposal for a new build 21st century school was relevant to each school, and it was not necessary or appropriate to ‘explore different options’ for each by way of three different consultations.. However, where alternative options for different schools have been put forward during consultation then these have been explored and findings subsequently included in the Consultation Report.

Objections have been received which suggest the whole process has been rushed. This is incorrect. The proposal has involved extending the statutory periods as set out in the School Organisation Code in an effort to provide consultees with as much time as possible to respond to the consultation. There was no call to extend the process further. Previous evaluations of consultations involving proposals to close a school have suggested that the longer the process takes the more stressful it can be for those directly involved, especially staff and pupils who can find themselves in a prolonged period of uncertainty about the future. 

Officers do not agree that the inclusion of information regarding the leisure facilities was inappropriate. It is the case that consultation on the proposed new pool is not a requirement of the School Organisation Code, though pupils at the new school and other schools in the area would have use of it. However it is also part of the overall proposal to create a health and well-being community campus and a number of comments were received about this aspect. In an effort therefore to address concerns and queries raised it was considered appropriate to include information about it in the consultation report. Additionally it is the case that the funding for the pool and the school has been secured as part of the 21st Century schools capital grant as one scheme. If the proposal for the new school is not approved then the funding for a new pool will also not be available.

Objections have been received which state that this proposal has been predetermined. To date no decision has been taken on the proposal other than to approve consultation and to publish a statutory notice allowing for objections to the proposal to be put forward. Elected Members have yet to make a final decision and will be urged to ensure that all the relevant reports and information available to them is fully considered before a decision is reached. Nor is it considered that Members have had a closed mind in the process to date.