Object

Representation ID: 7554

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

The draft Vision sets out:
“Well-planned growth supported by appropriate infrastructure and avoiding areas of high flood risk will enable the creation of strong, safe and resilient local communities in environments that facilitate healthy and independent living for all.”
This aspect of the Vision will not be achieved in the context of the Council’s Preferred Options omitting a significant number of the borough's KSCs and RSCs from the spatial strategy and do not seek to provide for the additional development required to secure balanced communities.
Theme 4 (Better Places) of the Council’s proposed Objectives for the Local Plan 2040 sets out:
“Provide appropriate amounts and types of housing to meet the needs of the borough’s urban and rural communities over the lifetime of the Plan making the housing stock more adaptable and resilient
Achieve a borough where everybody has appropriate access to high quality health and social care, as well as everyday essential services and community facilities where social and cultural wellbeing are supported, enabling all residents to lead healthy and independent lives.”
The principle of these objectives is supported but is reliant on flexibly supporting diverse opportunities for development across the settlement hierarchy. There are a substantial number of centres where the level of development identified is insufficient to secure the opportunities identified or, as in the case of Oakley, to provide for a long-term strategy for improvement of the facilities at Lincroft Academy.

SUPPORT FOR THE REQUIRED EXPANSION OF LINCROFT ACADEMY
(a) Summary of the Expansion Proposals Requiring Immediate Support
Lincroft Academy has an immediate requirement for expansion to support a Pupil Allocation Number of approximately 240 admissions per annum from 2023. This should be reflected in the policies of the Local Plan 2040. In summary, plans for the works required to achieve the additional intake have been drawn up and the requirement for expansion has been agreed by Bedford Borough Council’s Education department.
The Borough Council’s Education department has further confirmed with CMAT details of the NOR forecasts necessitating the increase in the Pupil Allocation Number to 240. To our knowledge the evidence base for the emerging Local Plan 2040 makes no reference to these forecasts and the account they take of growth at neighbouring Key Service Centres including Clapham and Bromham and other committed development. It follows that while the current proposals would address the immediate need for expansion it would be necessary for the evidence base for the Local Plan 2040 to consider the potential demand for a further increase in the PAN over the plan period. Annual applications are apparently at or in excess of the Pupil Allocation Number.
This requirement for expansion is not currently reflected anywhere within the policies of the emerging Local Plan 2040, and has not been assessed within the emerging evidence base. The Council’s Infrastructure Delivery Plan is not yet available and assumptions within the AECOM Transport Model assume limited growth in housing assumed beyond 2030 in the reference case (which assumes no further growth beyond the adopted Local Plan). For Oakley, this means that the reference case only takes account of development within the Neighbourhood Plan and ignores altogether the settlement’s role in providing Primary and Secondary education. The current position of the existing and emerging development plan means expansion will need to be achieved in the context of the existing traffic conditions on Station Road.
Given the background and context of the development plan the strategy to achieve the expansion required within the necessary timescales represents a freestanding development proposal within the existing site west of Station Road. This current approach precludes the wider benefits of incorporating CMAT’s interests east of Station Road, considered later in these representations.

The scheme drawn up has an itemised cost of circa £8m. The cost is considered the minimum necessary to achieve an efficient expansion to 240-pupil entry and reflects the absence of any funding strategy previously agreed upon the change of Lincroft Academy’s role as a secondary school.
Together with the expansion in teaching and classroom space the scheme drawn up offers some limited improvements for staff parking and an ‘Activity Centre’ is proposed within the new buildings. The proposals allow for improvement to highways conditions on Station Road.
The plans and proposed funding sources for expansion take no account of relocation or enhancement of the existing sports pitches and are not expected to raise any implications for the ESFA.
(b) Background to Lincroft Academy and the Requirement for Expansion
The buildings at Lincroft Academy and Oakley Primary Academy share a single site on land west of Station Road. This is important in the context of the ongoing implementation of school reorganisation across the Borough to provide full primary and secondary education provision (age 4-16 years) within Oakley and the role of the schools in serving the wider rural area.
The evidence base for the Bedford Local Plan 2030 substantially pre-dates the reorganisation of school provision in Bedford Borough. It cannot be overlooked that as part of the change from a two-tier to three tier system Lincroft Academy is the only former Middle School within the North Bedfordshire area, expanded and repurposed to provide secondary education provision for pupils aged 11-16. Oakley Primary Academy, forming part of the same campus, provides education of those aged 4-11.
Middle Schools in a number of settlements have been closed altogether with a total net reduction in the number of schools from 74 to 60. This emphasises the contribution of settlements such as Oakley with a range of education provision to providing services and facilities for the wider rural area.
The recent reorganisation represents a substantial challenge in planning terms, albeit in the first instance change in the role of a school building from providing Middle School to Secondary School facilities is not in itself a change of use requiring planning permission. The wider repercussions of this in terms of extant planning history and the requirements for future use and development must be considered further. This includes not only meeting the demand for school places but also acknowledging the campus’ (Oakley Primary Academy with Lincroft Academy) role as a key employer and provider of wider benefits to the local community.
CMAT is committed to addressing as part of maintaining and enhancing education facilities and outcomes in Oakley itself and across the Borough but notes the absence of any comprehensively agreed funding strategy or development proposals supporting the changes outlined above.
A review of the planning history clearly indicates that there is no application activity associated with the recent school reorganisation to provide full secondary education (age 11-16) facilities at Lincroft Academy. This follows from substantial previous activity to sustain and enhance the facilities available and address growing demand on school places; albeit no explicit planning to support an increase in pupil numbers has been undertaken in recent years. The popularity of the school has been associated with a reactive approach.
In practical terms planning condition no.4 attached to application reference 16/00329/MAF limiting the pupil roll at Lincroft Academy to 855 pupils is instructive of how the planning history of the campus fails to reflect the current and future requirements of the site.
(c) Background to Provision of School Places
It is agreed with the Council’s Education department that NOR forecasts for Lincroft Academy necessitate increase of the PAN to 240 pupils intake at ‘year 7’ from 2023 onwards. While these forecast are not set out in detail in these representations, data on the number of current pupils at each school and the confirmed intake for the 2019/20 academic year was compiled to support representations to the Oakley Neighbourhood Plan submission (Regulation 16) version consultation in August 2019. The Council’s Planning Policy Team therefore has advanced knowledge of the pressure on school places from before commencement of the immediate review of the Bedford Local Plan 2030.
This is important because it provides an insight into overall demand and the ongoing impact of reorganisation. Data for previous years was obtained direct from the Department for Education’s absence and pupil population records to 2017/18.
Failure of either the Local Plan 2030 or emerging Local Plan 2040 to take any apparent account of the Council’s own NOR forecasts is a significant deficiency in the context of ongoing reorganisation and forecasts for future housing growth across the borough; including within Key Service Centres and Rural Service Centres. This represents a significant risk at the authority level in terms of ensuring the need for school places is addressed.
Table 1. Pupil Roll and Forecast – Lincroft Academy and Oakley Primary Academy (see attachment)
The past intake data demonstrates the continued high demand for school places in Oakley and ongoing impact of reorganisation. For example, in 2016/17 the Oakley Primary Academy was still a lower school, i.e., only accommodated pupils up to Year 4, after which point, they moved to a middle school. In 2017/18, the school started transitioning to a Primary School and took pupils up to Year 5. In 2018/19, it became a full Primary School, with pupils up to Year 6. For this reason, there is also some short-term fluctuation in the total number of pupils at Lincroft Academy as the school roll transfers to a secondary education facility. For Lincroft Academy the September 2017 intake (2017/18 data) is based on year 6 to year 9 pupils only).
At the point that the condition restricting pupil numbers at Lincroft Middle School (855no pupils) was imposed as part of application ref: 16/00329/MAF Oakley Lower School had a pupil allocation number of approximately 200, equating to 1,055 places in total. It is clear from the data for 2016/17 that the condition on pupil numbers at Lincroft Middle School was breached in 2016/17, as was a cumulative total of 1,055 across the combined sites.
Due to its sustainable location, it was accepted that provision for up to 290 pupils at Oakley Primary Academy is acceptable in transport terms, as assessed under application ref: 17/03321/DC3. However, it is also clear that the school is already operating at this capacity with significant further growth to be provided for.
Previously confirmed pupil intake figures for Lincroft Academy in September 2019 indicate the increasing demand for places. The full Pupil Allocation Number (PAN) of 210 places was met or exceeded for year 7 and year 8; along with a waiting list of 5 places for additional year 7 students. Each year 7 group is expected to be filled in the future, equating to a total potential pupil roll total of 1,050 pupils across years 7-11. This significantly exceeds the present restriction to accommodate a maximum 855 pupils based on extant planning permission 16/00329/MAF.
Any breach of the extant planning condition should be considered to have adverse environmental consequences in terms of (for example) land use and traffic impacts. It is important that the policies of the development seek to manage and address these challenges, which is not currently provided for within the development plan, which imposes significant restrictions on the development of the campus and surrounding land.
Lincroft Academy also provides 28 further places for specialist education provision as part of its Autistic Spectrum Centre (ASC) reflecting an important dimension of the school’s wider role. These pupils are additional to the PAN for years 7-11.
This background informs the current requirement to further increase the PAN to 240 for years 7-11. The following analysis reflects our own review of committed development and does not replicate the Council’s own unpublished NOR forecasts.
Data obtained by Lincroft Academy shows the significant role of the school in maintaining the supply of school places for the wider rural area. Table 2 below shows the confirmed pupil roll by year group in September 2019 and indicates all catchment districts which represent the origin location of 25 or more pupils on the total roll:
Table 2 - see attachment
Lincroft Academy provides the secondary school for the Clapham catchment, while the Bromham catchment offers preference for places at either Lincroft Academy or Biddenham Upper School. This is reflected in the high numbers of pupil on the roll for each year from these catchments.
Both Bromham and Clapham are Key Service Centres within the borough’s settlement hierarchy and are required to provide for the development of up to 500 dwellings as part of the spatial strategy set out in Policy 3S of the emerging Local Plan 2030.
Bedford Borough Council’s Planning Obligations Supplementary Planning Document (July 2013) provides benchmark figures for the increased requirements for secondary school places based on the typical increase in population generated by new development:
• 11-15 year old pupils: 4.2 children/age group/100 dwellings
• Equivalent to 21 secondary school age pupils (11-15 year olds) per 100 dwellings
The provision of 500 dwellings would therefore be expected to generate around 105 pupils in total, or 21 in each year group. Notwithstanding the potential for demographic change in the existing population, these pupils would be additional to the existing roll. It should also be noted that the total roll in years 9-11 will increase going forward based on Lincroft Academy’s intake reflecting its full Pupil Allocation Number (PAN).
We have assumed that the number of these additional pupils likely to attend Lincroft Academy will be consistent with the existing proportion of the 11-15 year old population that is recorded on the pupil roll in Oakley. The have based this on the proportion of the population as recorded in the 2017 mid-year population estimates for the Built Up Area of Bromham and Clapham respectively. This is illustrated in Table 3 below:
Table 3. Local Plan 2030 Related Growth In Secondary Age Pupils – Bromham and Clapham (September 2019) - see attachment
Development in-line with the emerging Bedford Local Plan 2030 is therefore likely to generate an additional demand for secondary school places of around 63 pupils from Bromham and 75 pupils from Clapham. These figures are likely to be a minimum, given that in future Lincroft Academy will meet or exceed its current PAN for each year group. Furthermore, the popularity of Lincroft Academy as a choice for feeder schools in the Bromham catchment is likely to increase.
This demonstrates the role of Lincroft Academy in serving a wider rural catchment and the imperative of ensuring its future requirements can be met to safeguard sustainable development. This will be in the context of Lincroft Academy regularly exceeding the cap of 855 pupils imposed via planning condition on 16/00329/MAF.
The planning strategy for the increase in the PAN to 240 is required in the short-term to address this increased demand. Depending on the extent to which the Council’s own NOR forecasts take account of development within the Neighbourhood Plans at Clapham and Bromham that is not already consented (i.e., over-and-above extant commitments) there is a strong possibility of the requirement to accommodate further increase to the PAN.