SCHOOL ORGANISATION REVIEW
Response by St Felix CEVC Middle School Governors to the
report and recommendations of the Policy Development Panel
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1. Uncertain marginal gains far in the future are too high a price for this
generation of children to be expected to pay
2. The quality of the consultation was poor, disenfranchising the parents of
pre-school children in particular
3. The questionnaire was not fit for purpose
4. There was no consultation on the all-through school and insufficient
information about the new two-tier option
5. If the local authority proceeds with a decision to reorganise it will lay itself
open to judicial review
6. We make a Freedom of Information Act request as the non-delivery of the
consultation document should result in penalties being exacted from the
7. The Consultation Report is inadequate in a number of respects
8. It is a well-understood principle of public life that no mandate for change
is a mandate for no change.
9. The County Council owes a duty of care to the children in schools now or
about to come into the school system
10. The council owes duties of care to its staff
11. The separation of the review into two stages was misconceived because
we need to know how changes would work in practice before taking a
decision in principle to make them
12. The argument about school size goes topsy turvy when small village
primaries are mentioned
13. Planned changes to curriculum, learning and assessment make a
nonsense of trying to abolish the three-tier system
14. 14-19 Education is the elephant in the room and should be uncloaked for
proper public discussion
15. There is a better way
It is our view that the report of the Policy Development Panel (PDP) - dated
December 2006 - fails to refute the arguments advanced in our response to the
review, Reviewing the way schools are organised in Suffolk: a response by St Felix
CEVC Middle School Governors. Rather than repeat those arguments, we re-
attach that response to this.
However, we do want to emphasise one point. That by some time in the 2020s
Suffolk might have a marginally better education system, which ‘equates to
about 130 students a year performing less well in the three-tier system … For
example a student gaining 7 B grades in the two-tier system might gain 6 B
grades and one C grade in the three-tier system’ (School Organisation Review,
Pupil Performance, Research Findings, 28/3/06) but a whole ‘lost generation’ of
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children, some of them not yet born, will have their educational prospects
damaged forever by the profound and long-lasting upheaval that will be
caused by putting the PDP’s proposals into effect.
The Quality of the Consultation
Notwithstanding the protestations of the PDP, it remains our view that the
consultation was poorly conducted, for the following reasons.
Substantial numbers of Suffolk households did not have the consultation
document delivered to them as promised
Although the deadline for responses was extended - though not to the
30th October, 2006, as we argued – no effort was made to ensure the
consultation document was posted through every letterbox in the county
Although additional copies of the document were put out through the
good offices of schools, this action missed the point as a pre-school child
now might well be taking KS3 SATs – if they still exist – in either a split-site
school or in a portacabin or on a building site, always assuming Building
Schools for the Future runs to schedule!
In the circumstances it is not surprising that the response rate was low nor
that parents are now angry at what is proposed having felt kept in the
dark during the consultation period
Paragraph 20, Figure 2 of the Consultation Report (dated 31st October,
2006) showed that the response rate of the 17-25 age range was only
1.2%, much less than the 40% + responses in the 26-59 age ranges, yet this
is precisely the age group who may not have been reached through
school post but whose pre-school or as yet unborn children will suffer the
effects of the change process
The PDP’s report was accessible online only on Monday 18th December,
the day before the end of term, giving very little time for response to be
made before the Cabinet meeting on the 16th January 2007. A hard
copy arrived in the school’s post only on Thursday 11th January!
Questionnaire fit for purpose?
We made clear in our earlier submission that the questionnaire at the back of
the consultation document – for those who received it – was poorly designed.
We believe the reported outcomes confirm this in three main ways.
1. Pupil achievement comes out top of the list of concerns offered in the
questionnaire (Consultation Report, paragraph 24 and Figure 6). But, as
we predicted, the list was constructed in such a way that no other
reasonable choice was available. As a piece of data this outcome is
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2. On the other hand, the ad hoc comments summarised in paragraph 25,
Figure 7, in respect of concerns and again in paragraph 53, Figure 16, in
respect of school type, show only too clearly the kind of comments
people actually wanted to make but were frustrated from making by the
design. And those comments clearly favour the retention of the three-tier
system and the rejection of the option of destroying highly regarded
3. The introduction to the PDP report, paragraph 3, noted the 14-19 agenda
and the use of resources to support Every Child Matters as two of ‘a
number of significant, interlinked developments to consider that relate to
school organisation’. If the questionnaire had been fit for purpose, one
would expect that it would have generated responses on these issues
proportionate to their significance. What does the Consultation Report
‘The 14-19 agenda did not feature prominently in the responses’
‘Use of resources did not play a major part in the responses except in
the Governors Seminars, perhaps because governors have budget
responsibilities’ (paragraph 57)
‘Issues at the centre of Every Child Matters (ECM) were rarely referred
to directly’ (paragraph 75).
All-through Schools and New Two Tier
The PDP recommends that ‘consideration be given, in exceptional
circumstances, to the all-through option’, but, as the PDP itself acknowledges,
this is not an option on which we were consulted: ‘the Panel noted also that
there was no mandate within the consultation for the all through option’ (PDP
Report, paragraph 214). We believe that before any decision is taken, even ‘in
principle’, we are entitled to be consulted on this recommendation.
We note also that the report of the Scrutiny Working Party to Cabinet on 16 th
January says that ‘international evidence shows the best age of transfer age
between schools is 14 years’ (paper CYP07/02, paragraph 39) and the PDP
report says ‘the panel considered that this option [i.e. the new two-tier with
transfer at 14] had some merit’ (paragraph 211). In view of the lack of
information on this option provided during the course of the consultation, we
believe that we have a right to be re-consulted about this option too.
It is our belief that if the Cabinet decides to go ahead on the basis of the PDP’s
recommendations it will lay Suffolk County Council open to judicial review on
behalf of the generation of children, some of whom are not yet in the school
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system, whose educational experiences will be blighted by the disruption these
proposed changes will cause.
Freedom of Information Act request
Paragraph 73 of the Consultation Report talks of the ‘apparent’ non-delivery of
leaflets and documents, so unwilling were the PDP to acknowledge the facts.
The PDP report does acknowledge at last that ‘it became clear that there had
been difficulties in the distribution of About Suffolk’, paragraph 171, for example.
Those difficulties should not have affected the right of all Suffolk residents to be
consulted but were a contractual matter between the Local Authority and the
distributor. As a test of the authority’s ability to control costs, we should like to
The name of the contractor awarded the contract to deliver the
The amount of the contract
Details of penalty clauses included in the contract
Whether any penalties were activated as a result of the now
acknowledged non-delivery of the consultation document
The amount paid in respect of this contract
Whether this was less than the contract amount and if so by how much.
The Consultation Report
We should like to comment on the Consultation Report as follows:
Paragraph 19, Figure 1 shows that no unions responded. Paragraph 78
quotes a teachers union as recommending that the ‘pattern of 14-19
needs to be established first, before looking at structures ….’. The first
respondent in paragraph 78, a parent, is quoted as saying ‘I do not trust
your statistics’. Quite!
Paragraph 30 analyses response in terms of agree/disagree but the
largest number of responses, almost twice as many as any other, was
strongly disagree with change. Why offer degree of response options if
they are not then analysed?
A large majority of a small majority (paragraph 39) is actually a minority
(71% of 45%, Paper C07/02, paragraph 29). A minority on a small response
rate (paragraph 37) is a tiny minority
Paragraph 63 pejoratively contrasts the ‘growth and effectiveness of local
9-13 teacher training’ with ‘training for the two-tier structure …. More
attractive given its popularity nationally’. Local providers include the
University of Cambridge, of course, only ranked number 2 in the world for
the quality of its research!
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Paragraph 72 seeks to wrap itself up in ‘the partnerships arising from the
recent 14-19 consultation exercise’, yet none of these advocated a
change from three to two tier structures
Paragraphs 87, 102 (Figure 23) and 118 (and paragraphs 177 and 185 of
the PDP report) present pupils’ responses to changing school once, twice
or three times or more but this is an arithmetically bizarre way of analysing
pupil choices in relation to structure. As a matter of arithmetic, a three-
tier structure requires two changes of school. A pupil may change school
more often than twice but not because of a three-tier structure.
Paragraph 146 says ‘young people were less interested in structural issues
than the impact of schools on their lives and their own relationships with
schools’. Perhaps, rather than paying lip service to consulting pupils, the
PDP should take seriously what they say.
The Status Quo
Paragraph 29 of Paper C07/02 says that ‘the panel concluded that the
outcomes of the consultation were not decisive. They considered that, while
the margin in favour of change did not provide a mandate for change, neither
did it provide a mandate for the status quo’. It beggars belief that officers
senior enough to write papers for Cabinet should make such unexamined
statements, even on behalf of the PDP. It is – or should be – a well-understood
principle of public life that no mandate for change is a mandate for no change.
So well established is this principle that it is phrased in the language of ancient
Duty of Care
Suffolk County Council owes a duty of care to the children in the school system
now or about to enter it, the children whose parents have been effectively
disenfranchised by the flaws in the consultation process. As the Ofsted
framework makes clear, this duty extends to their standards of achievement.
Yet in pursuit of the chimera of marginal improvements to standards of
achievement by future generations of pupils brought about by a change of
structure alone, the PDP is willing to risk the standards which this generation can
achieve. This generation will not be educated in a ‘world class’ education
system but a second rate one.
What do we know?
Staff morale has already plummeted as a result of the PDP report and the
associated failures of the review process, not as a result of ‘the sharp
reduction in the number of middle schools nationally over the last ten
years’ as the PDP claims (chapter one, paragraph 3)
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Permanent staff, especially teachers, likely to be more mobile than
support staff, will leave middle schools as soon as they can and will not be
able to be replaced by staff of the same quality, if at all
Children who can migrate over the county’s boundaries to schools in
stable systems will do so, reducing the resources of our schools, especially
staffing, still further
Standards of achievement are likely to fall not rise
All so that 130 pupils who already score 7 grades B at GCSE can gain one more
B instead of a C. As we have already said, do we really want to put all our
children through this so that about 130 students can improve one GCSE by one
What is the PDP’s response to this probable state of affairs?
The PDP reports a ‘Risk Assessment’ in paragraphs 194 to 198 but it is this
generation of children that will bear the risks of change and about this the
PDP is almost completely silent
To resource the overall costs of the review by ‘borrowing at interest from
existing school balances’ (Paragraph 231). We have worked hard over
the last two financial years to turn around a deficit financial situation into
one showing a working balance. This should be available to educate
existing students, who have as much right to the highest class education
we can give them as anyone else. Yet at the moment we move into
surplus our children risk having that money taken away from them. This is
robbing Peter to pay Paul with no likely payback for Peter now or in his
In order to ‘cover the discrepancy’ between the timetables of the School
Organisation Review and the receipt of Building Schools for the Future
(BSF) moneys – always assuming BSF both runs to time (it is already one
year late) and materialises in full at all – to raid Devolved Formula Capital
funding, even though this funding exists to ensure a school is in the best
state for children now as well as the future. A new Science lab has been
in our School Development Plan for some time. Now, having spent money
doing all the feasibility studies, the local authority tells us that we cannot
enter the capital programme next year as we anticipated!
To seek to gain the agreement of the DfES and the Dioceses to resist
changes of status (paragraph 196) even when governors might decide
that such a change would be in the best interests of children now.
Following our successful Anglican inspection in November 2006, we should
like to consider whether a change to aided status would be in the best
interests of our children without this kind of pressure being applied to us by
the local authority. (In any case, the policy of the General Synod of the
Church of England is to increase the number of church secondary
schools. Since, according to Appendix 2 of the Dearing report, The Way
ahead: Church of England Schools in the new millennium, 7 of the 9
church secondaries in the diocese of St Edmundsbury and Ipswich are
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middle deemed secondary, it is difficult to see how the diocese could
acquiesce in the closure of its middle schools without requiring in
compensation a commensurate opening of 11-16/18 secondary schools
in their place.)
Duties to staff
Suffolk County Council affects to care for health and wellbeing of its staff by
promoting such programmes in school. Yet the PDP has neglected this duty of
care in framing its proposals.
There would be a huge range of detailed issues for negotiation if reorganisation
were to take place, and we cannot begin to address them. Recent public
statements on behalf of the PDP claim that no staff need lose their jobs.
However, such statements do not go far enough to allay fears. In particular:
Effective, skilful, experienced and senior teachers in the middle period of
their careers, say in the 35-50 age range, may find that they are too
young to retire and too old to gain new positions commensurate with
their age and experience. How will they be protected?
Support staff, many of whom work close to where they live, perhaps
because they may have sent their children to the school where they now
work, may not be mobile enough simply to move schools. How will they
Will compulsory redundancy be used and if so who is likely to made
redundant? Will middle school staff be singled out or will everyone in
three-tier areas be at risk?
No information on these and many other human resource questions has been
provided but the questions should be addressed in advance of any decision
even in principle to confirm that change is viable even from such a perspective.
The review division into in principle/in practice stages is misconceived
In fact, the whole decision to split the review into two stages, an in principle and
an in practice stage was misconceived. This is before taking into account the
exponentially much greater disruption to the education of the generation of
children who will endure the effects of the change process which will be caused
by separating stage two into phases.
For example, the PDP blithely assumes that it will be possible simply to:
add two years to existing primary schools, leaving the two extra years to
be educated in portacabins until money for building primary schools for
the future which is not even yet planned becomes available
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add two years to existing secondary schools, creating split site schools –
an option nobody would choose if given the choice – until building
secondary schools for the future, out of phase with the Organisation
review, comes on stream
close all middle schools
But is such an assumption realistic? We do not believe it is. Land use planning
would require not only satisfactory size and location of buildings, even
temporary ones, but an increase in outdoor play space for a larger number of
pupils and an increase in parking for a larger number of staff. It is our belief that
a significant number of primary schools across the areas of the county likely to
be affected, even in Newmarket, do not occupy sites capable of expansion
when all the requirements of land use planning are taken into account.
An accurate assessment of how any second part review could be implemented
– including its cost - needs to be made before any decision in principle is taken.
Small primaries and the logic of the argument
There is a strange reversal in one strand of the argument. This is the argument
that middle and upper schools in the three –tier system are too small for pupils to
reach the highest possible standards. Middle schools are typically home to 400
pupils. The PDP wants to create secondary schools of 1200, three times the size,
thus exacerbating the anxieties of transfer at age 11. This is at a time when the
creation of super-secondaries in the last period of reorganisation has been
discredited and when other authorities are considering changing to a three-tier
system to rekindle an appetite and improved climate for learning which our
middle schools are so good at, which even the PDP acknowledges – though
how they come to believe that ‘this expertise need not be lost and that steps
must be taken to ensure that established good practice continue’ (paragraph
208, for example) when they intend to destroy the schools whose ethos this is is a
Yet when it comes to small village primaries, many of them with sites incapable
of satisfactory expansion, the PDP wishes to protect them. How? By making
them bigger and bussing more children into them! (e.g. paragraph 27).
Planned changes to curriculum, learning and assessment
Fortunately, just as Cabinet is about to decide on this ill-considered
recommendation, a plethora of announcements from government show how
short-sighted the PDP report actually is. They include:
the personalising learning report
the pilot testing 11-14 children when their teachers believe they are ready
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changes to Key Stage 3 curriculum and learning to make use of the skills
learned at Key Stage 2
raising the school leaving age to 18, which will require a recalculation of
how to spend BSF moneys
Taken with the increasing emphasis on Every Child Matters by Ofsted, an existing
middle school strength, it is likely that Suffolk would not be very far into its
abolition programme before it wished it was creating more middle schools not
Turn again, Mr Whittington, before it is too late!
14-19 Education: the elephant in the room
As we made clear in our comments on the lack of fitness for purpose of the
questionnaire, there are a number of major issues that the public has not been
able to recognise from the way the review has been conducted. But perhaps
the biggest elephant in the room is what to do about 14-19 education.
Frankly, it looks very much as though the PDP wants to create Sixth Form
colleges in the urban areas and has used the reams of paper on standards of
achievement in the three-tier system as a blanket to hide the elephant. As we
have already argued, such a move would leave a medium-sized town like
Newmarket without a Sixth Form, creating yet more bussing.
No sensible decision about the future of schooling in Suffolk even in principle
can be made without having this discussion out in the open where it belongs.
What do we learn from the PDP? ‘They concluded that, if the Council agreed
to proceed to Stage 2, then the area reviews should include a review of 14-19
provision for all students’ (paragraph 88) by which time it will be too late to save
our middle schools.
There is a better way
As we said in our original response, there is an alternative: work with your
schools, not against them. That is the only way your ‘reputation’ (paper
CO7/03, paragraph 13b) can be salvaged.
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