Updating of the School Premises (General Requirements and Standards)(Scotland) Regulations 1967: consultation response analysis

Analysis of responses from the consultation on Updating the School Premises Regulations (General Requirements and Standards)(Scotland) Regulations 1967.

Business and Regulations

Question 23 – What are your views on the overall costs and savings identified in the Impact Assessment?

22 respondents provided comment on the overall costs and savings identified in the Impact Assessment.

The most frequently raised theme was that it was essential that the Regulations achieve better outcomes for children and young people and the achievement of any savings was secondary. This was most frequently commented on by local authorities, trade unions and individual respondents. It was felt that even if some costs did exist, clear and consistent Regulations covering children of all ages and in all provisions would be welcomed. This also provides an opportunity for schools to ensure they are fully accepting and inclusive. The benefits for learners were of the utmost importance, as although essential to control costs, it should not be at the expense of learning opportunities or have a negative impact on the ability to deliver effective learning. Cost and savings should not be the principle driver. Although the primary purpose for the consultation was stated as reducing bureaucracy, a trade union respondent felt that some bureaucracy was necessary, and that the need for this had been borne out across the UK where the pursuit of deregulation has had catastrophic effects.

As the importance of the proposed changes is based on enhancing a learner’s experience and impacting on educational outcomes, true cost neutrality can only be evident once the new Regulations are in place.

The most commonly held view by a small margin was that no savings will be achieved through the proposals. The potential for savings for not referring to a number of Regulations was considered to be illusionary, the hope is really that the Regulations won’t overlap. It was noted that it may be possible to achieve some savings if space standards are to be reduced. It was felt that costs in relation to playing fields were unlikely to be cost neutral, as there were ongoing maintenance costs to be considered; synthetic pitches also have lifecycle replacement costs estimated to be approximately every ten years. There were a number of concerns raised about the financial calculations used for pitches and whether external covered spaces were included in the accommodation areas for early years. Doubt was also raised about savings on land costs for multi-storey schools and the ability for these to necessary accrue to the Council. For example, if land for a new school is being provided but is part of a major new development, there may be pressure to minimise the land allocation, to the detriment of both design and teaching and learning.

The second most frequent response was that some savings could be achieved if the proposals were to progress. This view was most frequently held by inspection, regulatory and advocacy, local authority and individual respondents. It was felt that savings could be achieved by local authorities with one approach to space standards for early years facilities and supporting the development and use of appropriate outdoor space. Others stated that although in overall agreement, costs can change and fluctuate for a variety of reasons, so suggested costs can only be considered a guide. It was also highlighted that the best site to build a school is determined not only by cost but on the needs of the community to provide the best educational outcomes.

It was finally recommended that consideration should be given to reducing the overall running costs by making energy efficient options, such as solar panels, compulsory in new build schools.

Those respondents who considered the proposals to be cost neutral were most likely to be represented by equality or disablility and local authority respondents and formed the smallest group. No comments were made beyond statements of confirmation.

Two additional comments were made for consideration by the Scottish Government:

  • If the Regulations cover Independent Schools, mainstreamed or grant aided, then discussion should take place with schools to gain a realistic sense of possible costs.
  • A minimum standard in school infrastructure for ICT provision should be applied. This would be through the Scotland wide area network connectivity and the provision of connectivity in the classroom, either wired or wireless.


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