Supporting Communities
Introduction
This chapter sets out the planning policies that help support communities, particularly through the provision of social infrastructure, such as education and community, recreation and leisure facilities. Planning policies supporting communities are intrinsic to delivering the vision and objectives for the Local Plan and supporting Bromley’s Health and Wellbeing Strategy.
Social Infrastructure
3.1.1 Community facilities make an essential contribution to the health, wellbeing, development and education of individuals living and working in the Borough. There are substantial health benefits associated with access to community and leisure facilities, including not just better physical health, but also better mental health, through increased social interaction. The National Planning Policy Framework (NPPF) highlights the important role of planning in facilitating social interaction and creating healthy, inclusive communities.
3.1.2 The Equalities Act 2010 introduced a new 'single' equality duty to cover age, disability, gender identity, pregnancy and maternity, race, religion or belief, sex and sexual orientation. The equality duty requires all public bodies to have regard to the need to eliminate discrimination, advance equality of opportunity; and foster good relations between different groups.
3.1.3 The Infrastructure Delivery Plan (IDP) highlights requirements for additional supporting infrastructure, including schools, open space, community, health and leisure services which will assist in ensuring thriving and sustainable places in Bromley over the Local Plan period.
| Policy 20 Community Facilities The Council will promote the quality of life and the health and wellbeing of those living and working in the Borough and engage with providers and agencies to ensure the provision, enhancement and retention of a wide range of appropriate social infrastructure, including facilities for health and education; recreation, sports and play facilities, places of worship and venues for cultural and social activities, as well as the provision of community safety infrastructure such as police facilities, ambulance and fire stations. Development which meets an identified need for such facilities will be encouraged to locate to maximise accessibility and will normally be permitted provided that it is accessible to the members of the community it is intended to serve by a full range of transport modes. Planning permission will not be granted for proposals that would lead to the loss of community facilities, unless alternative enhanced provision is to be made in an equally accessible location for the community it serves, or it can be demonstrated that there is no longer a need for them or other forms of social infrastructure. Where a proposal for alternative social infrastructure involves a change of use not permitted under the GPDO Use Classes Order, the lack of need for the specific use class must first be demonstrated. Additionally, in respect of facilities identified by local communities as having significant value, planning permission for alternative uses will only be considered where it can be demonstrated that no prospective purchasers exist that would be willing to pay both a suitable price and maintain the existing use. |
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3.1.4 The ranges of uses that would be described as Community Facilities and / or Social Infrastructure, is very broad. The London Plan Policy 3.16 identifies the following as social infrastructure but advises that the list is not intended to be exhaustive;
“health provision, nurseries, schools, colleges and universities, community, cultural (Policy 4.6), play, recreation and sports facilities, places of worship, fire stations, policing and other criminal justice or community safety facilities and many other uses and activities which contribute to making an area more than just a place to live”.
3.1.5 It further expands on the a range of arts, cultural, sporting and entertainment provision (London Plan Policy 4.6) with reference to bars, restaurants, performing arts venues, cinemas and nightclubs. This wide definition of community facilities is also reflected in the National Planning Policy Framework (NPPF, para 70) which advises that planning policies should plan positively for the provision and use of shared space and community facilities, promoting opportunities for meetings between members of the community and specifically includes local shops and public houses. Additionally there may be other local infrastructure, open spaces or facilities which are distinctive to the Borough or particular places within Bromley.
3.1.6 The availability of social infrastructure has implications for the whole population but is particularly relevant in ensuring the delivery of “Lifetime Neighbourhoods”, which are defined as those that:
“offer everyone the best possible chance of health, well-being, and social, economic and civic engagement, regardless of age. They provide the built environment, social spaces that allow us to pursue our own ambitions for a high quality of life. They do not exclude us as we age, nor as we become frail or disabled” (Lifetime Neighbourhoods DCLG 2011).
3.1.7 Community facilities often face challenges in finding or retaining sites due to the nature of the activities, the impact on residential amenity and to financial pressures. The loss of social infrastructure can undermine communities and be detrimental to health and wellbeing and contribute to social isolation, which impacts particularly on older, disabled and other vulnerable groups. It also undermines the location options for organisations and service providers which help to build healthier communities and address health inequalities. Against the backdrop of increasing demands on community services and facilities and the spatial variation of provision, the Council will work with agencies and providers to ensure a wide range of accessible community, recreational and leisure facilities to support wellbeing and enhance quality of life.
3.1.8 The policy therefore resists the loss of community facilities unless alternative enhanced provision is to be made in an equally or more accessible location for the community it serves, or it can be demonstrated that there is no longer a need for them or other forms of social infrastructure. Such a demonstration of need should include consultation with relevant Council departments and third party providers to establish whether any community groups or service providers express a need for the site and are interested in buying or leasing it, as well as a six month period of marketing which is current and robust at a realistic value reflecting its existing use value (supported by a viability assessment which will be reviewed at cost to the developers). Proposals that involve a change of use between forms of social infrastructure, not permitted under the Use Classes Order, will also be required to demonstrate a six month period of marketing.
3.1.9 The Council recognises the financial realities faced by voluntary organisations in relation to their buildings and sites and will consider sympathetically proposals designed to support the maintenance and continued community use of such facilities.
Valued Local Community Assets
3.1.10 Under the Localism Act (2011), voluntary and community organisations can seek to protect valued facilities by nominating them to be listed as ‘assets of community value’, subject to certain criteria. This could include for example village shops, public houses, community centres or libraries. Once listed as an Asset of Community Value (ACV) the local community has a six month window to bid to purchase the land or buildings, should it be offered for sale. In some cases nominations as ACVs may only be received once the community become aware of the potential loss through the submission of a planning application (at which stage the sale of the site may have been agreed, subject to planning).
3.1.11 In respect of assets listed or nominated for listing, applications for planning permission will be required to demonstrate, through a six month marketing exercise which is current and robust, that no prospective purchasers exist that would be willing to pay both a suitable price and maintain the asset in its existing use.
3.1.12 London Plan Policy 4.8 relates to “sustainable access to the goods and services that Londoners need”, and, with reference to public houses notes that evidence of community asset value “includes where an asset is listed as an Asset of Community Value under the Localism Act 2011 or where an application has been made”. This is not an exclusive approach and other evidence may indicate that an asset is valued locally. The list of ACVs is available on the Council's website.
| Policy 21 Opportunities for Community Facilities The Council will support the maximisation of opportunities for the enhancement or the creation of social infrastructure, to address the needs of existing and future residents of all ages, particularly in renewal areas and more accessible locations such as retail centres and existing retail frontages by:
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3.1.13 As the demographics of the Borough evolve, for example with an ageing population or increasing birth rate, social infrastructure should reflect changing pressures to deliver appropriate provision for all residents of the Borough.
3.1.14 Opportunities to improve community facilities provision in the Borough may present themselves as a result of, for example, the changing nature of local parades and retail centres, through the creative use of existing buildings and open spaces, due to the reorganisation of services or through proposals for new developments.
3.1.15 The location of facilities should mirror the scale of the catchment of its users, ensuring appropriate accessibility. Where appropriate to the catchment, facilities will be expected to be suitably located in strategic locations such as town centres with good access to public transport. The changing nature of retail shopping presents opportunities for community facilities to occupy former retail units complementing the existing shopping function and helping to support the vibrancy of local parades and town centres. Additionally, subject to Local Plan retail policies, temporary community uses, which provide services to the public, can support the vibrancy of high streets or local shopping parades where a shop unit would otherwise lie vacant. Where a temporary community facilities use is permitted within an existing non “D” Use Class building, the restriction of the loss of community facilities afforded by Policy 20 Community Facilities, which might discourage such temporary use, will not apply.
3.1.16 Exceptions to this town centre first presumption would include facilities which serve smaller catchments, or locations which currently provide facilities to which there are established patterns of movement, or types of facility which are more numerous and therefore spread more widely across the Borough.
3.1.17 Where town centre locations are not available or appropriate, other vacant commercial buildings, which are accessible by a range of transport modes, may offer potential for social infrastructure uses, subject to other policies in the Local Plan notably those in the "Working in Bromley" chapter.
3.1.18 Numerous existing facilities already support a range of community activities. Such a “community hub” approach offers potential to assist the long term sustainability of facilities. The expansion of existing facilities into hubs can provide opportunities for enhanced provision, however, whilst this policy seeks to encourage co-location of services, proposals for relocation will be expected to locate in appropriately accessible centres within the shopping hierarchy and avoid unduly disadvantaging existing users, since poor access impacts disproportionately on older people and people with disabilities and can contribute to social isolation, diminishing health and wellbeing.
3.1.19 The National Planning Policy Framework (NPPF) is clear about the role that sport plays in delivering sustainable communities through promoting health and well-being.This can include enhancing community facilities, supporting educational opportunities, encouraging inclusion and engaging young people.
3.1.20 Planning Practice Guidance advises local planning authorities to consult Sport England in cases where development might lead to losses, or the creation or enhancement of major sports facilities, or the creation of pitches. Sport England’s Land Use Policy Statement “Planning for Sport, Aims and Objectives” details three objectives in respect of planning:
3.1.21 Pro-Active Bromley is a strategic, independent alliance of partners, including Bromley Council. The Pro-Active Bromley Strategic Framework 2011-2016 seeks to sustain and increase participation in sport and physical activity in Bromley and support the development of accessible sports and leisure facilities in the Borough to improve the quality of provision and widen opportunities to participate in sport and physical activity.
3.1.22 “Cultural Metropolis: The Mayor’s Cultural Strategy 2012 and Beyond” promotes high-quality urban design and an enhanced public realm, recognising that cultural organisations often have a key role to play in shaping strategies, informing planning processes and engaging on individual projects.
3.1.23 Developments should ensure that the environment does not lead to discrimination under the Equalities Act 2010 and should enable full and effective participation and inclusion.
3.1.24 It will be important that the impact of facilities on local amenity in respect of noise, hours of operation, highway safety or other environmental impacts are appropriately mitigated, for example through planning conditions or obligations, such as a travel plan.
| Policy 22 Social Infrastructure in New Developments New developments will be expected to provide social infrastructure appropriate to the nature and scale of the proposal, such as open spaces designed for imaginative play, on site provision of community facilities and / or contributions to off-site facilities. Developments of significant scale will create their own environment and therefore should incorporate within their design, public realm and / or community and other facilities, which create a sense of place, particularly in Renewal Areas and areas of acknowledged deficiency. |
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3.1.25 The NPPF advises that where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties.
3.1.26 Development proposals will be expected contribute to the reasonable costs of new services and infrastructure made necessary by their development proposals through the use of planning obligations (and/or any replacement of planning obligations, such as the community infrastructure levy) and to identify, plan for and, where necessary, complete necessary social infrastructure prior to occupation. It is important, especially in areas of significant new homes or areas of deficiency, to ensure the provision of community and other facilities, including local convenience foodstores, to match the projected population growth, reflecting the needs of a changing and increasingly diverse population, and that these facilities are accessible to all.
3.1.27 New development should also make provision where appropriate for wildlife as well as play and recreation areas in line with the Mayor's Supplementary Planning Guidance “Play and Informal Recreation” (2012).
Public Houses
| Policy 23 Public Houses The loss of public houses will be resisted by the Council except where :
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3.1.28 The National Planning Policy Framework (NPPF) indicates that planning policies and decisions should aim to achieve places which promote opportunities for meetings between members of the community who might not otherwise come into contact with each other. Many public houses attract adults across the age spectrum.
3.1.29 The NPPF specifically identifies pubs as community facilities and recognises their contribution to enhancing the sustainability of communities and residential environments; it requires local authorities to plan positively for such facilities.
3.1.30 Public Houses include a varied range of drinking establishments, as set out in the “Public Houses in Bromley Evidence Base 2014”. They can provide communities with a range of benefits, performing not only social but also cultural and economic functions and contributing to the identity of local places. Clause a) relates to all shopping centres from local parades to the metropolitan centre of Bromley.
3.1.31 Where a temporary community facilities use is permitted within an existing non “D” Use Class building, for example where a micro pub sets up on a short term basis, the restriction of the loss of community facilities afforded by Policy 20 Community Facilities, which might discourage such temporary use, will not apply.
3.1.32 The loss of public houses in the borough is a cause for concern, since 2000 at least 50 pubs have been lost across the Borough to alternative uses, most commonly restaurant and residential uses.
3.1.33 In line with national guidance the Council seeks to prevent the unnecessary loss of public houses unless alternative facilities are locally available, there is no adverse effect on local commercial centres or parades, and it can be demonstrated that the use as a Public House is no longer financially viable. This would involve demonstrating evidence of twelve months’ suitable marketing activity which is current and robust, and proof that the public house is no longer financially viable through an independent professional valuation, the submission of trading accounts, or other similar financial evidence, whilst the pub was operating as a full time business, and including details of the range of measures employed to attempt increase trade and diversify the offer. Information will be expected regarding the marketing of the business,offered freehold and leasehold, locally, and in the region, in appropriate publications and through relevant specialised agents. The CAMRA (Campaign for Real Ale) Public House Viability Test provides a guide to maximising the success of a pub business. A formal validation of the evidence will be undertaken by the Council, at the applicant’s cost.
3.1.34 Redundant pubs will also be required to comply with the Community Facilities Policy and hence should the twelve month marketing period as a public house not be successful, a further six months of marketing for alternative community uses, as set out in paragraph 3.1.8 will subsequently be required.
3.1.35 For communities wishing to protect a public house (or other community facilities) powers under the 2011 Localism Act allow communities to nominate pubs and potentially see them listed as Assets of Community Value.
3.1.36 Public house buildings may be important due to their heritage value and location. In such circumstances appropriate attention should be paid to policies that address heritage, conservation and character. In any event potential developers are reminded of the need for planning approvals prior to demolition taking place.
Allotments and Leisure Gardens
| Policy 24 Allotments and Leisure Gardens The Council will explore opportunities for new allotments and safeguard existing land used as allotments. Development of allotment sites will only be considered where appropriate reprovision of plots is made in accessible locations. In areas deficient in open space, any development enabled by replacement allotment provision elsewhere, will also be expected to retain an element of open space for public use within the redevelopment. |
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3.1.37 Allotment gardens present opportunities for outdoor activity social interaction, and healthy eating. In much of the Borough there are long waiting lists for a plot. Physical activity and good access to healthy food can improve quality of diet and help prevent obesity, overweight, diabetes and cardiovascular disease. Planning Practice Guidance outlines the importance of promoting access to healthy food through planning and infrastructure decision making.
3.1.38 The approval of the Secretary of State is required for the disposal or re-use of redundant statutory allotments. Whilst vacant allotment sites have in the past been rationalised, to provide enhanced allotment plots and benefits to the local community in terms of open space and housing, the London Plan (Policy 7.22) which encourages Land for Food, advises that existing allotments should be protected and suggests that boroughs should identify other potential spaces that could be used for commercial food production or for community gardening, including for allotments and orchards.
Burial Space
| Policy 25 Burial Space The Council will safeguard existing burial space and explore opportunities for further sites should pressure for places increase over the plan period. Developers will be required to secure the future maintenance of the burial site. |
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3.1.39 There are eight cemeteries across the Borough, six of which are owned by the Council and managed by contractors.
3.1.40 There is capacity in the Council's cemeteries at Biggin Hill and St Mary Cray for the period of the Local Plan and there is substantial capacity at the private Kemnal Park Cemetery and Memorial Gardens. It is difficult to predict how demand for internments and cremations may change over time but within the Borough there is provision available for people of all faiths and none.
3.1.41 The London Plan advises that boroughs should ensure provision is made for London’s burial needs, including the needs of those groups for whom burial is the only option. Provision should be based on the principle of proximity to local communities and reflect the different requirements for types of provision.
3.1.42 Given the pressure for land for development, any significant new proposals for burial sites would be likely to be confined to land with Metropolitan Open Land or Green Belt designations. Cemeteries are an appropriate use in the Green Belt and the National Planning Policy Framework (NPPF) advises that new buildings in the Green Belt are not inappropriate where they provide appropriate facilities for cemeteries, as long as they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
Health and Wellbeing
3.2.1 The development of town planning in 19th Century Britain came out of an understanding of the impact of the environment and development upon human health, leading for example to the provision of sewers and the development of building codes.
3.2.2 The Health and Social Care Act 2012 highlighted the need for partnerships and a shared health vision and agenda, and it proposes that public health be better integrated with areas such as social care, transport, leisure, planning and housing.
3.2.3 This is supported by Planning Practice Guidance which highlights the importance of local authority planners engaging and consulting with Health and Wellbeing Boards responsible for producing a Health and Well-being Strategy, underpinned by a Joint Strategic Needs Assessment (JSNA). Health and Wellbeing Boards bring together local authorities, the NHS, communities and wider partners. Bromley’s current Health and Wellbeing Strategy was published in 2015.
| Policy 26 Health & Wellbeing The Council will work proactively with health professionals and relevant bodies to improve the physical and mental health of the Borough's residents and reduce health inequalities by taking account of, and supporting local strategies for health and wellbeing and by delivering quality, healthy environments, infrastructure and accessible health facilities to meet the needs of the community, by
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3.2.4 Health is at least partly linked to the way we live our lives. The nature of the environments in which we live, work and relax affect both our physical and mental health. It is recognised that beyond fixed age, sex and hereditary factors there are “wider determinants of health”, including social, economic and environmental factors which are important for understanding health inequalities. The Marmot Review “Fair Society Healthy Lives” (2010) makes a clear recommendation that planning, transport, housing, environmental and health policies should be integrated to address the social determinants of health.
3.2.5 Healthier people tend to be happier, tend to play an active role and contribute to society and the economy through their families, local communities and workplaces. Conversely, poor physical and / or mental health and wellbeing puts a strain on individuals, the NHS, the economy and society. Planning Practice Guidance advises that “development proposals can support strong, vibrant and healthy communities and help create healthy living environments which should, where possible, include making physical activity easy to do and create places and spaces to meet to support community engagement and social capital” (Health and Wellbeing para 002).
3.2.6 The World Health Organisation defines health as “a state of social, physical and mental wellbeing and not merely the absence of disease.”
3.2.7 The Health and Social Care Act 2012 emphasises the prevention of illness with a specific leadership role for local government in respect of public health responsibilities including, tackling health inequalities, health protection and obesity.
3.2.8 The design of homes, can influence mental and physical health. All new dwellings, other than Category M4(3) Wheelchair user dwellings, should be accessible and adaptable (meeting requirement M4(2) of The Building Regulations.
3.2.9 The benefits to health of the multifunctional network of green spaces and the exercise they facilitate including, in relation to mental health, are well documented (e.g. MIND “Ecotherapy”). This health value is recognised and protection afforded to open spaces through policies in the Valued Environments chapter. Certain proposals may present health concerns, for example, relating to air or light pollution (Policies 120 and
122) or to the proliferation of hot food takeaways (Policy 98). Where health and wellbeing impacts are apparent they will be considered in light of national guidance and locally recognised health evidence, to assess the health impact on the community.
3.2.10 The NHS Healthy Urban Development Unit (HUDU) has produced a check list to deliver healthy sustainable communities (Watch Out for Health). This assists in the assessment of development proposals contribution to “Lifetime Neighbourhoods” which provide safe, healthy, supportive and inclusive neighbourhoods for people at all stages of their lives. Sport England's Active Design Guidance highlights opportunities to encourage and promote sport and physical activity through the design and layout of the built environment.
3.2.11 The Bromley Health and Wellbeing Board’s 2015 strategy, highlights the important links between health and a range of factors including, housing, green space and employment and access to education, leisure and transport, reflecting the Local Plan vision for high quality environments to ensure healthy, full, independent and rewarding lives. The Strategy focuses on a number of priorities including obesity, hypertension, diabetes, anxiety and depression and the emotional wellbeing of young people, all of which can be influenced by the physical environment. The Strategy responds to the Joint Strategic Needs Assessment (JSNA), which provides an understanding of the current and future health and wellbeing needs of the population. In 2015 the JSNA highlights that two thirds of the borough’s population are termed overweight or obese, a key risk factor for cardiovascular disease and cancer which are top two causes of death in Bromley; that the Borough has, and is predicted to continue to have, the highest number elderly people in London; and that the variation in life expectancy between wards can be as high as 9 years.
Health Facilities
3.2.12 The Council recognises the benefits of providing a range of health care services close to the communities they serve, including doctors and dental surgeries, chiropractors, osteopaths, mental health and other specific health facilities conventional or complementary to meet the needs of the population generally and those of particular vulnerable groups. Planning Practice Guidance advises that local authorities should consider the healthcare infrastructure implications of any relevant proposed local developments.
3.2.13 General Practices can sometimes be accommodated within residential properties without having a significant impact on the amenity of the surrounding residential area. However, General Practices support a wider range of services and many existing premises are unsuitable for this expanded function. Town centres and local shopping parades are likely to provide the most sustainable opportunities for new facilities, where the impact on residential amenity is minimised and there is good access by public transport.
3.2.14 Hospitals and other health facilities within the Borough may also require modernisation, reorganisation or expansion during the plan period. The Council will liaise with the relevant health organisations to support and enable development and improvement of appropriate health care provision and seek planning obligations or contributions through other mechanisms as set out in Policy 125 Delivery and Implementation of the Local Plan.
Education
3.3.1 Local authorities have a statutory duty under the Education Act 1944 to secure sufficient school places within their areas. The Academies Act (2012) changed the approach to educational provision and encourages the establishment of new Free Schools. The National Planning Policy Framework (NPPF) advises that local authorities should “give great weight to the need to create, expand or alter schools”. The current and projected changes in pupil numbers are set out in the Local Plan Education Background Paper (Autumn 2016).
3.3.2 Provision for primary places has been increasing significantly and steadily for the last 6 years, increasing the pupil intake at reception age to date, by the equivalent of over 25 form of entry (FE) - that is the ongoing provision of 25 reception classes of 30 pupils. Expansions to existing school infrastructure and new provision have together provided 16.5 FE with the rest provided in single year ‘bulge’ classes and through new provision in temporary locations. Bulge classes only provide for a single year of entry. These classes are not part of the schools normal roll / published admission number (PAN) and may be sited in non- classroom / communal school space. They do not therefore address a need for permanent form of entry (FE).
3.3.3 The increased pressure for places is now feeding through to the secondary sector.
National Planning Policy
3.3.4 The National Planning Policy Framework (NPPF) (2012) requires local planning authorities to assess the quality and capacity of infrastructure, including education and its ability to meet forecast demands (para 162); and to plan positively for the infrastructure required in the area (para 157).
3.3.5 The Government specifically “attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities” (NPPF para 72). It states that local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education by giving great weight to the need to create, expand or alter schools; and by working with schools' promoters to identify and resolve key planning issues before applications are submitted.
London Plan
3.3.6 The London Plan 2016 highlights local authorities’ strategic role taking a proactive, positive and collaborative approach to development that will widen choice in education, requiring local plans to “secure sites for future provision recognising local needs and the particular requirements of the education sector.” (London Plan Policy 3.18 Education Facilities). It advises that land already in educational use should be safeguarded and new sites secured to meet additional demands or changes in provision and that new schools “should only be refused where there are demonstrable negative local impacts which substantially outweigh the desirability of establishing a new school which cannot be addressed through the appropriate use of planning conditions or obligations”.
3.3.7 The London Plan Policy 3.16 ‘The Protection and Enhancement of Social Infrastructure’, advises that the suitability of redundant social infrastructure premises for other forms of social infrastructure for which there is a defined need in the locality should be assessed before alternative developments are considered.
3.3.8 The Mayor’s approach reflects the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on “Planning for Schools Development” (Aug 2011) which reiterates that there should be a presumption in favour of the development of state-funded schools, as expressed in the National Planning Policy Framework.
3.3.9 London Plan Policy 3.18 (D) advises, in respect of new schools, that they “should only be refused where there are demonstrable negative local impacts which substantially outweigh the desirability of establishing a new school which cannot be addressed through the appropriate use of planning conditions or obligations”. Given Bromley’s preference to encourage the extension of existing schools in the first instance, it is appropriate to apply this standard to extensions to schools.
3.3.10 In response to the increasing demand for school places the Local Plan addresses need by safeguarding ‘Education Land’, enabling necessary expansions and allocating sites, in line with the requirements of the NPPF.
| Policy 27 Education The Council is committed to choice in education for parents and young people and will work, in partnership with agencies and providers, to ensure the provision of an appropriate range of educational facilities to cater for lifelong learning across the spectrum from early years to further and higher education, and including specialist provision. It will achieve this by:
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3.3.11 All sites with permitted use for education purposes, including the sites of schools, colleges and purpose built day nurseries, will be defined as ‘Education Land’ and protected for education purposes for the period of the plan. This includes any future sites where new educational provision (excluding non-purpose built early years provision) is established on a permanent basis. The policy, which resists non education development, including other uses within Use Class D1 of the Town and Country Planning (Use Classes Order) 1987 (as amended), covers all buildings and land within the boundaries of the facility, including, educational and sports facilities, open space, ancillary buildings, car parking areas and access routes within the school boundaries and under the schools control. The designation also includes school playing fields, under the control of the school, but excludes non-school open spaces to which schools have access. The only exceptions to this designation would be land and buildings in use as Free Schools for the temporary period of a year, in response to the changes to the General Permitted Development Order (GPDO). Should permanent permission be subsequently permitted they will be considered to be ‘Education Land’.
3.3.12 In circumstances where alternative, more appropriate, sites are found for a school temporarily located in converted residential or office buildings, the Local Plan ‘Opportunities for Community Facilities’ Policy 21 would allow the reversion to offices or residential use and the safeguarding element of the “Education Land” policy would not be applicable.
3.3.13 Local planning authorities are encouraged to seek to approve applications for sustainable development where possible and work proactively with applicants to secure developments that improve the economic, social and environmental conditions of the area (NPPF para 187). It is therefore important that opportunities to address the pressure for education provision are not refused on grounds where there are potential solutions to mitigate adverse impacts of the development, through planning conditions or obligations,
(e.g. travel plans, highways measures, staggered school hours, landscaping). Where sites are constrained, opportunities to enhance existing facilities by expanding onto adjacent sites will be supported, subject to the policy. Given the ability of schools to be established on sites without their own playing fields it will be important that open spaces indicated to provide this function are protected, since patterns of physical activity established in childhood can be a key determinant of adult activity levels and therefore influence physical health.
| Policy 28 Educational Facilities The Council will support proposals for new educational facilities which meet local need, looking first at opportunities to maximise the use of existing Education Land or redundant social infrastructure. Where new sites are required, proposals will be permitted unless there are demonstrably negative local impacts which substantially outweigh the need for additional education provision, which cannot be addressed through planning conditions or obligations, and subject to:
Where Free Schools have operated from buildings for a year under “Permitted Development” (Part 4, Class C of The Town and Country Planning (General Permitted Development) (England) Order 2015) (GPDO), and, having been unable to secure a more appropriate location, are required to seek planning permission to remain permanently, applications for planning permission, will be supported subject to compliance with the limited requirements under Part 3 Class T of the GPDO, which enables permanent changes of use. In all cases new buildings should be sensitively designed to minimise the footprint, loss of open space and the impact of development, seeking to secure as far as possible the privacy and amenities of any adjoining properties, whilst delivering the necessary educational infrastructure. Proposals involving the sharing of facilities, including open spaces, between educational facilities, and / or the dual use of educational facilities by the wider community will be encouraged. |
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3.3.14 Whilst acknowledging the freedoms of Academy and Free Schools, applicants will be expected to:
3.3.15 The London Plan notes in Policy 3.16E that where a social infrastructure facility is no longer needed, boroughs should take reasonable steps to identify alternative community uses where the needs have been identified. Providers should look to explore opportunities presented by redundant social infrastructure when considering locations and demonstrate that investigations have been made when submitting applications for new educational sites.
3.3.16 There will be circumstances where sites unrelated to existing educational facilities or community facilities are proposed by Free School providers. As highlighted above it is important that opportunities to address the pressure for education provision are not refused on grounds where there are potential solutions to mitigate adverse impacts of the development, through planning conditions or obligations. Such mitigation may involve travel plans, highway measures and the consideration of "Healthy Routes."
3.3.17 Free Schools may operate for their first academic year from buildings with a range of previous uses under permitted development rights [The Town and Country Planning (General Permitted Development) (Amendment) (England) Order 2015 )(GPDO) Part 4 “Class C”]. Should the Free School be unable or unwilling to relocate planning permission will be required to remain on that site. Where there is no potential to relocate to a more appropriate site it will be important to ensure the on-going education of children at the Free School. In such instances it would be appropriate to consider the continued use of the temporary site on a permanent basis against the limited requirements of the GPDO Part 3 Class T prior notification procedures, which enable the permanent change of use to a school from a range of previous uses (but not including the temporary use as a Free School).
3.3.18 Where a proposed new education facility lies sufficiently close to an existing educational facility, or other community facility to enable the dual use of facilities, co-operation between providers to produce co-location of services and multi-use facilities will be encouraged in order to maximise land use, reduce costs and develop the educational offer, in line with the London Plan (Policy 3.18 F).
3.3.19 Educational land and buildings have considerable potential to contribute to the provision of community facilities. Many schools already allow outside organisations to make use of their sports facilities and grounds. The Council wishes to encourage schools and other educational establishments to maximise the contribution their buildings and grounds can make to the local community.
Assessing Need for Provision
3.3.20 The Council’s Primary and Secondary School Development Plans detail the need and strategic planning for school place provision in the borough. The most recent versions of these plans were approved by the Council in January 2016 and form part of the Local Plan’s evidence base. Need is expressed in ‘Forms of Entry’ (FE), entry age classes of 30 children.
3.3.21 Pupil place projections take into account a range of factors. However, the dependence upon birth data combined with recent migratory changes between London boroughs, has made predicting primary need harder and more difficult to manage than secondary provision, for which there are longer lead in periods.
3.3.22 Pupil place projections produced by the Greater London Authority (GLA) can fluctuate from year to year being based on a number of factors including the previous year’s population projections and historic birth data. The result is a lag period of a couple of years with 2015 projections based on children born in 2013. In recent years the primary school projections have significantly underestimated the published admission numbers (PAN).
3.3.23 Whilst these fluctuations and anomalies can impact rapidly on primary provision, there is a longer time frame to recognise and adapt to changed circumstances to address secondary provision.
Local Plan Approach to Meeting Need
3.3.24 The Local Plan education policies reflect the NPPF and the London Plan and state that the Council will ensure provision of an appropriate range of educational facilities by assessing the need over the plan period and allocating sites accordingly.
3.3.25 The overall strategy in the School Development Plans has been to meet forecast growth through a combination of 'bulge' classes, permanent expansion of existing provision and new schools.
3.3.26 As options to expand the existing infrastructure to meet the local need reach exhaustion, the Local Plan employs a range of approaches to address the education needs over the plan period, specifically through:
Expansions of Existing Schools
3.3.27 The Local Plan policies, reflecting national and regional policy, require that the Council will look first at opportunities to maximise the use of existing Education Land or redundant social infrastructure in line with other community facilities / social infrastructure policies. In order to deliver sustainable site options, and acknowledging the changes to education delivery noted above, the approach to the expansion of existing provision and to new site allocations follows a site assessment and sequential approach, set out in the supporting ‘Education Background Paper’. Such an approach ensures consistency, accessibility and transparency, as required by the National Planning Policy Framework. It considers the range of planning designations and sets out a robust approach to assess the relative merits of sites for additional education provision - (information regarding the planning status of proposals identified in the tables within this chapter reflects the situation as at Autumn 2016).
Open Space Designations
3.3.28 Larger school sites in Bromley tend to be covered by open space designations, with the 17 undesignated sites generally smaller, making school expansion particularly challenging. Permanent additional places or bulge classes are already being provided at a number of these undesignated sites and the feasibility of expansion explored at others.
3.3.29 All except one of Bromley Secondary schools have some form of open space protection. The Secondary School Development Plan 2015 – 18 suggests secondary provision expansions on the three school sites identified in Table 9, to provide an additional 3FE, alongside 2FE at Bishop Justus which already have planning permission.
Education Organisation Planning
3.3.30 For any expansion of existing educational/school infrastructure sites, consideration needs to be given to the proximity from which schools attract pupils in relation to demand. Many Bromley primary schools have small proximities, often less than ½ mile from the school. For pupil place planning purposes the Borough is organised into nine Education Planning Areas (EPAs).
3.3.31 The deliverability of any expansion proposal is also affected by educational and operational factors, notably the size of the existing intake, the site and existing accommodation, specific admission criteria, (e.g. faith) and the legislative education landscape post the Academies Act 2010. Academies are state funded schools, independent of local authority control, and therefore expansion proposals to address need require strong partnership working. All of Bromley’s 17 secondary schools, are academies. Eighty-eight percent, that is 65 of the 74 Bromley primary schools are academies either converting to, or exploring conversion, to academy status.
3.3.32 The provision of new schools is through the Free School process. Free Schools can be delivered through two routes: Government funded whereby founding groups, including parents, education charities and religious groups, submit applications to the Department for Education on the basis of parental demand to meet local need, or the ‘presumption route’ whereby the Local Authority funds the new school and runs a competition to choose a provider. As such the desired location of new schools can be difficult to anticipate, however the projections set out in the evidence base indicate that the primary school need is substantially to the north, northwest and centre of the Borough in Education Planning Areas (EPA)1-4, and this demand is generally reflected in the locations of Free School proposals coming forward.
3.3.33 Secondary school need is less localised and in theory is more 'footloose', however, the circumstances surrounding some of the specific Free School applications to the Secretary of State for Education have a particular locational focus.
Sites for New Schools
3.3.34 In addition to considering existing education and social infrastructure sites the Local Plan Draft Policies and Designations consultation document (February 2014) also included a “Call for Sites” for a range of uses. Assessments were made of these sites and sites identified by proposed Free School providers, some specifically referenced in their submissions to the Secretary of State for Education. The full site assessment methodology and results are set out in the 'Education Background Paper' which accompanies the Local Plan.
Recommendations and Sites for Allocation
3.3.35 The site assessment undertaken (set out in the Education Background Paper) demonstrates that proposals for new sites are the most sustainable locations for school development, having regard to the limited availability of appropriate sites and the national and regional guidance in respect of the “great importance attached to ensuring sufficient choice of school places”.
3.3.36 The constraints of the sites have been assessed and they are considered to provide realistic opportunities for school development to address the current and projected need for education facilities. There will, as part of subsequent planning applications, need to be robust assessments of the impacts, including, for example, highways implications, and appropriate mitigation and conditions attached if planning permission is to be achieved.
3.3.37 The site assessment process highlights the necessity to fully explore all potential policy complaint sites before other sites are considered, particularly where these involve release of Green Belt or Metropolitan Open Land, which require the demonstration of “exceptional circumstances”.
Education Need: Primary Schools
3.3.38 The need for primary school places based on projections is summarised below and indicates a requirement for a further 14.6FE, proposals for which are identified within this plan, to meet the projected need over the next 5 years. Projections beyond this time frame will be subject to future assessment but the Primary School Development Plan indicates where medium and longer term pressures might be addressed.
| Table 1 Primary Education Summary | ||
| Timeframe | FE | Comment |
| Current permanent FE | 133.5 | Includes 16.5 additional FE provided over the past 6 years |
| Need (5 year supply to 2021/22) | 14.6 | 9FE backlog (currently provided through bulge classes and a Free School without a permanent location), and 5.6FE additional to 2021/22 |
| Need for the following 9 yrs of the plan (to 2030/31) | 4.1 | Beyond 5 year timeframe the projections become less robust and further assessment will be required but 4.1FE provides approx 3% allowance for the period to 2030/31 |
| Total Need over the Local Plan period | 18.7 | See Table 2 (reflecting the Primary Schools Development Plan 2016) |
| Proposals in the Local Plan to address need | 16.5 – 19.5 | See Tables 3, 4 & 5 |
| Table 2 Education Need – Primary Schools | |||
| Current Outstanding need for permanent FE | Further 5 year need up to 2021/22 | Need for the remainder of the plan to 30/31 | Total Need over the Local Plan period |
| 9FE | 5.6FE * | For future Assessment** (4.1FE) | 18.7FE |
| Need to address 5 year supply 14.6FE | |||
Notes: *based on the projected increase in pupil numbers (2014 projections) ** 2014 projections indicate a further 4.1FE
3.3.39 Between 2009 and June 2016, 16.5 additional FE have been granted planning permission, however there remains an outstanding need for 9FE as set out in Table 2 which also indicates the projected need to meet the 5 year supply and the need for the period beyond 2021 to the end of the plan. Whilst the projections indicate a need for a further 4.1 FE to 2030, the projections are less robust for this later period and will be subject to further future assessment.
3.3.40 Table 3 summarises the proposals to meet the 5 year supply and the need for the identified above. Details of individual schools identified in the Primary School Development Plan (2015) and Local Plan proposals are set out in Tables 4 and 5.
| Table 3 Primary school proposals to address the 5 year supply and provision over the Local Plan period. | |||
| Primary School Proposals | 5 year supply to 2020/21 Sites proposed or being explored | 5 years – 15 years (to 2030) –potential to bring forward | Proposals in the Local Plan to address need |
| Extensions to Existing (see attached extract from Table 4) | 5.5FE |
6FE |
11.5FE |
| New Schools (see attached extract from Table 5) | 4FE (2 schools) |
1 – 4FE * |
5 – 8FE |
| Total | 9.5FE |
7 – 10FE |
16.5 – 19.5FE |
Note * includes 2FE at BET (also highlighted as potential extension to existing Alternate Provision or new secondary school) and Bushell Way (which if used by relocating existing 1 FE school would only add a single FE)
| Table 4 Proposals to meet primary need (Expansions to Existing Schools) | |||||
| Expansions to Existing Schools (subject to Academy agreement) | Forms of Entry (FE) | Designation | Local Plan Proposal (in addition to Education Land designation) |
Ward (Education Planning Area in brackets) |
|
| Proposed | Medium / Long term | ||||
| St Johns | 0.5 | none | (1) Penge and Cator | ||
| James Dixon | 1 | MOL | redesignation | (1) Crystal Palace | |
| Marian Vian | 1 | none | (2) Kelsey and Eden Park | ||
| Wickham Common | 1 | Green Belt | redesignation | (3) Hayes and Coney Hall | |
| Scotts Park | 1 | MOL | redesignation | (4) Bickley | |
| Farnborough | 1 | Green Belt | (5) Farnborough and Crofton | ||
| Edgebury | 1 | Green Belt | redesignation | (6) Chislehurst | |
| Leesons | 1 | UOS | (7) Cray Valley West | ||
| Midfield Site | 1 | Green Belt | redesignation | (7) Cray Valley West | |
| Poverest | 1 | UOS | (7) Cray Valley West | ||
| St Mary Cray | 1 | None and Green Belt | redesignation | (7) Cray Valley East | |
| Blenheim | 1 | UOS | (8) Orpington | ||
| Oaklands | Proposed expansion to meet existing need | Green Belt | redesignation | (9) Biggin Hill | |
| Sub totals | 5.5 | 6 | |||
| TOTAL | 11.5 | ||||
Note: a further 12.5 FE already have planning permission at other existing primary schools
| Table 5 Proposals to meet primary need (New Schools / Sites) | ||||
| New Free Schools / Sites | Potential Forms of Entry (FE) | Designation | Local Plan Proposal (in addition to Education Land designation) | Ward (Education Planning Area in brackets) |
| Langley Park Schools (Langley Schools site) | 2 | MOL | redesignation and allocation | (2) Kelsey and Eden Park |
| La Fontaine (Widmore Centre) | 2 | UOS | allocation | (4) Bickley |
| Bromley Education Trust (BET)*, Hayes Lane | 2 | Green Belt | redesignation | (5) Bromley Common & Keston |
| Bushell Way | 2** | UOS / SINC | redesignation and allocation | (6) Chislehurst |
| TOTAL | 5 - 8 | |||
Note: a further 4 FE already have planning permission at permanent sites for 2 new Free Schools *Bromley Education Trust also identified as potential secondary Free School Site
** only 1 if Chislehurst St Nicholas relocation
Education Need : Secondary Schools
3.3.41 The growth trend experienced in the primary sector is now being felt in the secondary sector which exceeded the capacity of the existing infrastructure in 2015, resulting in the provision of 3 bulge classes at existing secondary schools.
3.3.42 The Council’s “Secondary School Development Plan 2015 – 18” (January 2016) indicates that in 2015 there were insufficient places in secondary schools within a reasonable travelling distance resulting in the provision of bulge classes. The plan highlights that by 2018 / 19 there will be a need for 17 additional FE and a further 17 FE by 2022. Currently an additional 2FE have planning permission, there is therefore a pressing need to make allocations for secondary school provision.
3.3.43 In the Secondary School Development Plan two secondary Free Schools, Eden Park High School (formerly referred to as The Beckenham Academy) and Bullers Wood School for Boys are identified as providing 12FE although no sites currently have planning permission. Additionally a University Technical College (UTC) originally intended for 14+yrs has received ministerial approval to take pupils from 11yrs.
3.3.44 From 2022/23 to the end of the plan period the projections become less reliable. Proposals to meet the short term need, five year supply and provision for the remainder of the plan period are set out in Table 7 and 8. Details regarding the individual schools and Local Plan proposals are set out in Tables 9 and 10.
| Table 6 Secondary Education Summary | ||
| Timeframe | FE | Comment |
| Baseline (2014/15) | 118.8 | |
| 7 year supply (need to 2022/23) |
32 | Based on the Secondary School Development Plan (2016) |
| Need for 2023/24 – 2030/31 | 2 | |
| Total Need over the Local Plan period | 34 | See Table 7. |
| Site proposals in the Local Plan to address need | Up to 37 (dependent on school size) | See Tables 8, 9 & 10. Up to 21FE without Green Belt releases for which exceptional circumstances must be shown (including 4FE on the Kentwood site). |
Table 7 summarises the proposals to meet the 7year supply and the need for the Local Plan period. The Secondary Schools Development Plan (2016) indicates a need for an additional 34 FE by 2022/23, half required within the next 2 years (2FE have been permitted). The projections indicate a further requirement for 2 FE for the remaining 8 years of the Plan.
| Table 7 Education Need – Secondary Schools | |||
| Need by 2018/19 | Need 2019/20 – 22/23 | Need for the remainder of the plan 2023/24 – 30/31 | Total Need over the Local Plan period |
| 15FE | 17FE | 2FE | 34FE |
| Need to address 7 year supply 32FE | |||
3.3.45 Table 8 indicates proposals to meet the need with details of individual schools set out in Tables 9 and 10. Whilst the Local Plan can identify sites the provision of Free Schools is outside Local Authority control. As indicated in Table 8, sites offering some 20FE could be brought forward earlier in the Local Plan period, subject to Free School proposals coming forward or the Local Authority seeking a Free School provider in order to address the need in the short term.
| Table 8 Secondary school proposals to address the short term need, provide a 7 year supply and provision over the Local Plan period. | |||
| Secondary School Proposals | 7 year supply to 2022/23 | 8 years – 15 years (to 2030) Potential to bring forward | Total proposals in the Local Plan to address need |
| Extensions to Existing (see attached extract from Table 9) | 3FE | 3FE | |
| New schools / allocated sites(see attached extract from Table 10) | 12-14FE (Free school proposals) |
Up to 20FE | Up to 34FE |
| Total | 15- 17 FE | Up to 20FE | Up to 37FE |
Notes - Bromley Education Trust, Hayes Lane (BET) also indicated as potential extension to existing Alternate Provision or new primary school. Catholic Secondary school aspiration (currently no site proposed)
| Table 9 Proposals to meet secondary need (Expansions to Existing Schools) | ||||
| Existing School Sites (subject to Academy agreement) | Potential additional FE | Designation | Local Plan Proposal | Ward |
| Chislehurst School for Girls | 1 | Green Belt | Education Land designation (existing open space designation retained) | Chislehurst |
| Ravenswood | 1 | Green Belt | Bromley Common & Keston | |
| Darrick Wood | 1 | UOS | Farnborough & Crofton | |
| Total Expansions to Existing Schools | 3FE | |||
3.3.46 Expansions to existing secondary schools have the potential to deliver an additional 3 FE. No alterations to Green Belt are proposed at the two identified sites, which are embedded within the Green Belt. It is considered likely that a single FE addition to a secondary school could, subject to design, be consistent with the exceptions to “inappropriate development” as set out in para 89 of the National Planning Policy Framework.
3.3.47 Table 10 indicates sites proposed through allocations / redesignations in the Local Plan to facilitate proposals to meet secondary need.
| Table 10 Proposals to meet secondary need (New Schools / Sites) | |||||
| Sites | Potential School | Potential FE | Designation | Local Plan Proposal (in addition to Education Land designation) | Ward |
| St Hugh’s Playing Field | Bullers Wood School for Boys | 6 | UOS | Allocation | Bickley |
| 1 Westmoreland Rd | Bromley Technical College | 6 - 8 | none | Allocation | Bromley Town |
| Widmore Centre | Potential primary school site | - | UOS | Allocation | Bickley |
| Kentwood Site | Expand age range or new school (subject to academy support) | 4 | UOS | Allocation | Penge and Cator |
| Turpington Lane Allotments | 6 - 8 | Green Belt | Redesignation and allocation (Non Green Belt / MOL sites above having been prioritised for allocation) | Bromley Common & Keston | |
| BET Hayes Lane | - | Green Belt | |||
| Land adj Edgebury Primary | 8 | Green Belt | Chislehurst | ||
| Total New Allocations / New Free School | Up to 34FE (up to 14FE without Green Belt re-designation) - none have currently permitted sites | ||||
Notes Bromley College have ministerial approval for a University Technical College (initially 14yrs+ but now amended to enable intake from 11yrs - this provision may come forward on 1 Westmoreland Rd). BET – or potential expansion of existing alternative provision or primary Free School Site.
Specialist Educational Facilities
3.3.48 There will additionally be requirements over the plan period for specialist educational facilities, including alternative provision for pupils who, because of exclusion, illness or other reasons, would not otherwise receive suitable education. Proposals to address these additional requirements are set out in Table 11.
| Table 11 Proposals to meet other educational (New Schools / Sites) | ||||
| Site | Potential | Designation | Local Plan Proposal (in addition to Education Land designation) | Ward |
| 1 Westmoreland Road | UTC (with ministerial approval) | allocation (note may come forward as secondary age 11yrs+ provision) | Bromley Town | |
| BET Hayes Lane | Expansion of Alternative Provision | Redesignation and allocation | Bromley Common and Keston | |
| Midfield Site | Expansion of Alternative Provision or Special School | Green Belt | Redesignation and allocation | Cray Valley West |
| Burwood | Social, Emotional and Mental Health Specialism | Urban Open Space | Orpington | |
Note BET - also potential new primary or secondary school
| Policy 29 Education Site Allocations Subject to Local Plan Policy 27 ‘Education’, the Council will seek to meet the need for education provision over the Local Plan period as identified in the Council’s Primary and Secondary School Development Plans, by allocating sites for educational purposes and re-designating school sites in Green Belt and Metropolitan Open Land as Urban Open Space (as indicated in tables 3,4,7,8 and 9 illustrated and on the "Location of sites identified as allocations or involving re-designations to facilitate new or expanded education provision" Map and detailed in Appendix 10.4)
|
Supporting Text
3.3.49 Bromley’s Primary and Secondary School Development Plan 2015 identifies proposals to address the current and projected need for primary and secondary education. Many of these proposals will be dependent upon the co-operation of the individual schools, the majority of which are academies (outside local authority control).
3.3.50 The National Planning Policy Framework (para 72) advises that local planning authorities should take a proactive, positive and collaborative approach to meeting sufficient choice of school places advising that they should give great weight to the need to create, expand or alter schools; and work with schools promoters to identify and resolve key planning issues before applications are submitted.
3.3.51 Proposals will be subject to detailed planning applications, and will be subject to other requirements of Local Plan, notably the “General Design of Development” Policy
37. Robust assessments of the impacts of development on the locality will be required and proposals will need to satisfactorily address the full range of site specific constraints presented by each site, for example,
• Turpington Lane Allotments
3.3.52 Should proposals impinge on currently utilised allotments along the indicated boundary (up to a maximum of 4 plots along the southern boundary), it will be necessary to relocate the plots on-site to the satisfaction of the Council, over an acceptable time period, including any necessary drainage works. It will also be necessary to provide appropriate access and turning head arrangements for use by the allotment holders.
• Bushell Way
3.3.53 Proposals will be required to mitigate impacts on biodiversity, minimise the impact on trees ensuring a buffer to adjacent properties, maintain and enhance public access from Bushell Way through to the public open space known as “Walden Woods” and address the requirements for appropriate buffer around and access to energy infrastructure.
• Kentwood
3.3.54 Proposals, which would be subject to the agreement of the leaseholders (Harris Primary Academy Kent House), will be required to reprovide the existing education provision (primary and adult education), either on site or on appropriate, accessible, alternative site or sites within the locality (see also Policy 20 Community Facilities).
3.3.55 Detailed maps of the sites identified in Policy 29 for education purposes are set out in Appendix 10.4. All alterations to the Green Belt or MOL for education purposes involve re-designation as Urban Open Space and are protected from all other forms of development under the Local Plan Education Policy 27 for the lifetime of the plan.
Location of sites identified as allocations or involving re-designations to facilitate new or expanded education provision
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