Children, Families & Schools Committee

Agenda Item 45(c)


Subject:                    Public Involvement – Deputations


Date of meeting:    22 January 2024



A period of not more than fifteen minutes shall be allowed at each ordinary meeting

of the Council for the hearing of deputations from members of the public.


The spokesperson is entitled to speak for 5 minutes.


1. Reduction of Published Admissions Number at St Luke’s Primary School


Supported by:

Chloe Taylor

Justine Stephens

Kevin Holland

Simon Wattam

Kirsty Wilson

Ruth Hilton

Davina Christmas

Gillian Bourne

Barry Ling

Rose Roberts

Lara Havelock


On behalf of the children of East Brighton we want to express our concern about the proposal to reduce the pupil admission numbers at St Luke's Primary School from 90 to 60.

St Luke’s is a unique school. We have an outstanding Ofsted rating and our children achieve high academic results, but St Luke's is more than this: it is defined by its distinctive approach to learning, inspired by academic research. At St

Luke's, everyone is known by their first name, we don't have a school uniform, and we emphasise strong relationships over behaviour management. We expect our children to leave St Luke’s with strong critical thinking skills, and a good

understanding of their own identity and their place within a wider community.


St Luke's contributes heavily to BHCC education policy and practice. Its status as a larger school means it has the resources to develop curricula and to explore new ways to teach and learn. The PSHE curriculum used across Brighton

and the anti-racist strategy currently being rolled out were both developed at St Luke's. Initiatives like these are under threat by the PAN reduction proposals- St Luke's will not have the resources to continue to provide support to the wider

educational community in Brighton and Hove if they are forced to reduce their admission numbers. Parents and carers choose our school for many reasons, but when we spoke to the community about what St Luke's means for them, it is clear that many families select St Luke's for its excellent provision for the most vulnerable. For example, St Luke's has a dedicated member of staff who looks after the needs of the children in care or post care. Her expert knowledge of attachment theory facilitates these children developing into confident, happy, secure individuals, ready for secondary school and the wider world. It is hard to imagine where these children would be without her. The specialist music teacher at St Luke's does more than cover classes. He ensures that every disadvantaged child in the school has access to high quality music education above and beyond the statutory curriculum, particularly focussing on enabling and encouraging children to take part in activities such as choir, samba band or guitar lessons, giving them access to a world usually occupied by the more privileged. Yet his role is the kind of provision that would be threatened if St Luke's funding were to be cut. Using its own budget, St Luke’s provides a sensory space, 1-2-1 counselling, CBT and learning mentors among a host of other support mechanisms focussed on achieving the best outcomes for all pupils. We even extend our support to families by facilitating a supportive network of parents and carers. The provision for SEND and neurodiverse pupils is particularly strong, even for those who have been unable to access a diagnosis or statement, thus enabling our pupils to remain in mainstream education and relieving the pressure on the Local Authority services.

When you read through the consultation documents you will read several stories of how the school has transformed the lives of individual children. The effect of the school's efforts to support these pupils is not just anecdotal, it is backed up by

our results: disadvantaged children at St Luke's achieve well (eg see table- KS2 results). However, the facts are stark: the school cannot continue to offer this high level of provision for the most vulnerable children if it becomes a two form entry

school. It simply will not be able to afford it. There is no doubt in our minds that reducing the PAN at St Luke's would frustrate parental choice. St Luke’s has

consistently been oversubscribed and the projected numbers show that it will continue to be very much in demand. St Luke’s and Carlton Hill together are projected to have a minor deficit by 2026 of just 10 children and there are several

families who live in the ‘BN21’ postcode (Kemp Town) that don’t fall into the catchment area of any primary school that may wish to select St Luke's. For many families, such as those living North of the school on the Pankhurst Estate, St Luke's is the only local school. These families live on the edge of the traditional St Luke's 'catchment' and are highly concerned about the possibility of not being offered a place should the numbers be reduced. Families from these areas would need to travel further to alternative schools, some presumably as far as the Lewes Road. This would be a long journey to a school outside their local area for our most disadvantaged families. Again, it will be the most vulnerable in our community that would suffer should the PAN reduction go ahead. Other concerns we have are around the process of this consultation. Firstly we are troubled by the transparency of the process of selecting schools for a reduction in PAN. Given that St Luke's is virtually full in every year group, expects to be oversubscribed next year, and has a sound financial position, it is hard to understand why we have been selected at all.

We emailed several councillors to ask for the selection criteria. We received the reply: 'There is no single set of criteria used to decide which schools should be considered.' so we are still unclear as to whether multiple sets of criteria have

been used, and if so which have been applied to St Luke's, or whether our selection was random. We are extremely concerned about the timeline and the heightened pressure that will place on members of the committee. There are only three working days between the closing date and the committee meeting, in which such huge decisions about the provision of education for children in our city will be made. We know that over 600 submissions have been made already, with many more to come. It is clear to us that it is an unrealistic expectation to instruct members of the committee to properly and fairly assess all submissions. In addition, there are no members of the committee from our local area, and so they will not have the background local knowledge to understand the devastating impact on our community should these proposals go ahead. We hope that these proposals are rejected at the committee meeting in January. Meanwhile, we are preparing to make our representations to the schools adjudicator. We urge you to consider removing St Luke's from this proposal.


Supporting information:


Table showing KS2 results 2019, 2022 and 2023 for disadvantaged children.

St Luke's pupils consistently in line with, or above, the LA and national average.































2. Deputation concerning the legal obligations of the Local Authority/Council relating to equalities during the consultation into the proposed closure of St Bartholomew’s CE Primary School


Supported by:

Katie Blood

Keely Levy

Leanne Wulitich

Emily Thomas

Tessa Pacey

Rachel Christie-Davies

Azhar Naeem


This deputation concerns the legal obligations of the Local Authority/Council relating to equalities during the consultation into the proposed closure of St Bartholomew’s CE Primary School

In order to fulfil their legal obligations in relation to equalities, the Local Authority conducted an Equalities Impact Assessment (EIA), as part of the consultation process following proposals to close St Bartholomew’s CE Primary School. The EIA itself may not be statutory but this was the method chosen by the LA to show that they were fulfilling their legal duties in respect of their Public Sector Equality Duty.

However, it seems that this Equalities Impact Assessment (EIA) may not have met its intended purpose, as it deviated from the council's established procedures for EIAs, and the decided actions outlined in the EIA were left incomplete by Local Authority Officers. Consequently, this raises doubts about the legal fulfilment of the Local Authority's equalities duties. If not rectified, it could be inferred that the consultation process lacked equity for stakeholders and, as a result, might be deemed invalid.

Because our school is one of the most diverse schools in Brighton, and considering the significant intersectionality present among our students' vulnerabilities, the LA fulfilling its equalities duties is of significance for our community. If the tool used by the LA has not been appropriately deployed, it may be that our families have been discriminated against.

We therefore urge an independent review of the consultation process to verify its compliance with the Council's Public Sector Equality Duties. Further, if necessary, we would recommend the consultation process be re-started and conducted with a rigorous approach to equalities and inclusion before any further decisions are made concerning the closure of St Bartholomew’s CE Primary School.













3. Closure of St. Peter’s School and Nursery


Supported by:

Emily Brewer

Anika Carpenter

Carol Ward

Kim Enticknapp

Leanne Pocock

Laura Whittington

Alice Keogh

Lucyna Taylor

Patricia Sacre

Kylie Wakeford


The winter of discontent growing within the community

The closure proposal for St Peter's School and Nursery has ripped the heart of our

community. This 117-year-old school and nursery has inspired generations, even

welcomed a Labour Prime Minister, and has been a part of this city throughout modern history. Its inclusivity is a shining example of what schools could be like – nurtured, warm, and inspiring.


This closure proposal is the backdrop of what our country faces – and the families are at the sharp end of years of cuts and austerity. We didn't ask for this; we work, raise our children, pay our taxes and vote for parties we believe in, hoping they have our backs and our children's. Just your everyday citizen trying to get on with life quietly.


When you put your faith into parties who campaign on the importance of Early Years and Education, we believe it. Whether that's naive of us, only time will tell. Nevertheless, we hope to do the right thing by getting behind the people we think could make a positive

change. Sentences like "increasing preschool provision" and "protecting schools from closure in outlying areas of the city" are unambiguous. There is an intent to help working families with affordable nursery provision and secure the future of schools wherever they are. Now, we know there are debates about whether it's about secondary education. Still, there is no explicit detail that dictates this. A failure of clarity to the public. In the autumn, we have the chance to express our feelings – to get behind people who will make a change – and who demonstrate that they are honest and keep to their word. A school closure in August will be the perfect time for a community to express not just how they feel nationally but locally, too. Decisions made on a council level as well as a political level will be taken into account seriously. Faithful supporters who don't believe a party will follow through will start to second guess their choices – and those who doubt will vote with their feet. Nothing is a given in politics, no seat secure, but one thing's certain: the

community will still be here – and we will still be voting.






4. Consultation on the closure of St Peter’s Community Primary and Nursery School


Supported by:

Kirsty Moore

Vanessa Worgan

Stephen Taylor

Pierre Sacre

Tom Williams

Annie Farrant


I am here today to talk about St Peter’s Community Primary and Nursery school, our 117 year old historical school which the Labour Led Brighton and Hove city council want to unrealistically close by the end of the academic year.

I am here to talk about the faults, the neglect and the broken promises of this consultation.

6 - 7 months ago, families of south portslade received leaflets through their door during an election with labours Promises from the party on.

These promises from Labour Party specifically included

• Keeping schools open

The pledge reads “We will look at changing catchment areas to protect schools facing closure, particularly in outlying areas”.

St Peter’s as many know is on the boarder of Brighton and Hove and West Sussex county council, with half of the schools boarder being the sea. so the school itself is automatically disadvantaged loosing half of it’s proximity to the sea.

• The early years

The pledge reads “Labour council will look to increase the city’s provision for pre-school children and seek to maintain council-run nurseries wherever possible”.

St Peter’s is the only Local authority run nursery left in south portslade it has been apart of our school since 2000, when it was opened by a still serving member of support staff and the longest serving LABOUR prime minister Tony Blair came to celebrate the opening. But is completely dismissed off the proposal despite it having a huge affect on the families that use the nursery. That nursery school you miss out in your proposal has seen a 70% increase of students since 2022, this shows there’s a real demand for affordable preschool provision now. It seems absolutely bizarre to shut it. You say there is adequate provision, but you are not thinking about affordability & sustainability which is a major factor for parents who use St Peter's nursery. These pledges of course won the vote for Labour on the two main promises they made to the community. The families who use St Peter’s were happy Thinking such a special asset of the community would be protected with these promises. However fast forward 7 months, that has now been twisted and taken away with in less than a year!

Consultations were held, who’s to say they were real or not? To us as a community it feels all of our concerns around the school closure have been ignored.

This includes

• The nursery provision of St Peter’s, the wrap around care it offers for working families at cheap rates and the 30 hours funding it accepts which not many other do alongside the wrap around care.

• The damage it will cause to children- children who have already had their schooling majorly disrupted by covid and multiple lockdowns.

• The lack of surplus SUITABLE spaces within 1 mile. The limited availability of places will have an environmental and financial impact. Expecting families to travel up to 2 miles is in breach of the Department of Education’s closing schools’ policy regarding increased travel costs, long journey times, and increased use of cars due to the discontinuance of the school and preschool. The proposed arrangements for travel of displaced pupils to other schools including how the proposed arrangements will mitigate against increased car use. The impact of travel, the financial implications for families, and environmental factors have not been assessed. The closure would drive up all of these elements.

Whilst it’s ok Brighton and Hove council saying there are school places available, but they are missing out the fact that many parents have raised concerns regarding whether they are suitable and can accommodate their children’s needs, a high number of students who attend St Peter’s Are SEND. My daughter included who has found this whole ordeal incredibly traumatic. I myself have struggled greatly to find a school with availability for my two children within region of my youngest daughters nursery because, funnily enough I don’t want to disrupt all 3 of my children’s education, and the lack of available affordable nursery around the area is slim. Brighton and hove council have failed these children, and these families have been left in crisis without adequate support. They have failed to address the border of West Sussex, in which half of the school come from because they say and I quote “its not their problem”. but families of West Sussex have been unsuccessful getting support from their council also regarding this matter. The council have failed to address my 3 closest schools. Because there are huge waiting lists for these schools of up to 3 months. Maybe more depending on demand. This is neglect and we will not forget this. We as a family are struggling, before this

proposal we were actually midway through a legal battle regarding our sons tragic death however due to this current situation I have had to withdraw everything for the time being meaning I will have to live through the trauma again when I decide to reopen my case, this is because I don’t have the headspace for that aswell as, supporting my two children struggling with their safe haven being taken away and possibility of loosing all their friends and amazing teachers they’ve been through tough times of covid with. It’s not as simple as making new friends, for my daughter she uses her friends as a way of being able to communicate with teachers, it will take years for her to build up trust with new friends to be able to do this meaning we will have to live through years of anger, upset, frustration and refusal.

There’s a famous saying that says “if it isn’t broke, don't fix it” and that is the case here. Leave our school alone, let our children have the education they are entitled to.


I don’t really have anything else to say on this matter other than, Shame on you all.











5. Deputation on Behalf of the Governing Body of St Peter’s Community Primary School and Nursery


Supported by:

Daniel Chard

Michael Nicholls

Scott Haywood

Colette Lynch

Jeffery Zroback


The leadership of St Peter’s Primary School and Nursery are concerned that the draft report and recommendations being discussed at this meeting are severely lacking in the following areas.


A - The alternatives to closure presented by the school (3.29-3.33) to the LA have been inadequately and misleadingly presented in this report in the following ways:

1. The report states that the school did not address how to increase pupil numbers to 210. However, the school understands the wider context of falling pupil numbers in the city and is not proposing to return to 210, but rather, to adopt a new structure of mixed-age classes which would contribute to the overall reduction of the city’s places, while also bringing the school into financial viability.

2. The report states that the rent for part of the site is decided year on year and support from the Schools Forum for this cannot be guaranteed – this has been the case historically so there is no change to this within the budget submitted by the school. Further, the school is proposing to find ways to operate without this part of the site in the future, as it did prior to its expansion by the LA from an Infant into a Primary school.

3. The proposals for a smaller school would require a new structure, and the report raises concerns about the viability of delivering a good quality of education as a smaller school. However, the report itself states that this aspect of school improvement is ‘untested’ and so this should not be assumed to be a reason not to explore this alternative. Indeed, the support that has come through the Orchard partnership, the cost of which has contributed to the school’s current deficit budget position, has up-skilled the leadership and teaching staff. Note also that St Peters has proposed that it will be moving away from the Orchard Partnership as part of its revised structure and cost reduction measures.

4. Point 3.46 addresses nursery provision, stating that the council ‘has begun discussion with other schools about the potential of opening governing board led nursery provision to maintain a similar offer to that at St Peter’s. The alternative structure presented by the school includes development of what is already a successful nursery provision which is well regarded and loved by parents and carers in the community.

B - The procedure for consultation and preparation of the report has been inadequate and reflective of a council position whereby this decision is already a ‘done deal’. We note that other authorities, for example and very recently, Hackney, commissioned a third party to review their initial consultations. We have repeatedly raised concerns regarding the right turn around and are not convinced that the 313 responses to the consultation have been adequately explored and represented in the draft report.

We ask the committee to be mindful of possible misrepresentation of the responses to the consultation in reading and considering the report.

C - The recommendation report is very directly written to support the initial proposal for closure. By stating there is no credible financial plan or plan to fill the school to full capacity it misses the point. The school were never going to provide a proposal that either filled the school straight away or instantly reduced the deficit. Obviously, if we had that solution we would just be doing it. The proposals were a suggested starting point for an alternative financial plan. It was clear to come out of a deficit the school would need additional support from the LA / council but the point was that the proposals were a more effective way of managing the cost by using the staff and building against the financial cost of closure (deficit + redundancy). Closure is a very finite solution that clearly has unwanted impact on the local community. We request that the committee seeks clarity from the LA about its approach to these various financial risks prior to making its decision.



6. Deputation on behalf of Patcham Infant School Parents and carers


Supported by:

Dr Rebecca Devereux

Laura Cooper

Marie Buss

Charlotte Bowles

Lauren Allen


Deputation - on behalf of Patcham Infant School parents and carers for C, F & S Committee 22.1.2024

We the undersigned would like the opportunity to express our opposition to the proposed PAN reduction at Patcham Infant School on the basis of four key issues:


1. Poorly researched and overly complex proposals.


2. A rushed, unfair and deeply flawed ‘consultation’ process which seems to seek to stifle opposition voices.


3. We believe there are many sound reasons for Patcham to maintain its current three form entry, at least for the time being.


4. The proposals seem to be in direct conflict with declared Council priorities, particularly regarding climate change and helping disadvantaged families.


We would like the opportunity to share the many critical points made in the following two pages with the full Council.


Supplementary information:


Poorly researched proposals

•The council’s own background data issued to schools quoted inaccurate figures for current pupil numbers in both Patcham Infant School and Carden Primary School.

•Carden’s Chair of Governors is a local authority Councillor, Chair of the opposition party and has been – and still is - involved in debates on this issue. Indeed he has published an article in the local press promoting his own school, during the consultation period. This is a major conflict of interest.

•The Labour leader of the Council also used the ‘Labour’s View’ column in The Argus newspaper during an active consultation period to provide her views on School Closures and PAN reduction proposals. None of the information in this article had any relevance to Patcham Infant School.

•Planning areas for these proposals do not seem logical; they reflect political wards more closely than the way in which local families typically consider primary school choices.

•The proposals have been actioned on a city wide basis, with a lack of respect for and insight into the particular characteristics of individual areas.

•Total city wide pupil numbers are used for calculations, but proposed reductions are applied after consideration of only a subset of the city’s schools, since church and academised schools cannot be included. These schools’ typical intakes do not appear to figure in council calculations.

•It has not been fully explained why popular, successful, financially sound and full/nearly full schools (Patcham Infants, Goldstone Primary, St Luke’s Primary) have been targeted for reduction.

•No account appears to have been taken of factors other than NHS birth rate data/GP registrations - such as new housing developments, or families relocating to our area from within the city and from London/other areas. Local estate agents tell us that a significant proportion of house hunters in Patcham fit this latter category.

•Indicative actual numbers for September 2024 intakes became available on 15 January 2024 which, but for a delay caused by an unexpected by-election, would have been a week after this PAN reduction process was completed. Why would the council not have waited until at least this very useful data was available before formulating plans, to confirm whether forecast trends were proving accurate?



Rushed and flawed ‘consultation process’

•The Council is consulting on three major issues (school closures/PAN reduction/secondary school admissions) at once, which gives none of them the appropriate time, consideration and consultation timescales.

•The process seems to be timetabled for the convenience of the Council and does not promote proper participation from the communities.

•The Council’s claim that our school was ‘consulted’ before these proposals were decided upon is misleading. The first meeting was apparently framed as a strategy discussion but, despite our strong opposition, the decision on our school had been made within 24 hours, during which time we are not convinced the school’s written arguments (which we were encouraged to submit!) against the plans were even read.

•Our linked schools, Patcham Juniors and Patcham High, have not been included in the consultation at all, despite the fact that any reduction in our admission numbers will directly affect them in the near future. Our Patcham schools work very collaboratively with each other, and this is an unacceptable oversight.

•Residents were prevented from submitting questions to the November Committee meeting due to the late publication of the Council’s report on the proposals. This is in contravention of the ‘Access to Information Procedure’ Rule 5, Section 100B(4) of the Local Government Act 1972.

•The deadline for submissions on the consultation was just 10 days after your meeting with Patcham parents on 12.12.23. This was a very short window for parents to respond meaningfully.

•The consultation period coincided with the run up to Christmas, a busy time for schools and families alike.

•We expect the Council to be deluged with consultation responses, given there are 11 schools and thousands of families who will be directly impacted if these proposals go ahead. Yet the Council has allowed just 12 working days to collate, review and analyse what communities have had to say – on 3 different major proposals. (But for the aforementioned by-election, this would have been a laughable 3 working days.) We feel that represents insufficient time for proper consideration of all views, and thus implies that the Council is not taking the consultation seriously.

•Access to the online questionnaire was not straightforward, with so many onward links to negotiate that many potential respondents may not have completed the process. Some parents have already told us they ‘gave up’ because of this. Also, we are not aware of access in other languages, formats (as stated in the EIA) being made available?

•The content of the questionnaire invites everyone to comment on every school; how is anyone in no way connected to an individual school in a position to give an informed opinion? Why should other school populations be able to

comment on what is proposed for us? The potential for manipulation of consultation data from unscrupulous

respondents, keen to promote their


Why our PAN should not be reduced

•Councillors told us that a one form entry primary school of 7 classes is considered financially vulnerable. These proposals would reduce Patcham Infants to 6 classes – the smallest school in the authority. Logically, surely this must make us super vulnerable?

•Patcham Infants has many rare features: it is a stand-alone Infant School, which offers excellent educational opportunities, outstanding results and unique outdoor environments. Families are willing to travel to take advantage of what we offer, and the proposals would narrow parental choice considerably.

•An access route via a muddy twitten is used within catchment criteria by the Council. This is not a realistic options for those with babies in buggies or mobility issues, as it does not take into account accessibility in poor weather. Does this comply with disability legislation?

•A PAN reduction would mean that not all Patcham families would obtain a place at a Patcham school, something that is highly valued locally. More than one family has told us they moved to Patcham specifically because of our school. It could also lead to childcare difficulties for working parents who rely on local family support.

•Most of our families currently walk or scoot to school; denying Patcham families places at our school will inevitably mean more bus and car journeys, which will not help the city’s declared net zero by 2030 target. Parents and carers attending the public consultation event on the 12th December 2023 were shocked to hear Council Officers respond to this point as the outcome resulting from a ‘trade off’ with key council commitments.

•Factors unique to our area regarding the regular influx of families moving from the city centre and from London have not been included in the decision-making process. Local agents confirm that this is a particular feature of our area, which has a particularly high and growing proportion of young families.

•We feel there is no justification for including Patcham in these proposals at this stage, and that a more thoroughly researched, measured and phased approach would be more appropriate for the city as a whole.

•We can find no justification for selecting Patcham Infant School, one of several within these proposals, it might be pointed out, to have experienced a recent change of Headteacher. At a time when school leadership recruitment is very difficult, it seems unfair to target new heads in this way, adding additional pressures to the leadership transition period.


Conflict with declared local authority policies

•Net zero by 2030/Climate Emergency – families will have to undertake more bus and car journeys to travel to schools further from home. More families in receipt of ‘Free School Meals’ may claim travel expenses back from the Council resulting in the proposal costing more money for already overspent budgets, contributing further to the current financial crisis for the Council’s general fund.

•Parental choice – fewer places means more families will be disappointed in their first choice schools. This particularly applies to stand-alone Infant School provision, which in our opinion is extremely specialised, valuable and highly prized by parents/carers.

•Tackling disadvantage – reducing places at successful schools effectively narrows their catchment to a very confined, often more affluent, area of the city. It actively works against social mobility and aspiration. The reduction in school budgets would also negatively impact the scope of specialist support schools are currently able to provide to help disadvantaged children achieve their full potential. The Council’s own report recognises that these proposals ‘could challenge some schools’ abilities to deliver specific strategies for children and young people at risk of educational disadvantage’. It is quite breathtaking that at a time when one of the Council’s declared key priorities (2023-2027 plan) is ‘to maintain a focus on the city’s most disadvantaged families and ensure services are joined up’, this should be so casually sidestepped in these proposals.


Lastly we would like to ask what the LA will do after the consultation process to help repair some of the real damage and division caused by the nature of the process’ design, which effectively pitted neighbouring schools against each other. Many will no longer feel any part of the ‘Local Authority Family’ – which now feels completely dysfunctional.


We hope the Council will properly address what we feel are our legitimate arguments, and take our very real concerns seriously. Thank you.