This policy specifically includes educational facilities. The proposed policy direction is to support development of new facilities in appropriate locations where there is a local need for the facilities, and they are in close proximity to the people they will serve. New or replacement major facilities serving the city, or where appropriate the sub-region, would need to follow the sequential approach to main town centre uses established by national policy, and be located in sustainable, accessible locations.

The difficulty with this is that education would not normally be considered a main town centre use, and a new school or college serving a city-wide or sub-regional area (such as CMS) might be pushed towards a city centre location without a genuine justification in national policy. We request that the final policy makes it clear that education facilities serving a wider catchment area will not be considered a town centre use requiring the sequential approach to be applied, but that any such facilities must be located in sustainable, accessible locations.

The department welcomes the plan’s recognition that easy access to good quality educational provision is important for supporting economic growth, developing strong sustainable communities, promoting economic prosperity and sustaining quality of life. The plan states that new and replacement facilities should facilitate the growth of the area by providing sufficient capacity to accommodate community need and demand. We request an addition to this, explaining that in some cases this will include wider sub-regional community demand, and that for educational facilities there is a national policy requirement to provide a sufficient choice of school places, which is not necessarily the same as meeting a capacity need within a specific pupil place planning area.