11. Policy 4 – Strategic Infrastructure sets out the context for school place planning, and identifies that both expansions of existing and new schools will be required to meet the growth needs.

12. We would advise some slight policy wording amendments to ensure that the policy is sufficiently flexible and can endure throughout the plan period, where need and demand for education places may change.

School capacity will be increased to provide for growth by improvements and expansions to existing schools and the provision of new schools as required, including primary schools on strategic development sites and growth areas as identified in the most up to date evidence base.

13. It is considered that this change will ensure that the changing growth needs are capable of being met in future years, and will be underpinned by the latest evidence base, in accordance with the supporting policy text at paragraph 232 (setting out that the information will be updated annually in line with the Greater Norwich Infrastructure Plan ‘GNIP’). DfE also notes specifically that education infrastructure requirements for the plan period should be included within an Infrastructure Funding Statement . Where additional need for school places will be generated by housing growth, the statement should identify the anticipated CIL and Section 106 funding towards this infrastructure. The statement should be reviewed annually to report on the amount of funding received via developer contributions and how it has been used, providing transparency to all stakeholders.
14. DfE would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Infrastructure Funding Statement, viability assessment or other evidence relevant to education which may be used to inform local planning policies and CIL charging schedules. As such, please add DfE to the database for future consultations on relevant plans and proposals.
15. The supporting text to the policy, at paragraph 230, sets out the requirement for developer contributions and CIL in the delivery of schools.

16. Local authorities have sometimes experienced challenges in funding schools via Section 106 planning obligations due to limitations on the pooling of developer contributions for the same item or type of infrastructure. However, the revised CIL Regulations remove this constraint, allowing unlimited pooling of developer contributions from planning obligations and the use of both Section 106 funding and CIL for the same item of infrastructure. The advantage of using Section 106 relative to CIL for funding schools is that it is clear and transparent to all stakeholders what value of contribution is being allocated by which development to which schools, thereby increasing certainty that developer contributions will be used to fund the new school places that are needed. DfE supports the use of planning obligations to secure developer contributions for education wherever there is a need to mitigate the direct impacts of development, consistent with Regulation 122 of the CIL Regulations.
17. As drafted currently, we consider that paragraph 230 does not accord with our guidance on developer contributions (as referenced in paragraph 2) and therefore we would propose the following amendments:
If a new development is likely to generate enough children to fill a new school, developers are expected to contribute both the land and for the full construction cost of that school. A pro rata contribution is requested if pupil yield is calculated to be less than a full new school and the school places are to be provided elsewhere through expansions or on other development sites. Land must be secured through S106 Agreements, and contributions towards both on-site and off-site education can be secured through both S106 Agreements and CIL where applicable locally.

18. We also request a reference within the Local Plan’s policies or supporting text to explain that developer contributions may be secured retrospectively, when it has been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a secondary school to ensure that places are available in time to support development coming forward. This helps to demonstrate that the plan is positively prepared and deliverable over its period.