Draft Operational Policy 2.4 – Planning for school sites
The Western Australian Planning Commission (WAPC) sought public comment on the Draft Operational Policy 2.4 – Planning for school sites.
What triggered the review of Development Control Policy 2.4? Where does OP2.4 apply?
DC2.4 was adopted in 1998 – this review was an opportunity to address a number of identified issues with its implementation, including:
- strategic planning deficiencies (undersupply of schools and oversubscription of students in growth areas)
- suboptimal land use planning outcomes for school sites (quality of sites, traffic issues etc)
- unforeseen and excessive development costs for the Department of Education with respect to primary schools site acquisition and development
- the need for a transparent, certain and more equitable primary school contribution methodology regime.
Why does a structure plan proponent need to provide Department of Education documentation when lodging a structure plan with the local government?
This policy applies throughout the State. The principles of the policy apply to public or private education establishments, primary and secondary schools, existing and proposed urban areas, new schools or existing schools that are being modified or expanded.
The section of the operational policy that relates to developer contribution requirements (Section 3.9 and Appendix 2) for public primary school sites will apply to all region scheme areas or land within an approved structure plan unless otherwise exempted.
The policy is primarily intended to provide guidance for the delivery of primary and secondary school sites that are needed to address demand resulting from compulsory education. Universities and technical colleges (TAFE) sites tend to be larger in area and less numerous across the State, and subject to different issues.
All guiding information and expectations for universities and TAFE sites have been relocated to the Background section of the policy. It remains important that the needs of the Department of Training and Workforce Development and universities are considered through the strategic planning framework (the Sub-regional Planning Frameworks, region and local planning scheme amendments and district structure plans).
Why has the ratio of dwellings to public primary schools changed?
The WAPC considers that many of the planning ‘gaps’ and sub-optimal outcomes in relation to school sites can be improved through a combination of early consultation and engagement with the Department of Education as well as the identification of appropriate sites in the structure planning stages.
The Department of Education needs to be able to review and assess the requirements for future school sites across broader areas (not just individual structure plans) if it is to respond appropriately to land use planning changes including unforeseen or incremental demand from increased residential densities.
A land developer/applicant is required to demonstrate that they have engaged with the Department of Education early in the planning process where residential development is proposed, and to provide formal evidence of that engagement when the structure plan is lodged. It is not imperative that the parties agree in respect of the school site planning, however it is a requirement that the Department of Education is aware of any structure plan which proposes residential development, or any subsequent amendment which alters the scope of residential development or proposed estimated dwellings.
This process will advise the Department of Education early of cumulative changes that may occur in a locality and that may potentially impact school site provision, anticipated catchments and dwelling yields.
What is the ideal school site land area?
The previous ratio range of 1500-1800 dwellings per public primary school was not delivering effective outcomes as proponents tend to plan based on the upper end of the range, or in excess of it. This has resulted in insufficient school site planning and the oversubscription of many schools. The oversubscription of these schools can result in sub-optimal outcomes for the useable area of the school and the functioning of the adjoining transport network.
The new ratio of 1500 dwellings per primary school is expected to assist with the undersupply of school sites and/or student oversubscription issues. It will also provide the basis for a more accurate financial developer contribution to be calculated.
Additional and supplementary facilities
The revised policy maintains the previous size requirements for primary and secondary schools along with the potential size reductions where they are co-located with public open space incorporating sport or recreation facilities.
The revised policy outlines the circumstances when the Department of Education may request additional land area to be set aside to be acquired by the Department. This may include additional land for education support facilities, child care services or supplementary services supporting childhood health. Early engagement with the Department will assist in understanding the need for additional or supplementary services within each community.
In recognition of the infill agenda established via Perth and Peel@3.5million and occasional difficulties in accessing a four-hectare primary school site in established residential areas, a reduced area may be considered where there is appropriate information and merit provided to support an innovative outcome to meeting unforeseen demand. This reduced site area is contingent on support from the State agencies responsible for education and planning and is not to be considered “as of right” and is by exception.
What work should be undertaken to a school site ahead of ceding?
Government has made a commitment to facilitate the co-location of child care services with primary school sites where it identifies a need. The ability of the Department of Education to request additional land to be set aside for acquisition for the purpose of additional facilities has been clarified in the revised policy.
The location of care services within a primary school site/K-12 school, offers several advantages including convenience for parents of children attending both the school and care facilities, a smooth transition for children entering the primary school system, continuity for children across their school day or during vacation periods, and the building can provide a venue for other associated school or community activities. The utilisation of the school site as a hub will also assist with minimising vehicle trips.
What is being done to assist with traffic issues around school sites?
In recent years, the Department of Education has experienced substantial costs to bring school sites up to a developable standard and ensure sufficient developable area is achieved for the school. The improved early engagement process is expected to result in a higher standard of site being identified and provided for schools. This should ensure that the structure planning processes have resolved any issues relating to topography, environmental, geotechnical, water management and infrastructure provision.
It is expected that a school site will be ceded in an unencumbered state and that basic site works (fill and drain) to match in with the broader subdivision area and vegetation clearing will have been completed or other satisfactory arrangements made with the Department. All abutting roads should be constructed to levels that will match or coordinate with the school site and all appropriate infrastructure services have been made available to the site.
Proponents and clearing agencies should liaise with the Department of Education prior to endorsing the clearance of subdivision conditions relating to fill and drain, road construction and infrastructure provision where a school site is part of the subdivision area.
Who is responsible for construction of roads adjacent to school sites?
Movement network, traffic and parking issues continue to be raised as key issues affecting the day-to-day operation of schools. The sections of the policy relating to traffic and movement have been expanded and clarified and an additional appendix has been incorporated to provide strategic guidance and reflect the objectives of the Department of Transport’s Your Move schools program.
The policy has been revised to require a minimum of three road frontages around proposed schools, as well as other design requirements including limiting crossovers and intersections to ensure more parking, bus embayments and set down/pick up areas can be provided to assist with traffic flow around schools.
School sites experience peaks and troughs in student numbers - how does the policy assist in managing this challenge?
The subdivider is responsible for the cost and construction of roads adjacent to school sites. Historically an unintended interpretation of the original policy resulted in the Department of Education sharing half of the entire road construction costs. To remedy this, the reference to the sharing of road infrastructure costs with the Department of Education has been removed from the revised policy.
Subject to negotiation, the Department will contribute to the cost of providing additional road infrastructure directly attributed to the school site, including on-street embayments, raised pedestrian crossings and widened road carriageways.
Are there any changes to the way in which a school site is ceded?
Suburbs experience demographic changes over time which can impact on enrolment numbers and, in some cases, the need for school sites. The Department of Education and the WAPC see value in allowing for the adaptive re-use of schools that are not required in the short to medium term.
Creating a process where public school sites can be utilised temporarily for alternative land uses (in full or in part) will assist in maintaining the asset until enrolment numbers support its re-opening. It is expected that proposals to re-use a school site for alternative land uses will be done in consultation with the community and relevant local authority to ensure the proposed temporary land uses are appropriate for the location and local context. It is acknowledged that in some cases the closure and sale of a school site may be the preferred option.
How has the Developer Contribution for public primary schools changed?
Where land identified for a school site is to be ceded through the subdivision process, it will be ceded to the Crown for ‘Public Purpose – Education’ rather than ceded freehold to the Department of Education. The Crown will then provide a management order to the Department of Education to reflect the education and other incidental land uses applicable to the site.
What impact do the policy changes have on the subdivision process?
The previous policy did not outline the contribution methodology. A new section has been added to the revised policy to clarify the policy’s original intent, which is to provide for the ceding of government primary school sites free of cost, in a fair and reasonable condition, and provide transparency around the contribution arrangements. The contribution requirement has been expanded to apply to all region scheme areas and land subject of an approved structure plan.
The contribution methodology is premised on all subdivisions and intensification in residential density creating demand for, or on, a primary school. Based on a ratio of one primary school for every 1500 lots or dwellings, every subdivider should contribute 1/1500th of a notional four-hectare primary school site for every lot or dwelling that is proposed to be created.
The contribution will be imposed on all freehold and survey strata subdivisions that create more than five lots within the region planning scheme areas or land within an approved structure plan. The contribution methodology requires subdividers to have their properties valued to inform their primary school contribution or reimbursement amounts where a landowner has ceded more land than their lot yield would require.
The draft policy includes a threshold which proposes to set a maximum contribution cap per lot to ensure that contribution amounts are not unreasonable in higher land value areas. The threshold maximum contribution amount will be agreed on an annual basis by the Department of Planning, Lands and Heritage and the Department of Education, taking into account market considerations. It is anticipated that the provision for a maximum contribution amount will be set within the final policy. To facilitate discussion, two notional values of $2,500 and $4,500 per lot/dwelling is suggested in these FAQs and constructive feedback on the use of a contribution cap and the quantums proposed are welcome.
Will changes be made to the WAPC’s model subdivision conditions?
The WAPC will be responsible for referring all subdivisions which propose more than five lots to the Department of Education for comment, so that incremental density change or ‘coding creep’ can be captured, reviewed and responded to more effectively at that stage of planning.
Yes, the WAPC’s model subdivision conditions and advice notes will be revised to align with the revisions to this Operational Policy. These revisions will cover the new development contribution arrangements, transfer of land, site works and infrastructure provision.