Proposed Changes to Post-16 Provision at Mill Water School & increase in places

Proposals:

1. To change the age range from 3-19 to 3-16
2. Increase planned pupil numbers in the lower age range from 100 to 130 places
3. Acquiring of an additional (satellite) site at Seaton

The acquiring of an additional (satellite) site is related to the proposal to increase planned places from 100 to 130 and both are dependent on each other. The proposal to change the age range from 3-19 to 3-16 is not linked to the other proposals.

Consultation Period:

4^th December 2025 – 17^th January 2026

Consultation Meeting

An initial consultation meeting was held on 2 December 2025. A further consultation meeting will be held on 7 January 2026 at 6pm until 8pm on Teams. Further information will be sent out on joining this meeting on line.

Context and Background

Mill Water School is a specialist educational institution located within the grounds of Bicton College in East Budleigh, and is part of the South West’s largest special school multi-academy trust. The school caters for children and young people aged 3 to 19 with severe learning difficulties (SLD) and profound and multiple learning difficulties (PMLD). Currently, there are 120 pupils enrolled, including four pupils in the Post-16 provision (two Year 12 pupils and two Year 14 pupils). These Post-16 pupils attend either two or three days a week.

The current Mill Water School building, which opened in January 2015, was designed to accommodate 100 pupils. However, despite being purpose-built, budget constraints mean that the site has significant limitations, restricting its capacity to effectively meet the complex and changing needs of the pupil cohort. The limitations are exacerbated by the broad age range of students (3 to 19 years) and the fact that the school is operating at 20% above its intended capacity.

The location of Mill Water School, tucked away at the back of the Bicton College estate and three miles from the nearest town, has resulted in a loss of community engagement. The previous school site (in Honiton) provided essential links to local accessible facilities and work experience, and these were lost when the school relocated in 2015.

Initially, the new site included specialist subject classrooms such as Art, Design and Technology, Food Technology, ICT, Music and Drama, Science, a Fitness Suite, a Hydro Pool, and a separate Post-16 Student Common Room. These facilities were crucial for promoting age-appropriate independence. Additionally, there was an outdoor space designated for Post-16 pupils and a self-contained teaching flat, which was deemed essential for independence training.

Over the years, the leadership team has had to reallocate the use of these specialist rooms to accommodate the additional 20 pupils and associated increase in staff numbers. The impact of losing these dedicated spaces has led to a significant narrowing of the curriculum available for Post-16 learners. The absence of specialist teaching spaces in a special school is not merely a matter of losing a few classes; it severely hampers a Post-16 child’s overall capacity for experiential and taught development.

Specific Limitations of Current Provision

• The self-contained teaching flat, which provided vital life skills and independence training, has been lost. Dedicated spaces for practical life skills, such as kitchens and laundry areas, are essential for teaching everyday tasks. The absence of these spaces means pupils cannot practice real-world skills in a safe and structured environment, ultimately reducing their readiness for semi-independent or supported living.

• Post-16 education is focused on preparing students for adulthood, employment, and independence. Specialist rooms facilitate hands-on learning in areas such as catering, construction, and digital skills. Without these facilities, pupils miss out on practical experiences that are essential for employability and independence.

• Specialist spaces create environments tailored to older learners’ developmental stages. Without them, Post-16 pupils remain in classrooms designed for younger children, which can diminish engagement and motivation.

• Specialist areas simulate adult environments, such as workplaces and community settings, assisting pupils in preparing for college or employment. The lack of these spaces complicates transitions and may hinder pupils’ ability to adapt to new settings.

The absence of separate teaching spaces, outdoor areas, and opportunities for older pupils to distance themselves from significantly younger peers severely hampers the ability of Post-16 pupils to progress, mature, and embark on their transition journey to young adulthood with a solid foundation of independence. Every aspect of a special school must be geared towards an education that prepares pupils for a successful transition to adulthood. The removal of such vital facilities significantly undermines the very foundation of this goal.

The Proposals

The Governing Body and Trustees of Mill Water School are consulting for the second time on a proposal to change the age range of the school from 3-19 to 3-16 years of age through the closure of its Post-16 provision for new entrants in September 2026/27. This consultation is an opportunity for parents and stakeholders to share their thoughts, concerns, and suggestions before any final decision is made.

If the proposal is approved, there will be no new entrants to the Post-16 cohort. All current Post-16 pupils will remain at Mill Water to complete their education. However, with only two remaining pupils in the Post-16 provision in September 2026, it would close completely in July 2028. Mill Water School would then operate solely for pupils aged 3 to 16 years.

Additionally, the Governing Body and Trustees are consulting on a proposal to acquire an additional (satellite) site at Seaton and thereby increase pupil numbers in the lower age range (ages 3 to 16). If approved, this increase would take effect from September 2026, raising the number of registered pupil places from 100 to 130 across both the Bicton site and the school’s new satellite building at Seaton.

A process, including consultation, must occur before the proposals are submitted to the Department for Education’s South West Regions Group, which will make the final decision. Responses received during the consultation will form part of the submission to the DfE Regions Group.

Rationale for Proposed Changes

After careful review, we believe that closing the Post-16 class is in the best interests of our pupils for several reasons:

Legislative Framework

The aims and attributes of successful Post-16 provision for pupils with severe and complex learning difficulties are well documented. The Children and Families Act 2014 aims to enhance protections for young people with special educational needs and disabilities (SEND) and to promote a greater focus on outcomes and preparation for adulthood. To fulfil its obligations under this Act, Devon County Council must ensure that:

• All young people with an Education, Health and Care Plan (EHCP) for severe, complex, multiple, and profound learning difficulties have equal access to high-quality educational facilities that are commensurate with, or exceed, those available in other educational settings within the county.

• Any Post-16 provision offers a broad curriculum.

• Young people have the widest possible choice of courses, including the opportunity to access learning at other 16-19 colleges, if appropriate.

• Young people are able to socialise and interact with a broader peer group as they transition towards adulthood, similar to other young people entering sixth form education.

• Young people can engage in a diverse range of opportunities, including work experiences and internships across the county, including, if desired, within their home community.

Mill Water School is currently unable to meet the goals for a successful and flourishing Post-16 provision. A recent Quality Assurance report stated that “despite best efforts, the Post-16 provision is not fit for purpose.” Historical Ofsted inspections have also highlighted the lack of appropriate spaces for Post-16 learners, despite the school’s best efforts.

There has been an increasing demand for places in the lower age ranges, which Mill Water School cannot accommodate without adversely impacting its Post-16 provision.

Factors Contributing to Inadequate Post-16 Provision

Several factors contribute to Mill Water School’s inability to offer quality Post-16 provision:

• As the school caters for ages 3-19, pupils can remain in the same school building for 16 years, limiting the sense of progression and transition for older pupils.

• Because of the layout of the school building, all pupils regardless of their age must pass through the same main entrance at the start and end of the school day. School opening times are uniform for all age groups, and cannot be altered due to pupils’ complex travel arrangements. It is not possible to make different arrangements for Post-16 pupils, again limiting their sense of a transition towards adulthood.

• The space currently allocated to Post-16 pupils falls well below recommended measurements for an appropriate learning environment. This arrangement is neither appropriate nor respectful to them as a distinct group of learners.

• The allocation of a specific space to Post-16 learners this year has only been possible because of the very low number of Post-16 pupils. Each year, the leadership team must respond to the changing needs of the entire school, redesignating classrooms to accommodate physical and medical requirements. Because of these changing needs, and the limitations of the school site, it is not possible to create a permanent dedicated space for Post-16 learners that they can recognise as their own. This again undermines their sense of transition, progression, and independence.

• Post-16 pupils are unable to access essential facilities, such as toilets, kitchens, technology, and outdoor areas independently, due to the presence of younger pupils and restrictive access points.

• When Post-16 pupils are off-site their teaching space is used by much younger pupils. Should Post-16 pupils choose to stay in school, they would have to share the space with these younger pupils.

• Technology restrictions apply across the entire school, limiting Post-16 learners’ exposure to key tools and resources. They are subject to the same technology limitations as Early Years Foundation Stage (EYFS) and Key Stage 1 pupils, including restricted internet access and limited exposure to relevant websites. The absence of mobile phone signal within the school further hampers their ability to engage with technology.

• The rural location of the school limits opportunities for community engagement, use of public transport, leisure activities, and practical living skills. The lack of public transport means that Post-16 learners must be transported to nearby towns to access such activities, relying on the careful timetabling of a limited pool of staff drivers. This rigidity restricts spontaneity and the ability to adapt to changing circumstances, resulting in missed opportunities for pupils.

• Achieving accreditations is challenging due to the low number of Post-16 places allocated. Resources are primarily directed towards younger pupils, making it difficult for the school to offer a diverse range of courses that are both educationally viable and conducive to personal development. The absence of bespoke rooms for subjects such as food technology, ICT, textiles/manual labour, and music technology further limits the curriculum.

Proposed Alternative Arrangements for Post-16 Provision

Transitions into and out of further education have long been identified as critical junctures in a young person’s life. Young people are often encouraged to remain in school settings after the age of 16 without consideration of whether such provision will adequately support their transition to adulthood.

For those for whom Post-16 education is suitable and meaningful, Mill Water has established working links with other Post-16 providers that can offer age-appropriate programmes with experienced staff and appropriate facilities to meet the needs of these young people. These specialist providers can ensure that learners access education alongside peers of similar ages and interests, in a more age-appropriate environment, thereby better preparing them for life beyond the school gates.

Since the previous consultation, Post-16 colleges have expressed a keen interest in collaborating with Mill Water to extend their offerings to accommodate more diverse needs. Mill Water leaders have worked closely with staff at Petroc College to ensure their programmes meet the needs of our pupils. As a result of this collaboration, nearly all of Mill Water’s Year 11 leavers successfully transitioned to Petroc College in September 2025. Petroc has effectively catered for learners from all pathways, including pre-verbal learners, those requiring intimate care, multi-sensory impaired learners, pupils with sensory processing difficulties, and those exhibiting challenging behaviour.

The transition process has improved significantly, with pupils reporting increased readiness for their next educational stage following college visits. The excitement among this year’s Year 11s about their impending transition is palpable.

Commissioning of Special Schools

Devon County Council is undertaking a recommissioning of all special schools in the County which reflects the changing needs of Children and Young People with an EHCP in Devon. The recommissioning will ensure there is sufficient provision to meet the needs of learners who are unable to access a mainstream school and/or resource base provision on a mainstream school’s site.

In recent years, Mill Water has seen, through the consultation process, the needs of learners requiring a place at the school change with a shift towards learners who are now developing the skills and independence that enable them to access local Further Education (FE) colleges. This is a positive change. It means that pupils can benefit from a broader curriculum, social opportunities, and preparation for adulthood in environments that reflect real-world settings. This shift in commissioning has resulted in an increased cohort of learners whose post 16 needs can be better met in Further Education, building on the partnership work highlighted previously and a wider countywide plan to expand the SEND offer in all Further Education Colleges including Exeter, Tiverton, Barnstaple and South Devon.

Rights and Choices for Pupils

Pupils have the right to transition to different settings. Many of our learners will lead lives characterised by ‘purposeful leisure’, which can be more effectively facilitated in alternative environments, such as social care settings, other colleges, or supported living arrangements.

Post-16 learners have the right to learn how to navigate their communities. It is essential that young people and their families are empowered to make informed choices and understand the benefits of transitioning to provisions that can meet their needs in a more personalised manner.

For those young people beginning to access social care settings as part of their adult offer, it would be advantageous to conduct their learning in those environments; such providers may offer more authentic ‘real life’ opportunities.

Other provisions often provide better community access and easier access to local amenities, facilitating a more comprehensive educational experience.

Transport Considerations

Post-16 learners with an EHC plan will have an institution named in their plan at Section I. There is no entitlement to transport to and from this named provider, and transport should only be named in an EHC plan in exceptional circumstances. Local authorities should ensure that parents are informed during EHC plan discussions about the transport support available in accordance with the local authority’s post-16 transport policy.

The Department for Education’s statutory guidance outlines local authorities’ duties regarding transport for students with SEND. The 16-18 transport duty applies to young people of sixth form age with SEND, up to the age of 19 (and beyond if they are continuing on a course started before the age of 19). Local authorities also have a responsibility under the Education and Skills Act 2008 to encourage, enable, and assist the participation of young people with SEND in education and training up to the age of 25. Consequently, it is considered good practice for local authorities to provide information about available transport arrangements and their adequacy to facilitate participation.

Mill Water pupils will have already experienced potentially lengthy travel times to reach school prior to age 16, so they will be accustomed to any journey time required to access alternative provision.

Impact on Parental Choice

The leadership team has consistently maintained that Mill Water’s Post-16 provision is not an active choice for parents but rather a decision made due to the lack of other viable options. We aspire for our pupils and their families to have a genuine choice of provision that best meets their needs.

Staff Implications

There will be no staff redundancies as a result of this proposal.

Benefits of the Proposed Changes

The proposed changes will ensure that the needs of our Post-16 learners are better met, ultimately preparing them more effectively for their futures. Furthermore, the school will be able to accommodate more pupils in the lower age ranges.

Our Commitment

We are committed to supporting every pupil through this transition. If the proposal is approved, we will work closely with families to identify alternative, high-quality provision for Post-16 learners. This will include guidance on next steps and support with transition planning.

How to respond

The Governing Body and Trustees would like to hear your views on these proposals by 17 January 2026.

You can respond to the consultation by emailing the school: admin@millwater.devon.sch.uk or by writing to:

Chair of Governors, Mill Water School, Bicton, East Budleigh, Devon, EX9 7BJ.

If you need this document in a different format or language, please contact the school office.

Next Steps

Following the conclusion of the consultation period:

1. The Trustees will review all responses.
2. A decision will be made on whether to apply to the Department for Education’s Regions Group for a significant change.
3. The DfE Regions Group will make the final decision regarding the proposals.