Post 16 Provision

1st March 2023

Consultation on a proposal to:

Close Mill Water School’s Post 16 provision
Increase pupil numbers in the lower age range

22 February to 31 March 2023



Mill Water School is a specialist Foundation school, located within the grounds of Bicton College at East Budleigh, and is part of the Devon wide SENtient Co-operative Trust.  Mill Water School educates children and young people from age 3 to age 19 with severe learning difficulties, profound and multiple learning difficulties and complex needs.

There are currently 120 pupils on roll, with 6 in Post 16 provision (2 Year 12, 4 Year 14).

Over the last eight years, there has been a marked decline in demand for Post 16 places, alongside a significant increase in demand for places in the lower age ranges.


The Proposal

The Governing Body of Mill Water School is consulting on a proposal to close its Post 16 provision for new entrants in July 2023/24 and increase pupil numbers in the lower age range.  

If approved, there would be no new entrants to the Post 16 cohort.  All current Post 16 pupils would remain at Mill Water to complete their Post 16 education.  As there will only be 2 remaining pupils in Post 16 provision in September 2023, it would close completely in July 2025.  Mill Water School would then become a school for pupils aged 3 – 16 years. 

The Governing Body is also consulting on a proposal to increase pupil numbers in the lower age range (ages 3 - 16).  If approved, this increase would take effect from September 2023 and the number of registered pupil places (NOR) would increase from 100 to 112.  No capital funding or planning consent is required to enable an increase in places.  Revenue funding is in place to support any potential increase in pupil numbers. 

A statutory process, including consultation, must take place before the proposals are decided upon by Devon County Council’s Cabinet. 


Reasons for these proposals

  • 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 increase protection for young people with SEND and to promote a greater focus on outcomes and preparing for adulthood.  In order to meet 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 the same standard of high quality, ‘state of the art’ educational facilities that are commensurate with, or better than, other educational settings in the county
    • any Post 16 provision offers a broad curriculum
    • young people have the widest possible choice of courses including the opportunity to access some learning at other 16-19 colleges, if appropriate
    • young people are able to socialise and mix with a much wider group of their peers as they move towards adulthood, in a similar way to other young people joining a college for their sixth form education
    • young people are able to take up a broad range of opportunities, including wider work experiences and internships across the county, including, if they wish, in their home community.

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

  • There has been increasing demand for places in the lower age ranges which Mill Water School cannot currently accommodate.

Why is Mill Water School unable to meet the goals for a successful and flourishing Post 16 provision?

A combination of factors leads to this inability to offer quality Post 16 provision.

The layout and restrictions of the school building do not allow the creation of a single, designated area for Post 16 pupils that is differentiated and distinct.

Mill Water School is a single storey building with one main entrance for all pupils, aged 3 – 19 and pupils may stay in the same building for up to 16 years.  School opening times are the same for all age groups.  This cannot be changed due to complex travel arrangements.  All pupils pass through the same reception area and proceed to their designated classrooms. 

Pupils share all the facilities and common spaces – there is no space for separate designated Post 16 provision.  Currently, Post 16 pupils are spread across two cohorts and share facilities with younger pupils.  Every year, we have to respond to the changing needs of the whole school, re-designating classrooms to accommodate physical and medical needs.  This means that we are never able to leave all Post 16 learners in one space which they can recognise as their own and we are never able to showcase best practice at times of inspection.

Technology restrictions apply across the whole school

Post 16 learners are subject to the same technology restrictions as EYFS and KS1 pupils, such as limited access to internet and restricted access to websites.  There is no mobile phone signal for anyone within the school building.  This means that there is limited exposure to technologies which Post 16 learners will need to become familiar with as they approach adulthood.

The rural location of the school building

There is limited scope to offer a wide enough experience of community life, travel on public transport, leisure pursuits, practical living skills, money related activities, etc.  The rural location and lack of any public transport facilities means that Post 16 learners have to be taken into town to access such activities.  The school has been able to purchase a number of vehicles so that pupils can be transported to town centre facilities, but this relies on a bank of drivers being available and careful timetabling.  Changes to routines and spontaneity are difficult to accommodate.  Our pupils therefore miss out on the essential elements of effective Post 16 provision which prepare them for their best futures.

A town centre location site would be an ideal base for Post 16 provision, but this is not something that Mill Water School can offer.

Accreditations are hard to achieve

Due to the very low numbers of Post 16 learners, our resources are necessarily geared towards younger pupils and it continues to be a challenge for the school to offer a wide range of courses that are viable both educationally and in terms of personal development.  We lack bespoke rooms such as food technology, ICT, textiles/manual labour courses etc. 

Lack of support for families

It is important for both the young person and their families to consider what is best for the young person’s next phase of their life and what will best prepare them for adulthood.

In many cases, post 16 educational provision is not in the young person’s best interests.

Mill Water School has always offered a 5-day placement for 3 years for Post 16 learners, as opposed to the 3-day offer from most other colleges.  This means that Social Care can delay their support to families, knowing that they are safely looked after at Mill Water, even if the provision is not able to offer the best preparation for their futures.


What are the proposed alternative arrangements for Post-16?

Transitions into and out of further education have long been identified as weak points in a young person’s life. Young people are often being encouraged to remain in school settings post 16 without consideration of whether this provision will best support their transition to adulthood.

Pupils from Mill Water have the right to access appropriate post 16 provision to meet their needs.

Some families are holding onto education places post 16 due to a shortage of Social care services, supported employment services etc. For these young people it is important that they are supported within their localities to consolidate, develop and transfer the skills and knowledge they have gathered during their time at school to access meaningful activity, be that continued learning within a social context ie daily living skills or leisure in nature.

For those whom post 16 provision is suitable and meaningful, Mill Water has working links with other post 16 providers who can offer age-appropriate programmes with experienced staff, along with appropriate facilities to be able to best meet the needs of these young people. These specialist providers can ensure that the young people access learning with peers of similar ages and with similar interests, in a much more age-appropriate environment, better preparing them for life beyond the school gates.

Post 16 colleges are keen to work with Mill Water to improve their offer.

Pupils have the right to transition to different settings and not be institutionalised

Many of our learners will lead a life of meaningful leisure and this can be delivered more easily in other places such as social care/other colleges/supported living.

Post 16 learners have the right to learn how to negotiate their own communities 

It is important that young people and their families are able to make informed choices and understand the benefit of post 16 learners moving to provision that can meet their needs in a more personalised way in terms of the options for study.

For those young who are beginning to access a social care setting that is to become part of their adult offer, it would be better to do their learning there as well.  It can be disempowering and confusing to have to try and adapt to different learning settings and some social care providers may well have better ‘real life’ environments.

Other provisions may have better community access and easier access to local amenities.


Will transport be an issue?

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 during EHC plan discussions that parents are made aware that transport support will be considered in accordance with the local authority’s own post-16 transport policy.

The DfE statutory guidance explains the duties of local authorities regarding transport for students with SEND: 

The 16-18 transport duty relates to young people of sixth form age with special educational needs and disabilities aged up to 19 (and beyond the age of 19 if they are continuing on a particular course started before the age of 19). Local authorities also have a duty under the Education and Skills Act 2008 to encourage, enable and assist the participation of young people with special educational needs and disabilities up to the age of 25 in education and training. It therefore follows that it is good practice for local authorities to include information about what transport arrangements are available and whether they are adequate to enable these young people to participate. 

Mill Water pupils will have already experienced years of travelling potentially long distances to get to school pre-16, so will be used to any journey time that may be required to access alternative provision.


How will this proposal affect parental choice?

Mill Water Post-16 is not a choice.


Will there be any effect on staff? Will there be any redundancies?

There will be no staff redundancies.


Benefits of these proposals

The needs of our Post 16 learners will be better met; they will be better prepared for their best futures.

The school will be able to offer more places to children in the lower age ranges.

The Mill Water School budget can be spent more effectively if it is focused on a narrower age-range.


Have Your Say

The Governing Body of Mill Water School would like to hear your views on these proposals by 31 March 2023. Once these have been received, the responses will be fully considered by the Governors and a decision will be made as to whether to proceed to a formal representation period on the proposals. 

A drop-in information session will be held for parents/carers between 11am and 12pm on Wednesday 8 March 2023.  Jackie Ross Interim Deputy and SEND Strategic Director, will be there to represent the Local Authority.

Following completion of the statutory process, Devon County Council’s Cabinet will decide whether to approve or not approve the proposals, taking into account all responses received.  Any comments or objections received will therefore be shared with Devon County Council, as the decision-maker.  Any comments or objections will be placed on public file and will be available for public inspection.


Indicative timescale

If the decision is made to go ahead with the proposals the timescale is likely to be (assuming agreement to each stage):

Consultation 22 February – 31 March 2023

Governing Body meeting to consider responses April 2023 

Formal representation period 24 April – 22 May 2023

Decision: Devon County Council’s Cabinet 14 June 2023

Implementation: commencing September 2023


Responding to the consultation

You can respond to the consultation by emailing the school:

or by writing to:

Paul Charlton

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

By the closing date of 31 March 2023.

The school website will be kept updated as matters progress and the County Council will also keep you informed throughout the process at:

Please note that all responses will be properly considered by the Governing Body and Devon County Council, but we will not send individual responses to any specific points raised. 

If you need this document in a different format or language, please contact the School Planning Team on 01392 382057 or via email: