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IV CONCLUSIONS
71. My terms of reference were to consider the functions, constitution and methods of work of the Schools Council. While the evidence comprehends these three heads some of it goes wider. I was asked to consider the Council from first principles. This seemed to me clearly to imply that I must contemplate as possibilities the abolition of the Council or its transformation into a radically different body. Such questions as the effectiveness of its work and the esteem, or otherwise, in which it is publicly held seemed to me materially to bear on these possibilities. I have therefore interpreted the terms of reference widely and I have summarised above the evidence which this interpretation produced.
72. Before commenting on it I make a general observation. To an extent all education is political and no branch of it more so than schools education in which almost everyone is concerned at some stage or another: as pupil, parent; as taxpayer, ratepayer. Even the more specialised interests are widely diffused: those of teachers, school governors; employers, practitioners in further and higher education; Members of Parliament, Councillors and officers in central and local government in the sectors concerned. What astonished me however on first acquaintance with this subject was the extent to which these interests are institutionalised, and still more the multiplicity of the institutions representing some of them. The membership of the Schools Council as set out in its Constitution (Annex II) illustrates the point, as does the reference in paragraph 53 above to the still further bodies whose work has some bearing on, or some analogies with, that of the Council. To some extent no doubt this multiplicity merely reflects the complexity of the system; but to the extent that it represents rivalry between and within groups, it is also a manifestation of power politics.
73. When I reflect on the evidence as a whole it seems to me that at the root of the criticism of the Schools Council, both from its detractors and its supporters, is dislike of the application of power politics to a matter so important as schools education. It is a dislike that I share. Curriculum and examinations involve academic, social and even technical questions on which there is room for legitimate difference of view on objective grounds and also, as in all educational questions, for difference of individual opinion. But that is quite another matter. There are many other bodies both within and outside education whose members are nominated as representatives of particular interests but who, once elected, are more successful in combining for common ends than the Council is, are more prepared to engage in frank discussion - it was a frequent criticism in the evidence that representatives of central government on the Council were not - and in a less abrasive atmosphere. I believe that some improvement has taken place in recent years (and certainly many members of the Council have worked for it). But if the Council survives it will never, I believe, command such wide public acceptance as a large part of its work deserves unless it can make considerable further progress in this direction. In its 17 years of existence it has always been the subject of controversy; some would say that if it had not been it would not have fulfilled its purpose. Some controversy attaching to a body of this kind is inevitable and even healthy. It is the nature of this particular controversial aspect of the Council which is damaging.
74. Against the background of these preceding paragraphs I state my conclusions on the evidence in the order used in section III.
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Fundamental
75. I accept the need for curriculum development on a national basis. I do not think that this function could be performed by DES officials or HMIs. While both of them can suggest certain lines of general policy in relation to the curriculum (and both have recently done so) they lack the resources to deal with detailed development. Nor do I think that any of the other bodies mentioned in paragraph 53 above could take over the work at present done by the Council on the curriculum (though I refer in paragraph 91 below to the Council's relations with these bodies).
76. As to examinations I accept that in comparison with the GCE Boards' work in cross-monitoring, the Council's monitoring of A levels has been rather slight. But it does seem to me right, and indeed in the Boards' own interests, that some body external to them should engage in this operation (and indeed I suggest in paragraph 92 below that the Council has not done enough in relation to existing examinations generally). As to examinations policy decisions are clearly the responsibility of the Secretaries of State but they need expert advice, outside the resources of the Departments, to consider together with the views of the Boards and other interests. I conclude that a national body with these functions in relation to examinations is necessary also.
77. The great weight of the evidence accepts the case made in the Lockwood Report for a single body dealing with curriculum and examinations and I, too, accept it.
A nominated body
78. It does not follow that such a body should be of a similar composition to that of the Schools Council. A nominated body is the main alternative and I have considered the case for it carefully. There is ample precedent in other countries, including Scotland. In England itself there is precedent (though not in schools education) in the FEU, a body nominated by the Secretary of State. There are some evident advantages in such a system. It could be more efficient, would certainly be less costly and might command greater respect (in certain quarters, though not necessarily in others). The concept of a body which settles priorities and then leaves the staff to carry out, and where necessary commission, the work detaches the staff from at any rate a great deal of the political tensions.
79. I see three disadvantages. To my knowledge, bodies of this kind which exist elsewhere are not required to deal with the full range of functions (including detailed work on examinations) at present exercised by the Schools Council, and they tend to exist in systems of schools education less complicated than ours. Secondly, a nominated body would be unacceptable for much the same reasons as the CSG in 1962 to which the local authorities and the teachers' associations objected. Moreover there are by now more interested parties to object. The principle of partnership propounded by the Lockwood Committee was widely accepted at the time; the principle of extending this partnership to a wider circle of interested parties (particularly more of the 'consumers', such as parents and industry) was expressed in the Schools Council's Constitution of 1978; and according to the evidence that I have received both principles still command very considerable support. Certain tensions, such as those between teachers, between teacher associations, between Examination Boards and other
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parties concerned with examinations, between on occasion, central and local government, to name but a few, are inherent in our system as it is. They would not disappear if the Schools Council were abolished and its work taken over by a nominated body. As I have explained above they seem to me evident to an unnecessary (but I believe curable) degree in the present Schools Council. I cannot but think that they would express themselves in more objectionable ways if a nominated body were imposed (as in practice it would have to be). Thirdly, a nominated body is consistent, but in my view consistent only, with a system of central government control of the curriculum and examinations. It seems to me therefore better to build on the Schools Council as it exists, whatever its shortcomings. It must necessarily reflect the complexity of the system of schools education as it exists at present. If it could divest itself of its power politics it might do so rather well. I do not therefore recommend a nominated committee.
Further education
80. The only extension to the Council's functions which received significant backing was in the field of further education. I have described the conflicting evidence I received on the point. At first sight there is a case for extension because of the overlap in both curriculum. and examinations described in paragraph 47 (vi) a. It is a matter almost of accident whether a pupil proceeding beyond 16 is receiving instruction in the sixth form of a secondary school or a sixth form college (both classified as schools) or at a college of further education. The division of the two Curriculum Committees into 5-16 and 17-19 would be a neat arrangement on the face of it. Moreover, some of the institutions concerned with further education are represented on Schools Council's committees so it can be argued that it would not greatly complicate the Council's structure to extend representation as would be necessary if the Council's function were enlarged as suggested.
81. Nevertheless I do not recommend such an enlargement for the following reasons:-
a. There are many untidy borderlines in the education system and this one is no worse than some others. In so far as pupils in institutions of further education take GCE examinations their interests are covered by the Council's present work on curriculum and examinations.
b. An enlargement to include FE would require the Council to be involved with a (to it) whole new order of examinations at a time when its existing work on examinations is likely to increase.
c. In general I consider the Schools Council overstretched as it is.
d. Doubts about the role of the Curriculum Committees, explained below.
e. The enlargement would require fuller representation of FE interests and so would have complicating consequences for the committee structure whereas I believe, as I shall explain later, that an important need for the Council is to simplify the structure and reduce the size of committees.
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82. I am persuaded of the need for a body concerned with curriculum development and examinations financed by central and local government, distant to an extent from both but on which both are represented. Arising out of discussion of the further evidence below, I make suggestions and recommendations about the Council's work, none of which however would require any alteration in its functions as summarised in paragraph 26; and about its organisation which would require significant change. Subject to these points;
I recommend that the Schools Council should continue and with its present functions.
Performance
a. Curriculum development
83. It was evident to me from an early stage that I could not exercise independent judgement on the question of quality, important as it is. In terms of projects alone the Council has produced more than 180, in some cases with accompanying teaching materials, not to mention working papers (many of which concern curriculum) and other reports and bulletins. Even if the time allotted had permitted me to read it all, it would have been out of the question for any individual to comment on this range of subject matter. So I am dependent on the evidence which suggests to me that the quality of curriculum development work has been a mixture of good, bad and indifferent, as one might have supposed in the first place.
84. The Council is careful not to promise publication when it commissions work: I think this right. I suspect that it has not always been critical enough in its judgements of what should be published and what not. One of those who gave evidence referred to a specific piece of work, on which his opinion was asked as an assessor; he thought little of it; the Secretariat nevertheless argued that it should be published because "those concerned had put in a great deal of work". I have been unable to check the particular example and I certainly would not wish to generalise from it. So it is not a matter susceptible of recommendation. I hope, however, that the Council may see for itself that weak judgement on such matters endangers it reputation. It would be well advised to be critical.
85. On the effectiveness of the Council's work on curriculum development I note the evidence from HMI quoted in paragraph 52 above which begins "In general the Council's activities have not had a wide effect in the classroom". I cannot evaluate the statistical and other methods of the Council's "Impact and Take-up" project but its conclusions quoted at Annex III seem to me on the whole reassuring. Expectations were too high; measured against realistic expectations of the contact which might have been made with teachers the majority of projects have fallen below but some have exceeded; the degree of their use compares not unfavourably with Nuffield and other comparable schemes; interestingly enough, the attitudes of teachers to the Schools Council's work are more favourable the higher the school age range and "the higher the status of the teachers". Probably the only conclusion on which there would be general agreement is that the work has not been so effective as it was hoped or as it might have been. (It should be borne in mind that the analysis covers the period up to 1976 only.) There are some who consider the pace of change in the curriculum, irrespective of the influences that bear on it, altogether too slow for what society needs. For myself I would expect change in the curriculum to come about
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rather slowly, not because of inherent conservatism in the teaching profession as because teachers have to be persuaded that any given change is an improvement. That seems to me a useful and necessary safeguard.
86. I do however consider that the Council needs to take the question of dissemination much more seriously even than it has done in recent years. The means that have been used are various. Some of those who have been responsible for projects have themselves explained them to groups of teachers. Among the services used are those responsible to local education authorities, in particular local authority inspectors and advisers who are in frequent contact with the schools in their areas and teachers' centres. Colleges of Education and Departments of Education in universities and in the maintained and voluntary institutions use some of the Council's products for initial training of teachers. HMI act similarly in the courses they hold for in-service training of teachers. A variety of other agencies including the Open University and BBC educational broadcasts, while not promoting the Schools Council's products directly, use them as a basis for educational programmes. The Council's own Field Officers and its Regional Information Centres are especially active.
87. It seems to me that the Council urgently needs to do two things. It should review the means of dissemination external to its own officers to make sure it is using the former to the maximum extent and to plan the complement and deployment of its officers. For example, local authorities vary considerably in the resources they are prepared to devote to dissemination and this should have implications for the deployment of Field Officers and information centres. Should these, for instance, be placed in parts of the country where local authorities are relatively less active in this matter? Or, on the contrary, should the Council decide that it is impossible to obtain full national coverage and concentrate on selected areas which seem propitious? (I have had a number of letters from satisfied 'customers' in the north-east area, for example, where the City of Newcastle Upon Tyne is active and helps to finance one of the Council's few Information Centres and where one of its Field Officers is stationed).
88. Secondly the Council ought to devise some guidelines on the question of the use of its own funds for dissemination. I feel tolerably certain that it has not adequately budgeted for this aspect of its present programmes. Ideally this consequential expenditure should be foreseen and budgeted for in the first place; of course in practice this cannot be precisely, though an attempt at it should be made. It seems to me that there are at present no guiding principles about the extent to which the Council itself funds further dissemination of its earlier work. As recently as last term it voted funds for further dissemination of projects completed a decade ago. I do not say that the individual decisions were wrong, but what are the principles on which they are made? Is dissemination to be a continuing charge until the project is obsolete? Are only the very good ones to have such treatment? Is the Council sufficiently hard hearted in withdrawing continued support from the less successful? This is difficult territory, I know, but it seems to me one that it is necessary for the Council to explore in a more purposive fashion than it seems to have done so far.
89. If these two questions are not dealt with soon, the Council will shortly be up against a real dilemma: the choice between 'wasting' work already done and denying itself the power to commission new work. I think, in fact, that the Council is up against that dilemma now in relation to expenditure for 1983/84; and it might in fact be wise to commission no new work in 1983/84.
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I recommend that the Finance and Priorities Committee examines future policy on dissemination with a view to establishing principles; considering how better to forecast cost of dissemination in future; considering the consequences for deployment of staff, including in particular Field Officers.
90. I have expressed above my opinion that none of the other bodies concerned with the schools' curriculum could satisfactorily substitute for the Council's work on curriculum development. That is not, of course, to say that I consider that the Council has prescriptive rights in this field (nor, to be fair, has it ever claimed them). Although very little evidence on the point was volunteered, I have felt obliged to consider to what extent the work of the Council and of these other bodies duplicate each other.
91. Short of conducting a review of each of them, which would have been impossible in the time, I cannot be certain that there is no overlap. But, first, a degree of it (provided that it is not downright wasteful) is not necessarily harmful. Secondly, all of these bodies (and also the Council) are, short of funds and so have an incentive not to duplicate wastefully. The important thing seems to me to be that all of them should know what work the others are currently engaged in and that the Schools Council has a particular obligation to inform itself, and be the means of informing others, of what work is being undertaken or contemplated.
I recommend that the Director of Studies makes it his particular responsibility to be aware of curricular developments funded by other agencies; and that the Council should give effect to the intention stated in 'Principles and Programmes' 1979 to act as a clearing house for such information.
b. Examinations
92. I think that the Council acts as a useful back stop to the Examinations Boards in approving new subjects and syllabuses for GCE A level. It seems to me a pity that it relinquished this function in relation to syllabuses for O level and an even greater pity that it never assumed it for either subject or syllabus in the case of the CSE, since it is in that area that criticism about proliferation of subjects is strongest. That it abdicated that responsibility, I deduce from the evidence, was for two reasons neither, to my view, justified. It assumed that the CSE Boards would have a majority of school teachers: so they do, but I am assured that, so far as the marking of examination papers is concerned, the GCE Boards also have a majority of school teachers, so it was a false distinction. It was further assumed that the CSE Boards would be 'school based' in the sense that Mode III - the version that teachers in individual schools both set (subject to the validation of the Boards) and mark - would be predominant. I understand that Mode III accounts for only about 25% of CSE examinations. I regret also that the Schools Council abandoned its monitoring function in relation to GCE O level and never assumed it in relation to CSE. In the case of the latter it would have seemed particularly necessary. The school has no choice in the CSE Board used: it is obliged to use the Board appropriate to its locality. In this respect the system differs from that of the GCE Boards where choice at least introduces a degree of competition, and provides an incentive for cross-monitoring between Boards.
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93. However, the Government's acceptance of a common examination at 16+, which will when it is introduced take the place of both O level and CSE, has created a new situation, in which the role of the Schools Council is not yet clear. The present situation is that the Secretaries of State have asked the Boards to devise criteria for the new examinations and the Schools Council is itself considering the subject. Once the criteria have been accepted by the Secretaries of State, taking account of all the advice received, a great deal of detailed work will remain to be done about subjects, syllabuses and monitoring. It is of course for the Secretaries of State to decide how and by whom this is done. Obviously a good deal will be needed from the Boards but it would be surprising if the Schools Council were not invited to do a good deal too.
94. I do not accept the evidence that the lack of success over the years of some of the Schools Council's various proposals on examinations policy of external examinations has caused it to lose 'face' or, in the modern jargon, credibility. An advisory body must expect from time to time that its advice wIll be rejected. Possibly the Council was somewhat ham handed in the way it set about the discussions with other interests. It rushed the universities and polytechnics on its "N & F" proposals by setting unrealistic time limits and it was arrogant in representing to representatives of higher education that they would be "failing in their duty to the nation" if these proposals were not instantly accepted. Universities and polytechnics, well aware that no government in the foreseeable future is likely to find the means to fund four, instead of characteristically three year, courses, were quite right to fight their corner and were not necessarily merely selfish in doing so, for a lowering of standards can work back through the system to affect standards generally.
95. This is not at all to say that what those pupils who will proceed to higher education need to equip themselves for it is necessarily the same as what those need who will not so proceed; nor however is it to say the contrary. To pursue this thought would be to enter into a debate about the value educationally of various kinds of curriculum and corresponding examinations; to do that I should exceed my terms of reference. The point I want to make is that it is misleading to approach these important matters on the assumption of a conflict of interest. The only interest that matters is that of the pupils themselves. The old notion of "Matriculation", at once a school leaving certificate and a guarantee of suitability for higher education, may be outdated, has certainly had to be refined and may have to be refined out of existence. The Council has a useful role to play in discussing which examinations can fulfil several purposes as well as examinations designed for more limited purposes.
96. The way forward in my view is not by giving the Council control over Examination Boards. I do not think that this would be generally acceptable to schools or parents and so I doubt whether any government would be prepared to legislate (as would be necessary to bring this about). Nor is it by assuming that the Council's voice can be sole or even predominant. I suspect that rejection (not by any means always at the end of the day sustained) by successive Secretaries of State of the Council's proposals on examinations policy have created unnecessary resentment by many of the Council's members who have worked hard for change, because of misconceptions about the Council's role and of the position of those of its members who represent the Secretaries of State. This thought leads to my recommendation in paragraph 139 below about the distribution of responsibilities for examinations policy between the Council's committees.
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c. Priorities
97. Here I believe that the Council is weak, principally because the committees, and especially the Professional Committee, have been indecisive. Current criticism attaches particularly to the programmes. When I enquired of the Council's Review Group why each of the five programmes mentioned in paragraph 37 above had received the same budget of £330,000 over three years, I received the answer, in effect, that 'each should have its chance'. This immediately suggested to me that none of them had been properly costed, which I believe to be the case. It fortified my suspicion of compromise on what was selected from the many suggestions put forward and what was rejected. Direct observation of some of the Council's meetings reinforced that view. I observed on one occasion that the Professional Committee having received 'bids' of various kinds (for adding to programmes and financing dissemination of projects) in excess of the funds available was unable to choose between them; and it was therefore necessary for the Finance and Priorities Committee subsequently to do so. The justification for the teachers' majority on the Professional Committee is its qualification to establish educational priorities. I surmise, therefore, that this lack of grip in relation to priorities explains the way the programmes were devised and carried through the Finance and Priorities Committee and the way in which they were funded. This fortifies my view, which I explain later, that there is need for a clearer definition of function and responsibility in the Council's committees.
98. As to the programmes themselves it is an inconvenience of the timing of this review that neither I nor anyone else can comment with any authority on the outcome of the programmes technique. Clearly, by involving so many practising teachers, it has contributed to what some call 'in-service training', a need which many have recognised both before and after the James Report but some claim has never been adequately organised or funded. But if in-service training were to prove the sole justification for the programmes technique it might have been better to direct the financial resources elsewhere, as some of those giving evidence suggested. I personally think that the Council was right to take this new and rather adventurous approach, but whether it is successful in terms of useful generalisation is yet to be proved. The programmes themselves are funded only until 1983 and it will probably take much longer to establish their usefulness. What is reasonably clear already is that they are all underfunded, especially when dissemination is taken into account, and there must be doubt about the adequacy of the arrangements for monitoring and evaluation. I make no recommendations specifically on these points but I have had them in mind for what I say later about the responsibilities of the Finance and Priorities Committee.
d. Cost and Accountability
99. On this I have to say, first, that work of the kind being done by the Schools Council can to my mind never be shown to be cost effective or non-cost effective (but in this context I mean 'work' as distinct from 'establishment'). Secondly, I have no fault to find with the formal accounting procedures.
100. The criticism that because it is left free to determine how it spends its resources the Council is. at the end of the day. not properly accountable to central and local government is to my mind 'refutable because its 'paymasters', when they combine, are represented by a majority on the Finance and Priorities Committee. That is where accountability should be enforced: if it is not in practice so enforced it is up to the representatives of the 'paymasters' to see that in future it is.
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e. Wales
101 The question whether Wales should have a separate budget for curriculum development is one for the Council itself. The position of the Committee for Wales I discuss in paragraph 148 below.
f. Publication
102. I have summarised the evidence. To an extent it is a technical matter. I have neither had the time nor the necessary access to expert advice to form an opinion.
I recommend that the Council's Publications Committee consider the Council's publications policy generally; in particular whether it would be an advantage to have a business manager and in such a case whether there is a continuing need for that committee; and report to the Finance and Priorities Committee.
g. 'Style'
103. I endorse the criticisms in paragraph 61 above and add one of my own. I personally found the anti-intellectual flavour of some of the discussion in the meetings that I attended tiresome and unnecessary; certainly I never heard the word 'academic' used save in a pejorative sense. I also believe that public esteem for the Council would be enhanced if its members were better mannered in discussion, and in some cases used language more precisely and less evocatively. However, these are hardly matters for recommendation. The Council alone can be the guardian of its own reputation.
h. Opinions
104. I, too, have my prejudices. But if we are to retain a body (and I have already made it plain that I think we should) for curriculum and examinations, it must have freedom to commission its work and freedom (not obligation) to publish what it commissions. There is no point in seeking to restrain the range of its enquiries beyond what its common sense and the limit of its resources dictate, or to prescribe the style of its publications. It is bound to be prey from time to time to the fashionable and the sensational. Perhaps some resources are expended in ways which some of us (and we should no doubt disagree among ourselves) consider trivial or unsuitable; these resources will hardly be large. In my view a limited degree of waste is a small price to pay for keeping the system open. The ultimate safeguard is that no teacher is obliged to use the products of the Council's work and here again its reputation is in its own hands.
Organisation
Representation
105. It was proposed to me in evidence that it would be more satisfactory if the teaching interest in those of the Council's committees the membership of which is prescribed in the Constitution could be provided by bodies more representative of teachers professionally, for example the subject associations. The Schools CounCil Review Group suggested that the help of these associations should be more generally invoked (though not with membership of the main committees in mind) and I agree with that. But they could not in practice represent the whole of the teaching interest on the Council partly because the subject associations are not fully comprehensive. Moreover it seems to me reasonable that a considerable part of the teaching interest should be supplied
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by representatives of the teachers' associations. The Council needs the experience of various kinds of teachers, for example heads and assistants and of teachers in various kinds of schools.
106. I do not accept the principle of multiple representation by the teacher associations prescribed for these committees nor the reasons adduced for it. Teachers join trade unions, I suppose, for much the same reasons that other workers join other trade unions; that is, in regard to pay, conditions of service, protection against redundancy, accident and other misadventures. But a trade union of teachers is not a collection of teachers acting primarily in their professional capacity as teachers, and I see no rational argument for multiple representation of teachers' associations by reference to the size of membership, given the reasons for which their members join.
107. Moreover, multiple representation by these associations gives rise to multiple representation by other bodies in order to preserve what the architects of the Constitution of 1978 thought the appropriate balance of interests within certain committees, in particular the Finance and Priorities Committee and the Professional Committee. (The fact that, so far as I could observe, the Council rarely uses votes in practice does not affect the reality of the balance of interests.) The nominating bodies of the members who serve on the principal committees are set out in the Constitution (Annex II). The following table shows for each of them: total number of members; number of institutions with multiple representation; number of members representing those bodies.
(a) Committee | (b) Total Membership | (c) Institutions with multiple membership | (d) No. of Members representing (c) |
Convocation | 56 | 9 | 32 |
Finance and Priorities | 28 | 5 | 21 |
Professional | 37 | 8 | 28 |
Examinations | 32 | 6 | 24 |
Primary Curriculum | 20 | 4 | 15 |
Secondary Curriculum | 24 | 4 | 13 |
Committee for Wales | 22 | 5 | 15 |
It is perfectly possible to preserve the balance of interests in smaller committees if multiple representation is reduced.
108. On the question of rotation of membership the Council must be open to new ideas; and that implies fresh blood from time to time. The original arrangement of a succession of joint secretaries of short tenure was rightly discarded in the present Constitution. But the reason for the original arrangement (paragraph 23 above) was good. Now that there is a permanent staff, the time has come when there should, in my view, be a term to the period of service of all members of standing committees. The balance between the value of experience and the value of fresh approaches is an awkward one in any institution. Any fixed rule will involve some loss of particularly valuable individuals; but no change will ever take place without a fixed rule. The Council should in future allow the institutions concerned to appoint their representatives for all the standing committees entirely on their own discretion, as now, but for a fixed period of four years; and permit them to nominate the same representative for a further maximum period of four years though the committee concerned should have the power to accept or reject a proposal for renewal. If a proposal for renewal
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were rejected this should not prevent an institution from nominating the same representative for service on another of the Council's committees for four years. No individual should serve more than eight years in total on the standing committees of the Council.
I recommend that there should be a fixed term to membership on standing committees as described above.
Such a system could not be abruptly introduced. It would be necessary for the Council to arrange "staggering", with some reference to the length of service of its present members but it should agree within a year on how this should be done.
109. I recommend some restriction on the use of alternates, specifically that no member of a standing committee (that is a committee prescribed in the Constitution) should be an alternate for more than one other standing committee and that the procedure for the rotation of alternates should be the same as that recommended for members.
Committee structure
110. In proposing changes in the Council's committee structure I have had in mind the following principles:-
a. to preserve the spirit of the 1978 Constitution, which sought to provide as open a system as possible in order that ideas might emerge from many sources within the Council; but
b. to create a hierarchical structure with clearer definitions of powers and advisory functions of the various committees;
c. to provide the Council with sufficient flexibility to adapt its arrangements as the direction of its policy from time to time requires but at the same time to ensure that conscious decisions are taken (and the cost considered) when such adaptations are made;
d. to reduce the number of standing committees;
e. to reduce significantly the number of members of the standing committees while preserving the principle of wide representation;
f. as far as possible to abolish (and where that is not possible significantly to reduce) multiple representation of institutions on committees;
g. to maintain the majority of central and local government interests on the Finance and Priorities Committee and of the teaching interest on the Professional Committee;
h. to bring curriculum and examinations into closer proximity.
111. Before I apply these principles in detail some of them require further explanation.
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a. The principle embodied in the Constitution of 1978 of a division of powers between the three main committees as equal partners was a good one. There seems however a general consensus that it has not worked out in practice as it was intended. Perhaps it demanded too much of a body which needs to take decisions, on occasion quickly. Certainly the technique of programmes which was adopted soon after the Constitution was introduced has had practical effects on the Council's operations, the extent of which could probably not have been foreseen. The result has been the underemployment of some of the machinery prescribed in the Constitution and the use, to my mind not always sufficiently controlled, of ad hoc machinery in its place.
112. b. A careful reading of the Constitution shows that in fact specific functions are assigned to the various Committees. They are not always perhaps sufficiently closely drawn; but the real source of confusion probably lies in the requirements of the main committees to consult each other which creates a rather complex system of 'cross-referencing', the purpose of which was of course to give effect to the equality of powers. In any case it is now clear that there is confusion within the Council, and still more outside, about the source of decisions on given matters. Perhaps because of this a hierarchical structure has emerged with the Finance and Priorities Committee at its apex. It is timely to recognise this, to define more clearly the responsibilities of each committee and their relationship with each other; in a hierarchical system cross-referencing is not needed.
113. c. The Council is not committed to continuing curriculum development by means of the programmes technique indefinitely in the future. It could spend all its resources for new work on curriculum development in that way; it could revert to discrete projects exclusively; it could, as will soon be the case with the introduction of the new project to review the Secondary Science Curriculum, divide the resources between programmes and discrete projects; it might devise techniques different from either, and as yet unforeseen. Sensibly, it wishes to keep its options open. This makes it difficult, however, to suggest a structure which would be suitable for all possibilities. In these circumstances it seems best to provide in a revised Constitution for fewer standing committees and give the Finance and Priorities Committee the power to set up additional machinery as necessary and in the form appropriate for the circumstances at the time.
114. d. The main purpose in seeking to reduce the number of standing committees is that of flexibility, mentioned immediately above. But to do so would have other benefits: it would end the frustration of members called upon to spend their time on meetings for which there is insufficient, or no real, business; reduce the amount of staff time required to service them; and shift the proportion of resources at present devoted to variously 'establishment' and 'work'.
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115. f. & g. I consider that, with the partial exception of Convocation, the membership of all the Council's standing committees is too large for effective operation. I am more concerned with effectiveness than cost, though a reduction in the number of members would, too, contribute to correcting the balance between 'establishment' and 'work'. I have gIven (in paragraph 106 above) my views on multiple representation. The way to reduce the size of committees while not reducing the breadth of interest represented is to cut out or, where that is not possible, severely cut down, multiple representation generally.
116. I now apply the principles set out in paragraph 110 above to the Council's present structure. Clearly the provision for Trustees must remain. As to the standing committees, the continued existence of the Finance and Priorities, Professional and Examinations Committees has not been called in question and seems to me essential. The evidence is conflicting on Convocation, the Primary and Secondary Curriculum Committees and the Subject Committees and I give my opinion on each of these, as on the Committee for Wales and the Publications Committee, in turn below.
117. I am in favour of retaining Convocation. I appreciate the arguments against it but it is a novel body which in the nature of the case would need more time than others of the Council's committees to find its feet. I doubt whether it will ever be capable of fulfilling the rather ambitious role originally conceived for it (and I shall say more later about the definition of its functions and about adjustments to its method of work). It is not a parliament, for parliaments legislate and decide: the Schools Council, including Convocation, has no such powers. But parliaments are also 'talking shops' (hence the name); and a forum as widely representative as Convocation is for debate on schools education seems to me, potentially at least, a useful institution.
118. I consider that there is at present insufficient work to justify the existence of the Primary and Secondary Curriculum Committees. I have heard it proposed that they should concern themselves with refining and elaborating 'The Practical Curriculum'. If there is a need for detailed work on the general principles set out in HMI's document 'A View of the Curriculum' 1980, the DES document 'The School Curriculum' 1981, and the Schools Council's document 'The Practical Curriculum' 1981 (and it is not clear to me that there is such a need) it is more likely to call for inclusion in the programmes or projects than to require general exercises by the Curriculum Committees. It has been argued that the Professional Committee is overloaded, with the implication that more work could be delegated to the Curriculum Committees. But it seems to me that in recent years these Committees have not initiated much: most of their business consists of transmitting proposals from ad hoc bodies, or opining on such questions (not very many) as the Professional Committee sends to them. I consider the Professional Committee overloaded not so much by the size of its agenda as by the size of its membership.
119. That is not to say that committees of this kind may not be needed at some time in the future. But they should not have the status of standing committees nor be prescribed in the Constitution. Accordingly,
I recommend that the Primary and Secondary Curriculum Committees be discontinued.
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120. The Subject Committees present a slightly different, and more difficult, problem. Between them they represent a considerable body of serving teachers and the work that they have done in the past has brought credit to the Council. They have been on what might be called a standby basis for some time, since they are required to meet only once a year and need the Secretary's authority to meet more frequently. This arrangement already causes dissatisfaction to the Subject Committees, as well it might.
121. Their A level examination subcommittees clearly have continuing work to do and on one assumption referred to above about the new 16+ examinations considerable further work of this kind may be necessary in future. It is not clear to which body or bodies these subcommittees now report. In future they should report to the Examinations Committee which should appoint their members from a panel of the present members of the Subject Committees afforced as necessary by nominees of subject associations.
122. However, with the exception of the Science Committee (which will be involved in the review of the Secondary Science Curriculum) it is difficult to see how Subject Committees' work on the curriculum which is defined as "to offer advice ... on developments and issues within its subject ... and to make proposals for further work" is to be pursued if the Council continues in future to place the same emphasis as it does at present on the technique of programmes. At the same time it would be wrong to assume that no curriculum development work on individual subjects will be necessary in the future.
123. It is wasteful to keep committees in existence against contingencies and unsatisfactory to members of the Subject Committees to be kept in a state of inanimation. Here again the right course is to set up machinery as and when it is required for a specific purpose. It has been represented that without the Subject Committees there would be no source of initiative for subject curriculum development. But it is open to any organisation (including a subject association) and indeed to individuals to propose to the Professional Committee any subject project for which a good case can be made and, if that Committee recommended it, the Finance and Priorities Committee would have the power to create an appropriate subject committee. Further I recommend below that the membership of the Professional Committee should in future include nominees of the subject associations.
I recommend that the Finance and Priorities Committee determine which of the present Subject Committees need to be retained for work currently in progress, and for how long, and that with any exceptions so determined the Subject Committees and the meetings of the Chairmen of the Subject Committees be discontinued.
124. There is a distinct aspect of schools' education in Wales, deriving from the Welsh language and culture. This distinct aspect is, however, rather small. On the whole the similarities in schools' education between England and Wales are greater than the dissimilarities. Some Welsh problems, in so far as they affect rural areas for example, are the same problems as affect similar areas in England. Naturally, more school children in Wales take examination papers in Welsh language and literature and related subjects than school children in England but the examinations system in the Principality is identical with that in England. Since however there are some distinct interests and since the Secretary of State for Wales has separate powers for education in Wales, it
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seems right that there should be a committee of the Council specifically concerned with Wales and meeting in Wales, although, as I explain below, I thInk its scope and complement should be reduced.
I recommend that the Committee for Wales be retained.
125. The continuance or otherwise of the Council's Publications Committee depends on the outcome of the review on the substance of the question that I have recommended in paragraph 102 above. In any case, I do not think that it should be a standing committee: but a body that the Finance and Priorities Committee has the power to call into being or stand down as necessary.
126. On the basis of the arguments in paragraphs 110-125 above I recommend that there should be five standing committees: the Finance and Priorities Committees, the Professional Committee, Convocation, the Examinations Committee and the Committee for Wales: the first three should be 'main' committees.
127. As to the hierarchical structure, the Professional Committee should be responsible to the Finance and Priorities Committee; the Examinations Committee and the Committee for Wales responsible to the Professional Committee. Convocation should be advisory to the Council as a whole but particularly to the Finance and Priorities, Professional and Examinations Committees. When I say 'responsible' I do not of course imply 'responsible on everything'. It is essential that each of the standing committees has defined functions. In what follows I recommend the functions and membership of the five standing committees. The changes in the Constitution needed to give effect to my recommendations on these and earlier points in this section of the report are summarised at the end of this section.
The Finance and Priorities Committee
128. This Committee should be the body which takes final decisions on overall policy (and not only when these are of a nature to result in advice to the Secretaries of State and local authorities). It should not playas passive a role as it seems to me it has done in the initiation of policy: it ought to initiate discussion on important general questions and will have, as it has now, the power to remit them to other committees for advice.
129. An important part of its function will continue to be the allocation of resources, both of money and manpower. On the former it should take a longer view: the idea of a five year "rolling programme" put forward by the Schools Council's Review Group is a good one. The Council, in common with other educational establishments, is hampered in its planning by not knowing its budgetary provision for, at best, a year ahead. But assumptions can and must be made, as they are made now. I consider that provisional planning for five years ahead is essential and that the Committee should annually review such a rolling programme, as well as controlling the use of the budget from year to year. It should decline to consider any proposals from the Professional Committee unless that Committee makes plain its priorities and the reasons for them.
130. The Committee should keep under review the proportion of expenditure allocated to 'establishment' and 'work'. It should have both the power and the obligation to keep under regular review the subsidiary committee structure of the Council. It should stand down committees no longer needed. Its authority should be required for the establishment of new committees or groups and in
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authorising them it should specify the task and set a term for its completion. It should have the power to determine the membership, though it may well find it sensible to delegate this power on occasion to the Chairman or the Professional Committee or other bodies.
131. Resources of manpower are at least as important as financial resources (and indeed often have long term financial implications). This Committee should keep them under review. For example it should be aware of the obligations that the Council is incurring in relation to staff pensions (and just conceivably, in these hard times, redundancy payments); it should be consulted by the Secretary on any proposals to convert short term into permanent appointments. It should concern itself with the implications for staff in work commissioned by the Council, in terms both of complement, use of staff and finance. In short it ought to exercise a managerial, as well as a policy role. It is significant that some of those who gave evidence expressed doubt as to where ultimate responsibility for staff lies: under the present Constitution it lies firmly on the Finance and Priorities Committee already. I suspect, however, that the Committee has probably delegated responsibility further than to individual staff appointments and probably more than it should have done.
132. The Committee should have the responsibility for determining publications policy.
133. At present changes in the Constitution require the agreement of the three main committees. In future the other two should be consulted by the Finance and Priorities Committee but that Committee should have the power of decision.
134. There is one function of the Finance and Priorities Committee that I would modify. The Committee is at present the channel through which advice to the Secretaries of State on examinations policy is given. While it must continue to have an important function in this matter it should in my view, for reasons that I explain under 'The Professional Committee' in paragraph 138 below, be a more limited one.
135. There is one function that I would add to those of the Finance and Priorities Committee and that is to be the authoritative voice publicly in all matters of important Council policy. Many have commented that it is impossible to determine who 'speaks for the Council'. In one sense there must be a multiplicity of voices: for example many of the papers produced for and by the Council are in the nature of working or similar papers put forward for discussion. It would be absurd to suggest that all such papers and all press statements should be approved by the Finance and Priorities Committee beforehand. Moreover I recommend (see paragraph 145 below) that Convocation should continue to meet in public so that the press will have the opportunity to reflect, as they have now, the views of individual members of the Council. But for major matters of policy communicated publicly, whether in Convocation or elsewhere, the only. authoritative voice should be that of the Chairman of the Council, or those acting for him, on the strength of decisions taken by the Finance and Priorities Committee. I include within this general principle statements about advice on examinations policy, even though I recommend below that the channel of communication to the Secretaries of State should be the Professional Committee.
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136. In Annex IV I set out my recommendations for membership of the standing committees, showing the existing membership for comparison. In the case of the Finance and Priorities Committee the effect is to reduce the membership from 28 to 17 while preserving the proportions between the teacher interest and that of local and central government combined and between those of local and central government separately.
The Professional Committee
137. Although, as I have said above, I envisage the Finance and Priorities Committee's initiating more discussion in future on general questions of policy I think it right that the Professional Committee should continue to be the main committee in which proposals for curriculum development are considered. It is essential that in future it exercise much more rigorous judgement on priorities.
138. In future the Examinations Committee should report annually to the Professional Committee on such recommendations as it has made to the Examinations Boards on subject, syllabus and monitoring activities, and what action the Boards have taken on them. If, as may be the case, the Council is asked to exercise responsibilities in respect of the new 16+ examination, the Examinations Committee should report similarly.
139. On examinations policy the present position (reflected in the Constitution) is that the Examinations Committee submits proposals to the Finance and Priorities Committee and it is the latter that submits advice to the Secretaries of State. The reason for this arrangement was probably that as the Secretaries of State are powerfully represented on that Committee it was assumed that their officials, not dissenting from the Committee's recommendations, would positively recommend them to the Secretaries of State and that Ministers would accept their advice. This double assumption seems to me a double misconception. Given the Secretaries of State's responsibilities under the Education Acts, and the variety of other interests which must be taken into account, it would be more realistic to assume that they will take account of the Council's advice as only one part of the total advice that they need and their officials who represent them on the Council will never be in a position to commit them in advance. In terms of function and membership the Professional Committee is better fitted than the Finance and Priorities Committee to consider examinations policy. If it in turn was required to report to the Finance and Priorities Committee two main committees instead of, as now, one would need to be concerned with the proposals as a whole. It is therefore preferable that the Council's advice to the Secretaries of State on examinations policy should be put forward by the Professional Committee. However, cost will always be an important consideration for the Secretaries of State. So the Examinations Committee with the help of its members from the Examinations Boards and the Council's Finance Officer should always prepare estimates of costs of proposals for consideration by the Finance and Priorities Committee, whose comment on these should be quoted by the Professional Committee in submitting its advice.
140. Representatives of the CSE and GCE Boards at present serve on the Professional Committee as observers. So far as curriculum is concerned that seems satisfactory. The present Constitution provides that "when considering questions of examinations policy the Committee shall invite the participation of additional representatives of the GCE and CSE Boards". I understand that this provision has never been invoked, probably because in practice the Committee has hardly ever discussed examinations. With the Professional Committee's enhanced responsibilities in this field it is important that when examinations are
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discussed two representatives each from the GCE and CSE Boards should attend as members. On membership generally (Annex IV) my proposals do not add to, nor subtract from, the list of bodies represented but do require changes in status as between members and observers in both directions; preserve the overall majority of school teaching interests but create this majority in part by the addition of members nominated by the subject associations as well as by the membership of the chairman of the Examinations Committee ex officio, while reducing the representation of the teachers' associations; they reduce representation of the Secretaries of State to allow only for one DES official and one HMI, excluding the official interest of the Secretary of State for Wales in compensation for making the chairman of the Committee for Wales an ex officio member (in parallel with the membership ex officio of the chairman of the Examinations Committee) instead of, as before, an observer. Some institutions at present nominating members would in future nominate observers. The effect of the proposals is to reduce the size of the Committee from 37 members and 9 observers to 22 members and 8 observers so that the total would be reduced from 46 to 30. This is still an uncomfortably large body but the Professional Committee is central to the Council's operations and breadth of representation is important. Even with that size it should be possible for the Secretary's staff to circulate better considered papers further in advance of meetings.
Convocation
141. Convocation's present functions are set out in clause 11 of the Constitution. Convocation should have the power as now to debate over a wide range. I see its role as essentially advisory, however, and specifically to the Finance and Priorities, Professional and Examinations Committees. While clearly Convocation, as any other committee, can ask for information through the Secretariat from other parts of the Council I do not consider it appropriate that it should be able to require reports from other committees. I do not think it appropriate that it should "provide reports ... for general circulation". It is consistent with what I have proposed earlier that the Finance and Priorities Committee rather than Convocation should approve the annual report.
142. None of these changes would affect the work for which Convocation is useful or greatly affect what it has been doing in practice. But they would give more precise definition to Convocation's role.
143. In common with the other main committees Convocation meets once a term. It.is, however, the one body for which, on the evidence of the Council's Review Group, the Chairman and Secretary have on occasion to contrive the agenda. Nobody can justify meetings (especially such expensive ones as those of Convocation) unless there is genuine business. The other committees will continue to consult Convocation as they see the need. Moreover there is scope at present for its members themselves to initiate business; this will remain. Where, however, on a particular occasion the business generated by other committees together with that proposed by the members themselves does not produce agenda justifying a particular meeting of Convocation that meeting should be cancelled.
144. This is the more necessary because Convocation seems to me the body of the Council on which the widest representation is desirable and where size is not, as it is in the other committees, an impediment to effective prosecution of business. My recommendations on membership (Annex IV) reduce multiple representation though less drastically than for some of the other standing
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committees and permit those bodies, which at present "acting jointly" nominate one representative between them, to nominate one each. They reduce the membership of Convocation from 56 to 46.
145. The tradition is that the press are present at meetings of Convocation: many of those giving evidence have suggested that this encourages 'playing to the gallery'. I do not doubt that it does and that this damages to an extent the Council's reputation. On the other hand I think the press quite able to evaluate this element and discount it: it does more harm to the reputation of the organisations who play to the gallery than to the Council itself.
The Examinations Committee
146. The present functions are set out in clause 21 of the Constitution. No change is proposed in functions but in consequence of the recommendations at paragraphs 127 and 139 above some rewording is necessary. The sub-committees on examinations should be appointed by the Examinations Committee from a panel of members of the present Subject Committees as afforced by nominees of subject associations and report to the Examinations Committee.
147. The recommendations for membership of the Committee generally follow the present pattern save that the NFER and the local authority advisory service would be represented by members rather than observers. The general principle of reducing multiple representation is applied. The result is to reduce the members of the committee from 32 to 21, the assessors from 3 to 2, the observers from up to 7 to up to 4; and the maximum size of the Committee therefore from 42 to 27.
The Committee for Wales
148. The functions of the Committee are set out in clause 25 of the Constitution and I propose no change in them. But the "special needs of the schools and pupils in Wales", though justifying the continuance of the Committee do not justify its present structure which seems to me unnecessarily elaborate. I see no need for primary and secondary curriculum committees: the Committee itself should do their work. Of the five faculty committees I would retain only one (that for Welsh) and even that not on the basis of a standing committee. With the approval of the Finance and Priorities Committee the Committee for Wales could set up groups (either by subject, groups of subjects or any other basis) ad hoc as required. As to membership (Annex IV) my recommendations abolish the distinction between members and co-opted members, apply the usual principle of reducing multiple representation and add two members nominated by subject associations. The Committee is reduced from 27 to 20 members and the total size from 30 to 23.
149. I recommend that the functions and membership of the standing committees be as described in paragraphs 128 - 148 above.
Changes to the Constitution
150. To give effect to the recommendations in paragraphs 108, 109 and 149 the following amendments to the Constitution are required. (The references are to the clauses of the Constitution).
Clause 10
1. Delete "The Primary Curriculum Committee", "The Secondary Curriculum Committee" "The Publications Committee". (If following the review recommended in paragraph 102, the Finance and Priorities Committee decide to retain the Publications Committee, it should not be as a standing committee).
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Replace the last subsection by "Such committees, having such functions and composition as the Finance and Priorities Committee shall determine".
2. Substitute "The Finance and Priorities Committee may delegate its functions. The other committees named in sub-clause 1. above may delegate their functions subject to the agreement of the Finance and Priorities Committee".
3. Delete "after consultation with the Professional Committee and Convocation".
Between 3 and 4 insert new subsection: "An appointing body may appoint its representative on any committee named in sub-clause 1. above for a period of four years; it may nominate the same representative to service for a further period of four years on the same committee, but that committee shall have the power to accept or reject the nomination. No representative shall serve on any such committee for a period exceeding eight years in aggregate, whether the service is on one committee or more than one in that period."
4. Add "provided that no member of a committee named in sub-clause 1. above shall serve as an alternate to more than one other such committee."
Convocation
Clause 11
b. Delete.
d. Delete "or require reports from".
c. Delete.
The Finance and Priorities Committee
Clause 13
Between b. and c. insert a new sub-clause "To authorise any public statement on general policy made on the Council's behalf ."
d. Substitute "To comment to the Professional Committee on the of any proposals for examinations policy submitted by the Examinations Committee."
e. - g. Delete.
i. Substitute "After consultation with the Professional to Committee to determine" for "To agree with the Professional Committee."
j. Substitute "To determine the constitution of committees and sub-committees not defined within the Constitution; keep under review any such committees and sub-committees; authorise when it sees fit, on the proposal of any committee named in clause 10 a. the establishment of any such committees or sub-committees; specify the term of office and determine the membership."
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The Professional Committee
Clause 15
c. Delete "and to request ... Schools Council Publications" Substitute "Determined by' for 'Agreed with"
d. Substitute "To submit to the Secretaries of State any proposals on examinations policy; such proposals shall include the comments of the Finance and Priorities Committee on the estimated cost. When considering questions of examinations policy the Committee shall afforce the representation of the GCE Boards and the CSE Boards; as shown below."
e. Delete "by Convocation or". Substitute "other committees of the Council" for "other bodies".
The Schools Council Committee for Wales
Clause 25
2. Delete the section beneath the list of membership from "The Committee may appoint ... Parent Teachers Association".
Add new subsection:-
"5. Subject to the approval of the Finance and Priorities Committee to set up subcommittees. The Chairman of any such subcommittee, if not a member of the Committee for Wales, shall attend meetings of the Committee as an observer."
Subcommittees of the Committee for Wales
Clause 26 Delete
Amendment of the Constitution
Clause 29 Substitute
"1. The Finance and Priorities Committee may amend this Constitution provided that
a. That Committee has first consulted the Professional Committee and Convocation;
b. Each member of the Finance and Priorities Committee, the Professional Committee and Convocation shall have been given one month's notice in writing of the term of the proposed amendment and the date of the meeting of the respective committees.
2. No amendment shall be valid the effect of which would be that the Schools Council ceased to be a body established for charitable purposes only."
151. The composition of the committees set out in clauses 12 1., 14 1., 16 1., 22 1., and 25 2., should be amended to bring them into line with Annex IV.
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152. Although it has nothing to do with my recommendations on the substance there is a minor error in clause 8 of the Constitution. Sub-clause 1 should read "The Deputy Chairman of the Schools Council hereinafter called the deputy chairman."
153. I recommend the changes to the Constitution described in paragraphs 150 - 152 above.
Chairman and Staff
154. The office of Chairman of the Schools Council is both onerous and crucial. I considered the suggestion in the evidence that it should be both permanent and paid. I paid particular regard to the present Chairman's opinion that a part time Chairman, carrying out his own permanent job elsewhere in the educational field, and therefore in touch at first hand with educational developments that affect him in that capacity, is likely to carry more weight as an acknowledged practitioner than a full time Chairman would. There is now a full time Secretariat which ought to be capable of carrying the load not only of the day to day work but of a certain amount of thinking ahead about policy; and the recent addition of a part time Director of Studies should help in this respect. I therefore propose no change in the present arrangements.
155. I have no doubt that it has been an improvement to have a largely permanent staff. The consequences of diminishing the number and size of committees should remove undue strain and release more time for servicing essential work of the Council. On the difficult question whether the Secretary and his staff exercise too much or too little power I make two observations. Where there is uncertainty about the functions of committees, staff are always in a difficult position: if action is necessary they will have to act, possibly in excess of what some may consider their proper powers, but they should not be blamed for it. Secondly, I hope and expect that with more precise definition of the responsibilities and powers of the remaining standing committees (and especially those of the Finance and Priorities Committee) the Secretary and his staff will at the same time have greater freedom of action from day to day and greater certainty of the framework within which they act.
156. There is an additional matter which could not be conveniently treated at an earlier point in this report. Many of those who gave evidence, particularly but not exclusively on behalf of organisations represented on the Council, expressed the opinion that this Review was premature. They pointed out that the present Constitution has been in operation only since September 1978. Some thought that an external review was in any case unnecessary since the Council has the power itself to alter the Constitution. It is not for me to comment on either point. I do however draw attention to the fact that any external review creates uncertainty in an organisation (including the staff) and a good deal of work which must be at the expense of the work that the organisation was set up to do. Therefore
I recommend that the Schools Council should not be the subject of another external review for at least five years from the date of this report.