Dear Cabinet Members of Bridgend County Borough Council,

We, the undersigned, urge you to urgently reassess the home-school-transport policy, agreed by Cabinet members on 10th September 2024, for the following reasons.

In 2024, the Children’s Commissioner for Wales published a report highlighting a critical loophole in local authorities’ obligations to risk-assess walking routes.

In publicly available documents regarding the removal of home-school transport within the borough, the council acknowledges that active walking routes have not been assessed since 2017, furthermore, in determining ‘safe’ or available walking routes, the council determined that ‘well-travelled or main arterial routes’ were considered safe or available without need for assessment and produced twelve reports of routes that were assessed.

In 2021, Road Safety GB published updated guidance on the Assessment of Walked Routes to School and noted that even if it is suggested a route is not hazardous, a site survey must still be carried out.

The twelve reports cover seven comprehensive schools within the borough. Additionally, six primary schools out of 39 had walking routes assessed. Of these six, five primary schools were within a 10-mile geographical radius of one another, with the sixth being an average of 16 miles from the other five.

Notably, the five primary schools assessed within a ten-mile radius were also confined to a small geographical area, where the demographic needs, transport links and traffic flow are vastly different to other areas within the county.

As such, these six assessed routes cannot accurately reflect and do not determine the safety of all walking routes directly to and from primary schools across the entirety of the borough. Furthermore, the six assessed routes do not accurately reflect the public transport links and availability across the whole borough.

The Welsh Government states that for a route to be deemed available or safe, the route needs to be:

Moreover, the Learner Travel Statutory Provision and Operational Guidance highlights that local authorities must consider any proposals that might impact the safety of walking routes, such as infrastructure and increased traffic flow.

Under the Learner Travel (Wales) Measure 2008 provisions, local authorities have a statutory duty to: ‘Assess the travel needs of learners in their authority area and must also consider the learner's age and the route the learners are expected to take between home and the place where they receive education or training.’

Moreover, the Measure states that Local Authorities must consider that the travel arrangements they make must not cause unreasonable stress levels, take an absurd amount of time or be unsafe.

Article 12 of The United Nations Convention on the Rights of the Child states that children have the right to say what they think should happen when adults are making decisions that affect them, and to take their opinions into account.

In asking pupils how they felt about the withdrawal of transport for all learners benefitting from an identified and available (safe) walking route, 62.8% of pupils who responded, did not agree, with the most cited reasons being the impact on education after walking up to 6 miles per day, safety, particularly in winter months and the effect on mental well-being. Pupils also raised issues regarding the insufficiency of public transport in the area and questioned whether school facilities can support the introduction of the proposal, such as locker spaces or somewhere to dry clothes/shoes.

With respect to the above, we believe that the Bridgend Council has exploited critical loopholes in its obligations to ensure the safety of all learners within the borough. As such, we implore the council to reinstate the home-school provision and take appropriate steps to ensure that all walking routes for school-aged pupils are adequately assessed.