Guidance

Installing temporary buildings on RAAC-affected school sites

Published 31 October 2023

Applies to England

Overview

This guidance shares best practice on installing temporary buildings when they are needed on school sites that are affected by reinforced autoclaved aerated concrete (RAAC).

It is for:

• local authorities
• school leaders and governing bodies in all maintained schools, academies and free schools
• contractors working on behalf of responsible bodies or the Department for Education (DfE)

There is separate guidance for responsible bodies and education settings with confirmed RAAC.

This guidance is to support those who plan to install RAAC-related temporary school buildings under permitted development rights, specifically schedule 2, part 4, class CB of The Town and Country Planning (General Permitted Development) Order 2015 (as amended).  

Class CB is a time-limited right which expires on 24 October 2026. It allows schools to install temporary buildings, without having to submit a planning application to the local planning authority, subject to limitations and conditions.

This does not affect other consents that may be required, such as building regulations, which continue to apply.

Some schools will have more options than others for where they can locate temporary buildings while RAAC-affected buildings are mitigated or remediated .

This guidance provides advice on minimising any negative impacts of temporary buildings. When a negative impact is unavoidable, responsible bodies should discuss with their DfE caseworker and other partners, weigh up the implications and decide which option is preferable overall.

Limitations and conditions for class CB

Details of the limitations under class CB can be seen in full in schedule 2, part 4, class CB of The Town and Country Planning (General Permitted Development) Order 2015 (as amended).

The right does not apply if the temporary building is placed on land which is, or forms part of:

• sites of special scientific interest
• safety hazard areas
• military explosives areas
• land which is a scheduled monument or within its boundaries

Temporary buildings:

• cannot be installed within 5 metres of a boundary with residential land
• cannot exceed 2 storeys or 9 metres in height
• cannot have a combined floor space which exceeds 125% of the combined floor space of the parts of buildings vacated due to the presence of RAAC
• must not result in an increase to the school’s published admission number, as detailed in the school admissions code
• must be placed to minimise, as far as practicable , any reduction in the amount of land used as playing fields and space available for parking or turning
• must be removed once RAAC-affected buildings on the school site have been remediated or replaced, or before the right expires on 24 October 2026, whichever comes first

The school must notify the local planning authority and the relevant fire and rescue authority before the development begins or as soon as reasonably practicable after it has begun.

As soon as reasonably practicable, following the removal of temporary buildings, the land where the temporary building was placed must be restored  to its condition before the development took place.

Temporary accommodation for pupils displaced by RAAC-affected buildings cannot be placed on separate school sites, such as a satellite site for the school or another school within the same multi-academy trust. This would lead to an increase in pupils at the site accommodating the temporary buildings (even if they are not on roll at that school), which is not permitted under class CB.

There are other permitted development rights that may be useful for schools requiring urgent temporary accommodation, such as:

• GPDO schedule 2, part 4, classes C and CA (temporary use of buildings and vacant commercial land for state-funded schools)
• GPDO schedule 2, part 7, class M (covering extensions and alterations to schools)

Notifying the local planning authority

Schools must notify the local planning authority and the relevant fire and rescue authority that they are using class CB to provide temporary buildings. In notifying the local planning authority and fire and rescue authority, the school must provide:

• a written description of the development
• a plan showing the development and any buildings on the school land
• the start date or expected date for development
• the address of the school
• the school’s contact address
• confirmation that there is a RAAC-affected building on the school site
• the total floor space (in square metres) of school buildings that have been vacated due to RAAC
• the total floor space (in square metres) of the temporary buildings being provided

If schools cannot notify the relevant authorities before the development takes place, for example because the temporary buildings were installed before this right came into force, they should send the notification as soon as reasonably practicable.

In most cases we would expect schools to have notified the local planning authority and fire and rescue authority within 8 weeks of temporary buildings being provided on site.

Sport and recreation

Responsible bodies must aim to avoid, as far as practicable, any reduction in the amount of land used as playing fields. However, we recognise that some temporary loss of playing fields may be unavoidable.

The Town and Country Planning (General Development Procedure) Order 1995 (as amended) defines a playing field as “the whole of a site which encompasses at least one playing pitch”. A playing pitch is a “delineated area which, together with any run-off area, is of 0.2 hectares or more” and is used for sports such as football, rugby, cricket, and hockey.

The School Standards and Framework Act 1998 defines ‘playing field land’ as “land in the open air which is provided for the purposes of physical education or recreation other than any prescribed description of such land”. This includes most outdoor space on school sites, though it excludes:

• access land
• roads
• paths
• parking areas
• drop-off spaces
• refuse and recycling areas

Guidance on involving the Secretary of State for Education in land transactions provides further detail about types of playing field land and other types of land that are not included in the definition.

It is important that schools continue to meet their curriculum requirements for physical education and sport, so schools should aim to avoid putting temporary buildings on land which is used to deliver the PE curriculum, such as sports pitches (including the maintenance of adequate safety margins) and playgrounds.

Where no other suitable land is available within the site, schools may prefer to put temporary buildings in informal areas without environmental constraints, that fall within the broad definition of ‘playing field land’ but are not actively used for PE.   

When there are no suitable alternatives to using land used for PE and sport, schools may need to find offsite solutions for delivering the curriculum. DfE can assist with the revenue costs associated with this, such as transport and rent of offsite facilities, as set out in the guidance for responsible bodies and education settings with confirmed RAAC in their buildings.

If there are any pre-existing arrangements for the local community to access facilities, we encourage responsible bodies to maintain this where possible.

Temporary buildings provided under class CB cannot lead to a permanent reduction to the amount or quality of playing field land.

When temporary buildings are removed, the school land on which the temporary building was placed must be restored to its condition before the development took place. Class CB does not impose a time limit for this, but in most cases we would expect responsible bodies to reinstate playing fields within 12 months of the temporary buildings being removed.

Schools may wish to use photographs or tools such as Pitch Power to make a record of the site’s condition before the development took place, to help with restoring or improving the site in future.

When planning the reinstatement of playing fields, we recommend that responsible bodies have regard to Sport England design guidance and specifications for different sorts of outdoor surfaces to ensure the reinstatement is fit for purpose.    

Transport considerations

When siting temporary buildings, responsible bodies need to be mindful of maintaining sufficient parking and turning areas, safe and inclusive access, and active travel opportunities.

Parking and turning facilities

In some cases, the most convenient location for temporary buildings under class CB will be an area of hardstanding used for parking  cars and bicycles. However, class CB requires that buildings are placed to minimise, so far as practicable, any reduction in the space available for parking or turning.

Responsible bodies should consider the impact that the loss of space available for parking and turning will have on the safe operation of the school, and any impact on the local road network. It is important to maintain appropriate drop-off and pick-up areas, without detriment to nearby residents or highway safety.

Responsible bodies should assess the amount of existing parking (both motorised and active) and turning facilities when deciding whether to install temporary buildings on formal parking areas. If necessary, they should consult with the relevant transport authority. If there is an excess of onsite parking and turning facilities, a temporary partial reduction may not have a significant impact.

When schools need to retain as much parking space as possible, responsible bodies can explore options for informal parking elsewhere on the site to minimise any net loss, while considering the importance of retaining playing pitches and playgrounds.

Travel to and from school

It is important to retain and, where possible, enhance opportunities for active travel to and from school. If temporary buildings result in an obstruction to or loss of a footpath or cycle route through the school site, we recommend this is replaced in an alternative location within the school site, while considering people’s destinations and the convenience of this route.

Due to the impact additional pupils and associated vehicle trips would have on the local road network and space for parking and drop-off or pick-up, class CB only allows temporary buildings to be installed on the same school site that has RAAC-affected buildings. It does not permit development which would result in an increase to the school’s published admission number.   

This means that any intensification of the use of a school, through additional pupils attending the school site is not permitted by class CB, and in these circumstances temporary buildings would require planning permission.

Developments that involve new or altered access into the school site may also require planning permission.

Protecting the environment

When installing temporary buildings, responsible bodies should consider the impact on the environment, including implications for flood risk, trees, soil compaction, air quality, and protected landscapes.

Flood risk

When considering the most suitable location to site temporary buildings, we advise responsible bodies to consider any known flood risk at the site and avoid installing temporary buildings:

• in flood zones 2 or 3
• close to any watercourse
• close to any flood defences

Get flood risk information for planning in England provides maps and information on flood zones and estimated flood levels.

If temporary buildings cannot be sited outside flood zones 2 or 3, responsible bodies should:

• have an emergency plan that considers severe weather such as flooding
• sign up for any relevant flood warnings to inform their emergency plan
• aim to raise temporary buildings above estimated flood levels (without exceeding 9 metres)
• ensure safe routes for access and escape are provided

There is guidance on emergency planning and response for education, childcare, and children’s social care settings.

If temporary buildings cannot be sited away from watercourses and flood and sea defences, responsible bodies will need to check if they need permission to do work on a river, flood defence or sea defence.

Responsible bodies should consider the potential for a development to increase or exacerbate flood risk for surrounding areas, for instance through increased surface water run-off. Responsible bodies should factor water recycling and suitable drainage solutions into decisions about siting temporary buildings.

Soil compaction

Wherever possible, temporary buildings should be installed in a way that minimises soil compaction and promotes long-term soil health, with a view to reinstating the site to its former, or an improved, condition when temporary buildings are removed.

Soil compaction can contribute to flooding, and we recommend that responsible bodies have regard to the code of practice for the sustainable use of soils on construction sites when procuring temporary buildings and working with contractors on their method of delivery.

Contamination

It is important to consider any risks from land affected by contamination, indicated by previous land uses at the site. While the risk of contamination may be low on long-established school sites, there should be a proportionate assessment of chemical and asbestos contamination as part of the preparation for ground works for temporary buildings.

Responsible bodies should consider potential ground contamination when laying new water supply pipes – the Drinking Water Inspectorate provides advice on these risks.

They should also consider risks to groundwater in groundwater protected areas, such as source protection zones or drinking water protected areas. It is important that mitigation is in place to avoid the risk of leaks from foul drainage entering groundwater.

If temporary buildings cannot be connected to a foul sewer, responsible bodies or relevant contractors should contact the Environment Agency for advice regarding the method used for non-mains sewage discharge.

Trees and air quality

When deciding where to site temporary buildings, consider the root zones and canopies of trees and the potential for buildings to compromise tree health.

Works to trees may require consent or a prior notification to the local planning authority, if they are protected by a Tree Preservation Order or located in a conservation area.

The Wildlife and Countryside Act 1981 and the Conservation of Habitats and Species Regulations 2017 give legal protection to species and habitats, which may be affected by the works. If the works to install temporary buildings will involve disturbing or removing protected species such as newts or bats, you may require a wildlife licence.

It is important to retain and protect trees on school sites, as they provide valuable shade, wildlife habitat, and carbon sequestration, as well as enhancing the general environmental quality of the outdoor space.

Trees and other vegetation can also provide a beneficial barrier between roads and a school’s buildings and outdoor space, reducing the effects of air pollution. Responsible bodies should consider air quality and avoid siting temporary buildings close to a source of air pollution, such as a busy road.

Visual impact

It is good practice to minimise the visual impact of development, even when buildings provided under class CB will only be in place for a limited period.

Temporary buildings that blend reasonably well into their surroundings, due to careful consideration of size and colour schemes, will have less visual impact in the landscape and may be more acceptable to local communities. This is particularly important in nationally protected landscapes such as National Parks and areas of outstanding natural beauty.

Fire safety

Class CB requires schools to notify the relevant fire and rescue authority either before the development begins or as soon as reasonably practicable afterwards. They should include details such as a written description and a site plan showing the development.

Schools must have a fire risk assessment and fire strategy management plan, and these should be in line with guidance on fire safety risk assessment in educational premises.

Responsible bodies should ensure that relevant assessments and plans are updated to take account of temporary buildings and any changes to the operation and movement around the school site.