Your views
7. Please share your response below.
Please share your response below.
(Required)
Feedback on ARB introduction of fees
• Anything further that ARB should consider regarding how the fees are to be paid. For example, whether there is anything you would like us to know about the timing of learning provider budget setting and the timing at which we invoice for the fees.
The Centre for Alternative Technology is a unique institution dedicated to researching and teaching and disseminating positive solutions for environmental change. Our Graduate School of the Environment courses are respected across the world, providing a big-picture, integrated approach to sustainability and the knowledge, skills, inspiration and networks to make a real practical difference. We have a number of postgraduate degrees wholly focussed on this mission but only one ARB-accredited course, the M.Arch in Sustainable Architecture, which is validated by the University of East London (UEL) and has fewer than 50 students in total.
We dispute the assertion that the size of the learning provider has minimal impact on the ARB’s work. An organisation the size of CAT with a single part II course and 50 students is far less complex than for example the Bartlett School with 3,360 students (2018-19 data) and 6 undergraduate and 19 postgraduate programmes. As you have stated the law is clear that fees must not exceed the reasonable costs of providing the service.
As a small specialist school of architecture with only one ARB accredited course with less than 50 students (currently there are 36 students across both years), a £9,200.00 per annum fee payable to ARB becomes a significant proportion of our budget which is shown below.
As an alternative provider, our course fees per student are around 2/3 of the fees available to standard university courses). Our income is around £250- 280K per year from the MArch students (student numbers are variable).
When our budget is set: Staff Salaries and visiting lecturers; Student support and Admin; Accrediting University fees; Acommodation; Subscriptions and External Quality Assurance (QAA) accounts for around £235K of this which leaves around 20K-40K for materials/travel and overheads to CAT for operating the site. In normal University practice, £60-70K would be a reasonable overhead figure for a HE course of the MArch size to the organisation, however a normal HE Part 1 or Part 2 course would have fees of £9250 per student per year i.e 1/3rd more than CAT, with many accredited organisations also having students for an additional three years.
In addition CAT does not receive any other statutory funding from Government or HEFCW (the Welsh equivalent to the office for students); just UG fees for Part 2 architecture students. As an alternative provider unlike Universities, CAT is unable to apply directly for UKRI research funding, which can also be a source of income to an institution. Our only other sources of income would be a proportion of general fundraising by Centre for Alternative Technology, but that is not significant as much of it is restricted project funding rather than core funding, and the core funding would support the general overheads.
Consequently, the proposed fee charged by ARB to CAT equates to around £200 per student per year or £400 in total. When compared to larger schools of architecture with perhaps 10 times the number of students at undergraduate ad postgraduate level this rigid ‘one size fits all’ fee is inequitable. Using the example of the Bartlett School given earlier the £9200 annual fee would be equivalent to £3 per student per year. It means in effect, that students studying at CAT will contribute far more to their professional recognition than students elsewhere, which is inequitable.
We note that many other organisations such as the Office for Independent Adjudication for Higher Education are able to offer differential fees based upon organisational size. The decision of the ARB not to offer this means that small institutions with fewer resources are effectively subsiding much larger institutions.
Regarding the timing of making budgets. Because we only take small numbers of students and the numbers are variable, we are not able to set an operating budget until July/August due to the unpredictability of student fee income.
The introduction of the fees is very poorly timed coming as it does part way through an academic cycle when budgets have already been set. The decision by ARB to postpone payment until August is not helpful. It simply means that in the first year of charging fees for accreditation services schools are having to pay twice.
• Anything in the structure of the fees that could have a disproportionate impact on particular groups of students or other individuals, in light of our commitment to Equality, Diversity and Inclusion.
The Centre for Alternative Technology sits outside the norm of architectural education UK. The structure/delivery of the course (one full residential week on site each month) is attractive to students seeking an alternative model to the standard format of other full time courses and so provides a means of studying that will suit a variety of specific personal needs, such as caring, parenting, work life balance and so on. In addition, the course ethos/content (with its fundamental focus on Sustainability in architecture) means that we provide a highly specialist destination for students seeking a very different educational experience that is not catered for by the mainstream architectural providers. The loss or erosion of this provision is counter to the ARB aims of widening participation, and the additional cost per student is effectively a tax or barrier on their Diversity and Inclusion.
We are supportive of the ARB intention to open up access to Masters level study to a wider audience than just part 1 architecture students. Our concern is that this new fee will erode our provision and inevitably lead to an increase in the fees we charge. This in turn will have a knock-on effect to recruitment and therefore access to the specialist course we provide.
The new fee has a disproportionate impact upon small providers like CAT. With less money we will be unable to provide support for students with our own bursaries for widening participation, or provide the level of additional support for students with special educational or learning needs that we aspire to.
• Any further regulatory impacts to which you would like to draw to our attention.
Currently the funding for architecture courses means that students have to embark upon a Part II Masters programme within 3 years of graduating from an undergraduate programme. The funding model for students entering Masters level programmes in future remains unclear. Will this 3 year rule still apply if part 1 courses are not accredited? Will applicants from cognate disciplines be able to access the same level of funding or will they only have access to the less generous postgraduate funding?
Alternatively, will the new regulations have the effect to preclude all architecture students from undergraduate Masters funding? Most other integrated Masters courses only attract an additional single years funding, rather than the two years funding for an MArch part II qualification. This would provide a large financial barrier to continuing Architecture education beyond initial undergraduate degree and Part I training.
The ARB fees for developing new programmes in architecture, especially for small, alternative, specialist providers like CAT, will inhibit development, leading to less educational innovation and a teaching model based on a homogeneous approach. Continued erosion of an operating budget for a programme will ultimately be seen in less resource to deliver programmes restricting the expensive practical experience, and reducing external expertise that enriches the teaching and learning.
ARB state that the new fees are set to cover ARB costs in running the new accreditation process. The calculation of this fee is not transparent and mechanisms for how this is monitored and adjusted in future have not been set out.
An additional cost will also be borne by institutions in relation to increased requirements for preparing for the new ARB process, including the costs of hosting an ARB visit. For small institutions such as CAT the increased requirement will have to be met by a smaller team, than most other universities.
Please note if this response is published then we would like the following specific financial text redacted. It does not affect the rest of our response but is given directly to the ARB so that the impact on finances on us a small institution can be directly measured
"Our income is around £250- 280K per year from the MArch students (student numbers are variable).
When our budget is set: Staff Salaries and visiting lecturers; Student support and Admin; Accrediting University fees; Acommodation; Subscriptions and External Quality Assurance (QAA) accounts for around £235K of this which leaves around 20K-40K for materials/travel and overheads to CAT for operating the site. In normal University practice, £60-70K would be a reasonable overhead figure for a HE course of the MArch size to the organisation, however a normal HE Part 1 or Part 2 course would have fees of £9250 per student per year i.e 1/3rd more than CAT, with many accredited organisations also having students for an additional three years."
Thanks
• Anything further that ARB should consider regarding how the fees are to be paid. For example, whether there is anything you would like us to know about the timing of learning provider budget setting and the timing at which we invoice for the fees.
The Centre for Alternative Technology is a unique institution dedicated to researching and teaching and disseminating positive solutions for environmental change. Our Graduate School of the Environment courses are respected across the world, providing a big-picture, integrated approach to sustainability and the knowledge, skills, inspiration and networks to make a real practical difference. We have a number of postgraduate degrees wholly focussed on this mission but only one ARB-accredited course, the M.Arch in Sustainable Architecture, which is validated by the University of East London (UEL) and has fewer than 50 students in total.
We dispute the assertion that the size of the learning provider has minimal impact on the ARB’s work. An organisation the size of CAT with a single part II course and 50 students is far less complex than for example the Bartlett School with 3,360 students (2018-19 data) and 6 undergraduate and 19 postgraduate programmes. As you have stated the law is clear that fees must not exceed the reasonable costs of providing the service.
As a small specialist school of architecture with only one ARB accredited course with less than 50 students (currently there are 36 students across both years), a £9,200.00 per annum fee payable to ARB becomes a significant proportion of our budget which is shown below.
As an alternative provider, our course fees per student are around 2/3 of the fees available to standard university courses). Our income is around £250- 280K per year from the MArch students (student numbers are variable).
When our budget is set: Staff Salaries and visiting lecturers; Student support and Admin; Accrediting University fees; Acommodation; Subscriptions and External Quality Assurance (QAA) accounts for around £235K of this which leaves around 20K-40K for materials/travel and overheads to CAT for operating the site. In normal University practice, £60-70K would be a reasonable overhead figure for a HE course of the MArch size to the organisation, however a normal HE Part 1 or Part 2 course would have fees of £9250 per student per year i.e 1/3rd more than CAT, with many accredited organisations also having students for an additional three years.
In addition CAT does not receive any other statutory funding from Government or HEFCW (the Welsh equivalent to the office for students); just UG fees for Part 2 architecture students. As an alternative provider unlike Universities, CAT is unable to apply directly for UKRI research funding, which can also be a source of income to an institution. Our only other sources of income would be a proportion of general fundraising by Centre for Alternative Technology, but that is not significant as much of it is restricted project funding rather than core funding, and the core funding would support the general overheads.
Consequently, the proposed fee charged by ARB to CAT equates to around £200 per student per year or £400 in total. When compared to larger schools of architecture with perhaps 10 times the number of students at undergraduate ad postgraduate level this rigid ‘one size fits all’ fee is inequitable. Using the example of the Bartlett School given earlier the £9200 annual fee would be equivalent to £3 per student per year. It means in effect, that students studying at CAT will contribute far more to their professional recognition than students elsewhere, which is inequitable.
We note that many other organisations such as the Office for Independent Adjudication for Higher Education are able to offer differential fees based upon organisational size. The decision of the ARB not to offer this means that small institutions with fewer resources are effectively subsiding much larger institutions.
Regarding the timing of making budgets. Because we only take small numbers of students and the numbers are variable, we are not able to set an operating budget until July/August due to the unpredictability of student fee income.
The introduction of the fees is very poorly timed coming as it does part way through an academic cycle when budgets have already been set. The decision by ARB to postpone payment until August is not helpful. It simply means that in the first year of charging fees for accreditation services schools are having to pay twice.
• Anything in the structure of the fees that could have a disproportionate impact on particular groups of students or other individuals, in light of our commitment to Equality, Diversity and Inclusion.
The Centre for Alternative Technology sits outside the norm of architectural education UK. The structure/delivery of the course (one full residential week on site each month) is attractive to students seeking an alternative model to the standard format of other full time courses and so provides a means of studying that will suit a variety of specific personal needs, such as caring, parenting, work life balance and so on. In addition, the course ethos/content (with its fundamental focus on Sustainability in architecture) means that we provide a highly specialist destination for students seeking a very different educational experience that is not catered for by the mainstream architectural providers. The loss or erosion of this provision is counter to the ARB aims of widening participation, and the additional cost per student is effectively a tax or barrier on their Diversity and Inclusion.
We are supportive of the ARB intention to open up access to Masters level study to a wider audience than just part 1 architecture students. Our concern is that this new fee will erode our provision and inevitably lead to an increase in the fees we charge. This in turn will have a knock-on effect to recruitment and therefore access to the specialist course we provide.
The new fee has a disproportionate impact upon small providers like CAT. With less money we will be unable to provide support for students with our own bursaries for widening participation, or provide the level of additional support for students with special educational or learning needs that we aspire to.
• Any further regulatory impacts to which you would like to draw to our attention.
Currently the funding for architecture courses means that students have to embark upon a Part II Masters programme within 3 years of graduating from an undergraduate programme. The funding model for students entering Masters level programmes in future remains unclear. Will this 3 year rule still apply if part 1 courses are not accredited? Will applicants from cognate disciplines be able to access the same level of funding or will they only have access to the less generous postgraduate funding?
Alternatively, will the new regulations have the effect to preclude all architecture students from undergraduate Masters funding? Most other integrated Masters courses only attract an additional single years funding, rather than the two years funding for an MArch part II qualification. This would provide a large financial barrier to continuing Architecture education beyond initial undergraduate degree and Part I training.
The ARB fees for developing new programmes in architecture, especially for small, alternative, specialist providers like CAT, will inhibit development, leading to less educational innovation and a teaching model based on a homogeneous approach. Continued erosion of an operating budget for a programme will ultimately be seen in less resource to deliver programmes restricting the expensive practical experience, and reducing external expertise that enriches the teaching and learning.
ARB state that the new fees are set to cover ARB costs in running the new accreditation process. The calculation of this fee is not transparent and mechanisms for how this is monitored and adjusted in future have not been set out.
An additional cost will also be borne by institutions in relation to increased requirements for preparing for the new ARB process, including the costs of hosting an ARB visit. For small institutions such as CAT the increased requirement will have to be met by a smaller team, than most other universities.
Please note if this response is published then we would like the following specific financial text redacted. It does not affect the rest of our response but is given directly to the ARB so that the impact on finances on us a small institution can be directly measured
"Our income is around £250- 280K per year from the MArch students (student numbers are variable).
When our budget is set: Staff Salaries and visiting lecturers; Student support and Admin; Accrediting University fees; Acommodation; Subscriptions and External Quality Assurance (QAA) accounts for around £235K of this which leaves around 20K-40K for materials/travel and overheads to CAT for operating the site. In normal University practice, £60-70K would be a reasonable overhead figure for a HE course of the MArch size to the organisation, however a normal HE Part 1 or Part 2 course would have fees of £9250 per student per year i.e 1/3rd more than CAT, with many accredited organisations also having students for an additional three years."
Thanks