"A local authority much have regard to the desirability of such a formula being simple, objective, measurable, predictable in effect and clearly expressed" (The School Funding (Wales) Regulations 2010, Section 10 paragraph 2)
Did the authority provide a written explanation of the Conwy funding formula? No. They provided their Section 52 statements but no rationale or explanation for the formula.
Is the formula measurable? Is it predictable? Yes. With the necessary specific information related to a school it ought to be possible to work out how a school's funding was arrived at.
"The regulations require that 70 per cent of the funding must be distributed on the basis of pupil numbers. (School Funding in Wales Research Briefing August 2018)
Is 70% of school funding based on pupil numbers? Yes. Pupil-led funding is clearly stated within the Section 52 information to make up c.70% of the school funding, and in addition, since base level funding per pupil is the same acoss all schools in specific year groups, Conwy is also ensuring "the same funding for pupils of the same age irrespective of the nature of the school which they attend" (The School Funding (Wales) Regulations 2010, Section 23 paragraph 1b).