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Consultation responses

Government and other bodies publish consultations as a means of seeking public input and evidence into policy-making and legislation. APM submissions are contained within this section.

Current consultations

You will see below a list of all the consultations APM has responded to (previous dates) or are currently considering responding to (future dates).

On the latter, we will only respond if we receive enough interest to warrant one.

Please send your comments to external.affairs@apm.org.uk, letting us know which consultation you’re responding to.  There is no need to answer every question, just those linked to your area of expertise.

You can also respond separately of the APM response on the consultee website.

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20/03/24 – DfE Advanced British Standard (ABS)

Consultation title: A world-class education system: The Advanced British Standard consultation


Consulting organisation: UK Department for Education


Deadline: 20 March 2024 (please provide any response for APM to consider by 11 March 2024)


About this consultation 


This consultation makes proposals and seeks views on the design of the Advanced British Standard.

In particular:

  • Aims and purposes of the ABS
  • Design of the ABS including:
    • Structure and coverage
    • Subjects, employability, enrichment and pastoral (EEP) activities and the industry placement
    • English and maths
  • Assessment, grading and awarding
  • Supporting 16-19 education providers
  • Supporting students and the wider system


A world-class education system: The Advanced British Standard consultation - Department for Education - Citizen Space

Background to inquiry


The Government are seeking to introduce the Advanced British Standard (ABS), a new Baccalaureate-style qualification framework for 16-19 year-olds. The ABS will:

  • Bring together technical and academic routes into a single framework, taking the best of A levels and T Levels.
  • Increase the number of taught hours for all students.
  • Require students to study maths and English to the age of 18.
  • Offer greater breadth, increasing the average number of subjects students take post 16, with students able to choose a combination of bigger and smaller subjects, called ‘majors’ and ‘minors’.
  • Have a clear offer for all students.

Consultation questions


There are 58 questions in total, too many to add here. They are available on pages 63-69 at A world-class education system: The Advanced British Standard consultation

How to respond


Please send your comments to external.affairs@apm.org.uk by 11 March 2024, letting us know which consultation you’re responding to.  There is no need to answer every question, just those linked to your area of expertise.

You can also respond separately of the APM response on the DfE website, deadline for responses there is 20 March 2024.

06/03/24 – Public Accounts Select Committee: Lessons learned: Delivering value from government investment in major programmes

Consultation title: Delivering value from government investment in major programmes


Consulting organisation: House of Commons: Public Accounts Select Committee


Deadline: Response submitted


About this consultation 


Based on the NAO report, the Committee will take evidence from HM Treasury and the Infrastructure and Projects Authority, on subjects including:

  • Examples of best practice in generating economic, social or environmental value;
  • How to place such benefits at the heart of project design and delivery;
  • How to review and evaluate delivery.

If you have any evidence on these issues, please let us know.

https://committees.parliament.uk/work/8147/lessons-learned-delivering-value-from-government-investment-in-major-programmes/

Background to inquiry


Both the Committee and the National Audit Office (NAO) scrutinise how major projects are delivered, including inquiries on resetting of Government programmes and lessons from major projects and programmes.

As part of this theme, the NAO’s report on delivering value from Government investment in major programmes looks at a small selection of projects, including High Speed 1 and the Millennium Dome, to identify lessons Government can learn to generate value from major programmes.

Consultation questions


This consultation asks for evidence on the following:

  • Examples of best practice in generating economic, social or environmental value;
  • How to place such benefits at the heart of project design and delivery;
  • How to review and evaluate delivery.

16/02/24 – UK Labour Party Major Capital Projects Review

Consultation title: Major Capital Projects Review


Consulting organisation: UK Labour Party 


Status: Response submitted


About this consultation 


The Major Capital Projects review will look at all major aspects of infrastructure project delivery, including what is needed to get growth in the economy and save costs to the taxpayer.

The review will make recommendations on how to: improve the initial scoping and budgeting of major projects and infrastructure, improve the capacity of public bodies to effectively deliver infrastructure;  unlock wider growth around projects, deliver value for money and better performance management, and boost the British supply chain. It is set to conclude in the Spring.

It will cover:

  • Improving estimates of costs, benefits, and timescales to completion.
  • Whether the Civil Service has access to the skills it needs for successful delivery of major projects.
  • How greater transparency and regular reporting of project data could help to improve delivery.
  • How we can plan for changes in the external environment, including inflation, rising interest rates and other factors.
  • How projects can contribute more to UK economic goals, including supporting UK supply chains, jobs, and skills.
  • Investigating governance of how major projects are delivered and fast tracked nationally and locally.

Background to inquiry


As announced at Labour Party conference in 2023, a review led by the Shadow Chief Secretary into the delivery of major projects and infrastructure is now being undertaken. This work will run alongside the pre existing review launched by Shadow Transport Secretary Louise Haigh, which will focus on turning around Britain’s rail and urban transport infrastructure.

Consultation questions


Headline Questions

  1. How can we improve estimates of costs, benefits, and timescales to completion for major projects?
  2. Does the Civil Service have access to the skills it needs for the successful delivery of major projects? If not what is needed?
  3. How can we ensure greater transparency and regular reporting of project data to improve delivery?
  4. How can government plan for changes in the external environment, including inflation, rising interest rates and other factors?
  5. How can projects contribute more to UK economic goals, including supporting UK supply chains, jobs, and skills?
  6. How can the machinery of government be improved to support the delivery of major capital projects?

Current and future major projects

  1. What projects or initiatives do you think should be prioritised for the future development of UK infrastructure, and why?
  2. Are there specific technological advancements or innovations that you believe can significantly benefit infrastructure delivery?
  3. What can we learn from the experience and approach taken by other nations in terms of accelerating infrastructure projects?

Procurement and supply chains

  1. How can we enable more efficient local supply chains?

Future reforms, funding and investment

  1. What do you see as the main obstacle to the private sector investing more significantly to help improve UKs infrastructure?
  2. Are there regulatory changes or policy recommendations that you believe would be beneficial to accelerate investment and delivery?
  3. What do you see as the main alternative funding models* available to the sector to fund stations and their surrounding city developments?
  4. Are you aware of best practice approaches and case studies that have used alternative models with successful outcomes?

23/05/23 – Public Accounts Committee Inquiry: Resetting Government Programmes

Consultation title:  Public Accounts Committee Inquiry: Resetting Government Programmes


Status:  Response submitted


Background to inquiry


Both the National Audit Office and Public Accounts Committee have examined a number of government programmes which have needed a “reset” for various reasons.

The Committee will question two panels of witnesses on programmes that have required resets for any reason such as a reset to what the programme is delivering, how or when it will deliver, or all of these elements.

For the first panel, the Committee will question the Senior Responsible Officers of a series of major projects and programmes that have required such resets:
The Department of Transport’s Crossrail project, the Department of Work and Pensions’ Universal Credit rollout, the MoD’s Ajax tank programme and the MoJ’s electronic monitoring (or “tagging”) programme.

The second panel of witnesses will include questioning on the governance of major projects by HM Treasury and the Infrastructure Projects Authority.

This inquiry, based on an NAO investigation, will aim to set out a common framework for thinking about programme resets and support decision makers in building a realistic understanding of the challenges. The inquiry will not be looking in detail at any individual projects subject to a reset.

17/02/23 – IfATE: Mandatory Qualifications Criteria

Consultation title:  Consultation on proposed updates to the mandatory qualifications criteria


Consulting organisation:  Institute for Apprenticeships and Technical Education (IfATE)


Status:  Response submitted


About this consultation


The Institute for Apprenticeships and Technical Education is holding a consultation on proposed updates to the mandatory qualifications criteria.

Background


Learning from the last few years of apprenticeship delivery, IfATE believe there is room for improvement in how qualifications are used and operate within apprenticeships.

They are proposing changes to the requirements that are used when deciding whether an apprenticeship should include a mandatory qualification (a qualification which is mandated in the occupational standard, to be completed by an apprentice as part of their apprenticeship).

In updating criteria, IfATE will strengthen and make clearer the expectations for the suitability of a qualification, to ensure that only those which are truly necessary and deliver for apprentices and employers are included. They also present proposals to integrate a mandated qualification’s assessments with the apprenticeship end-point assessment.

Consultation questions


IfATE invites written submissions from APM members on any or all of the questions below:

Q1: To what extent do you agree that qualifications should only be mandated where they fulfil a regulatory, professional body, or labour market requirement?

Q2: To what extent do you agree that qualifications which provide ‘fuller occupational coverage’ or provide structure for off-the-job training should not be mandated on this basis alone?

Q3: To what extent do you agree with our approach to include more specific evidence criteria when mandating a qualification due to regulatory or professional body requirements?

Q4: To what extent do you agree with our proposals for requiring evidence of labour market demand for a mandatory qualification? We have made some suggestions of the kinds of evidence we would expect to see submitted – in your response, we would be interested to hear of other sources of evidence which could be used to evidence employer demand.

Q5: To what extent do you agree that where a qualification has not been approved through any current or future approval process, that outcome should inform decisions about its suitability for use in an apprenticeship.

Q6: To what extent do you agree that a qualification mandate should specify exactly which qualifications can be used to fulfil the mandate?

Q7: To what extent do you agree that qualifications should align with, and not go wider than, the KSBs set out in the occupational standard?

Q8: To what extent do you agree that mandated qualifications should be at the same or lower level as the apprenticeship?

Q9: To what extent do you agree that where possible, a qualification should be integrated into the EPA?

Q10: We have identified some scenarios in which integration might not be appropriate or possible. If you have further examples, please provide details to support our policy development around integration.

Q11: To what extent do you agree that all integrated assessments should assess the same subset of KSBs?

Q12: To what extent do you agree that the defined subset of KSBs cannot be assessed by multiple smaller qualifications?

Q13: To what extent do you agree that only one subset of the KSBs should be identified for assessment by integrated qualifications?

Q14: We have set out our preferred approach to integration and one we know to work. We would welcome your thoughts on how this approach might work for you and any alternative modes of integration you might wish to propose.

Q15: To what extent do you agree that the EPA’s assessment plan should indicate which of the integrated qualification’s grade boundaries should attest to occupational competence?

Q16: To what extent do you agree that awarding bodies setting the qualification’s integrated assessments is the best way to protect the independence and reliability of the EPA?

Q17: To what extent do you agree that it is fairer to apprentices if we do not allow awarding bodies to permit centre adaptation of an integrated qualification’s assessments?

Q18: To what extent do you agree that, for integrated written and onscreen assessments, at least one assessor must be independent in accordance with the description in the proposal?

Q19: To what extent do you agree that integrated practical assessments must be conducted by a person suitably qualified to make assessment judgements, but who has no vested interest in the apprentice’s or the assessment’s outcomes?

Q20: To what extent do you agree that, where such arrangements would present significant challenges to a centre, the tutor who has delivered the content may deliver the integrated assessment, provided they are joined by at least one other assessor who is sufficiently independent. Please provide examples of any potential challenges in your response, where applicable.

Q21: To what extent do you agree that integrated assessments must be marked or graded by the awarding organisation, independent persons appointed by the awarding organisation, centre staff with sufficient independence, or a combination of the above?

Q22: With reference to the General Impact Assessment (Section 4.1), are there any other impacts, including costs, savings or benefits, which we have not identified? Please provide examples, data and/or evidence where possible.

Q23: With reference to the General Impact Assessment (Section 4.1), are there any additional steps that could be taken to mitigate any negative impact, resulting from the proposed approach to approvals? Please provide examples, data and/or evidence where possible.

Q24: With reference to the Equality Impact Assessment (Section 4.2), are there any other potential impacts (positive or negative) that have not been identified? Please provide examples, data and/or evidence where possible.

10/10/22 – Public Accounts Select Committee: Developing workforce skills

Consultation title:  Developing workforce skills for a strong economy


Consulting organisation:  House of Commons: Public Accounts Select Committee


Status:  Response submitted


About this consultation


In July 2022 the NAO reported that the UK “faces a major challenge in ensuring it has a sufficiently skilled workforce”, with the head of the NAO, the Comptroller and Auditor General, concluding that “There is a risk that, despite government’s greater activity and good intent, its approach may be no more successful than previous attempts to provide the country with the skills it needs.”

A skilled workforce is critical to the country’s economic success and to achieving other government aims such as “levelling up”. Economic and societal changes are making the skills challenge more acute - the UK’s exit from the EU has reduced the supply of workers from member states and potentially increased the need for the country to train its own workers. The Government’s commitment to achieve ‘net zero’ greenhouse gas emissions by 2050 will create new skilled jobs and around one in five existing jobs is likely to be affected by the transition.

But the NAO found that participation in government-funded further education and skills training has declined significantly, particularly in disadvantaged areas. The number of adult learners fell by 48% over the last decade, from 3.2 million in 2010/11 to 1.6 million in 2020/21. From 2015/16 to 2020/21, the number of participants aged 19 and over in England’s 20% most disadvantaged areas dropped by 39%, compared with a 29% drop overall.

Largely because of the drop in learners, there was a 46% fall in the Skills Index – government’s measure of the impact of the further education system on productivity – from 2012/13 to 2020/21.

The 2022 white paper Levelling Up the United Kingdom set out the government’s plans to address regional and local inequalities, but according to the NAO report “its aims go only some way towards addressing the decline in participation in skills training”. By 2030, the government wants 200,000 more people in England to successfully complete high-quality skills training annually, including 80,000 more people in the lowest skilled areas. Achieving this would only partly reverse the fall of around 280,000 learners in the 20% most disadvantaged areas since 2015/16.

If you have evidence on these findings and issues to inform PAC’s questioning of the departments, please submit it.

09/05/22 – Department for Transport: Transport Labour Market and Skills

Consultation title:  Transport labour market and skills


Consulting organisation:  Department for Transport, UK Government


Status:  Response submitted


About this consultation


This consultation considers the barriers and opportunities to developing skills and careers across the transport sector.

Background


This consultation sets out 5 pillars that form the basis for the work the Department for Transport wants to carry out in collaboration with external partners, including the transport industry, academia and the third sector. These pillars are:

  • boosting diversity, inclusion and social mobility
  • improving training and employment
  • promoting careers in transport
  • preparing for future skills
  • building evidence and evaluating progress

Informed by public response to this paper, the 5 pillars will set the direction for the work of an industry-led taskforce.  The taskforce and the Department will develop a programme to support the sector in accessing skilled workers to create a transport system fit for the future. 

Consultation Questions


The Department would like APM member comment on five questions, as well as any more general comments:

1) In your view, what skills does the transport sector need in the future?

2) How, in your view, can current qualification and training routes be made more accessible for those who want to pursue a career in the transport sector?

3) What, in your view, are effective ways to attract young people and career changers into a career in the transport sector?

4) What, in your view, are the barriers to further increasing diversity, inclusion and social mobility in the transport sector?

5) How, in your view, can barriers to diversity, inclusion and social mobility in the transport sector be reduced?

6) Any other comments.

15/04/22 – Scottish Government: Strategic Transport Projects Review

Consultation title:  Draft Second Strategic Transport Projects Review for Scotland


Consulting organisation:  Transport Scotland, Scottish Government


Status:  Response submitted


About this consultation


Transport Scotland has developed the Draft Second Strategic Transport Projects Review (STPR2) for Scotland. 

It now wishes to get opinions, from Scottish members and others, on what has been proposed.  The review will inform Scottish Ministers decisions on transport investment in Scotland for the next 20 years (2022-2042).

Consultation on the draft second Strategic Transport Projects Review (STPR2) for Scotland

Background


STPR2 is one of the mechanisms for delivering the Vision, Priorities and Outcomes of the second National Transport Strategy (NTS2). It is an important tool for achieving the Scottish Government’s commitment to 20% reduction in vehicle kilometres by 2030 and contributing to Scotland’s net zero greenhouse gas emissions target by 2045.

STPR2 considers the transport needs of Scotland’s people and communities and provides an overview of transport investment that is required to deliver the National Transport Strategy priorities and objectives of the Review.

It does not cover routine day-to-day motorway and trunk road maintenance and committed improvements; rail network operations, maintenance and renewal; and revenue funding for public transport services.

STPR2 makes 45 recommendations grouped under six themes.  The themes are:

  1. Improving active travel infrastructure
  2. Influencing travel choices and behaviours
  3. Enhancing access to affordable public transport
  4. Decarbonising transport
  5. Increasing safety and resilience on the strategic transport network
  6. Strengthening strategic connections

And the 45 recommendations for future project development can be seen on pages xv-xix in the consultation document - STPR2 Draft Technical Report.

Consultation Questions


There are 45 questions in total, too numerous to list here, but they can be accessed at Consultation questions and respondent information form.

20/01/22 – Education Select Committee: Future of Post-16 Qualifications

Consultation Title:  Future of Post-16 Qualifications


Consulting organisation:  House of Commons: Education Select Committee


Status:  Response submitted 


About this consultation


The Education Committee will hold an inquiry examining how effectively post-16, level 3 education and qualifications (such as A Levels, T Levels, BTECs and apprenticeships) prepare young people for the world of work.

The Committee will consider the Government’s current work and proposals in this area and look at whether an alternative model, which enables a greater blend of academic and vocational pathways, should be explored.

The Government has several proposals underway on post-16 qualifications:

  • Level 3 qualification reform: The Government has responded to its consultation on reforming level 3 qualifications, with a policy statement published in July 2021. This sets out a timeline for reforms to level 3 qualifications, which includes defunding from technical qualifications that overlap with T Levels
  • The Skills and Post-16 Education Bill, which had its second reading in the House of Commons on Monday 15 November
  • The further rollout of T Levels

The Committee’s new inquiry will look at the impact of these changes and whether existing and proposed arrangements go far enough to prepare young people for the world of work.